ALGOA BAY SEA-BASED AQUACULTURE DEVELOPMENT ZONE

FINAL BASIC ASSESSMENT REPORT

BASIC ASSESSMENT PROCESS IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 (ACT NO. 107 OF 1998)

APPENDIX F: STAKEHOLDER CONSULTATION REPORT

research & monitoring

Anchor Research & Monitoring Report No, 1808/4

ALGOA BAY SEA-BASED AQUACULTURE DEVELOPMENT ZONE

FINAL BASIC ASSESSMENT REPORT

BASIC ASSESSMENT PROCESS IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 (ACT NO. 107 OF 1998)

APPENDIX F: STAKEHOLDER CONSULTATION REPORT

October 2019

research & monitoring

8 Steenberg House, Silverwood Close, Tokai 7945, South Africa https://anchorenvironmental.co.za

Authors: Vera Massie, Ken Hutchings, Jessica Dawson and Barry Clark

Citation: Massie V, Hutchings K, Dawson J and Clark B, 2019. Algoa Bay sea-based Aquaculture Development Zone – Final Basic Assessment Report: Appendix F Stakeholder Consultation Report. Supporting documentation for the Basic Assessment process conducted in terms of the National Environmental Management Act (No. 107 of 1998). Report prepared for the Department of Agriculture, Forestry and Fisheries by Anchor Research and Monitoring (Pty) Ltd. Anchor Report Number: 1808/4, October 2019.

Title Page Photo Credit: Shutterstock

research & monitoring PROJECT DETAILS

Objective Application for Environmental Authorisation in terms of the National Environmental Management Act, 1998 (Act No 107 of 1998) Applicant Department of Agriculture, Forestry & Fisheries Environmental Assessment Practitioner (EAP) Vera Massie under supervision of Dr Barry Clark from Anchor Research & Monitoring (Pty) Ltd

Anchor Project Name Algoa Bay Sea-based Aquaculture Development Zone Basic Assessment Process Anchor Project Number 1808

Report name Algoa Bay Sea-based Aquaculture Development Zone, Basic Assessment Process in Terms of the National Environmental Management Act, 1998 (Act No. 107 Of 1998) - Final Basic Assessment Report, Appendix F: Stakeholder Consultation Report Status Decision-making phase Application submission date 19 July 2019 Competent Authority Reference 14/12/16/3/3/1/2055

Case Officer Ms Matlhodi Mogorosi

OVERVIEW OF PROJECT OUTPUTS BASIC ASSESSMENT REPORT AND APPENDICES

Basic Assessment Pre-Application BAR – Released for comment between 28 March and 30 April 2019 Report (BAR) Draft BAR – Released for comment between 23 July 2019 and 4 September 2019 Final BAR – Current – For submission to Competent Authority Appendix A Environmental Management Programme (EMPr) Appendix B Details of EAP, Expertise and Declaration Appendix C Details of Specialists, Expertise and Declaration Specialist studies: Appendix D 1. Benthic Mapping Assessment for the Proposed Algoa Bay Sea-based Aquaculture Development Zone (Dawson et al. 2019) 2. Dispersion Modelling Study for the Proposed Algoa Bay Sea-based Aquaculture Development Zone (Wright et al. 2019) 3. Marine Specialist Study 2019 (Hutchings et al. 2019) 4. Maritime Underwater Heritage Specialist Study (Gribble 2019) 5. Comparative Assessments for the Development of the Proposed Sea-based Aquaculture Development Zone Located within Algoa Bay in the Eastern Cape in South Africa (Rhodes University August 2016) a. Socio-economic Report b. Ecological Report c. Feasibility study Appendix E Background Information Document Appendix F Stakeholder Consultation Report Appendix G Stakeholder comments and response table 1. Pre-application-phase stakeholder consultation 2. Application-phase stakeholder consultation Appendix H Additional Information

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NOTE: In response to stakeholder comments, the Draft Basic Assessment Report (BAR) and Appendices were updated at the end of the application-phase commenting period (23 July – 4 September2019) to produce the Final BAR. All changes to the content in the Final BAR and Appendices are underlined for easier reference (note that changes incorporated in the Draft BAR following pre- application consultation are nolongerhighlighted inthe Final BAR). Stakeholder comments received during the pre-application and application phase stakeholder engagement processes and responses by Anchor, specialists and DAFF, are included inAppendix F and G of the Final BAR.

ii research & monitoring TABLE OF CONTENTS

1 INTRODUCTION ...... 1

2 PRE-APPLICATION PROCESS STAKEHOLDER CONSULTATION ...... 2

3 APPLICATION PROCESS STAKEHOLDER CONSULTATION ...... 3

4 SUMMARY OF STAKEHOLDER ENGAGEMENT ...... 5

4.1 PRE-APPLICATION PHASE ...... 6 4.2 APPLICATION-PHASE ...... 15

5 PUBLIC RESISTANCE AGAINST THE PROPOSED ADZ ...... 18

6 APPENDICES F1-F7...... 18

APPENDIX F1: PROOF OF THE PLACEMENT OF THE RELEVANT ADVERTISEMENTS AND NOTICES ...... 19 APPENDIX F2: PROOF THAT THE ORGANS OF STATE AND KEY STAKEHOLDERS RECEIVED WRITTEN NOTIFICATION OF THE PROPOSED ACTIVITIES ...... 23 APPENDIX F3: LIST OF REGISTERED INTERESTED AND AFFECTED PARTIES ...... 26 APPENDIX F4: EMAILS SENT TO STAKEHOLDERS...... 54 APPENDIX F5: SUBSTANTIVE COMMENTS ...... 56 APPENDIX F6: MINUTES OF MEETINGS HELD ...... 58 APPENDIX F7: ATTENDANCE REGISTERS AND PRESENTATIONS ...... 60

iii Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

1 INTRODUCTION The Department of Agriculture, Forestry and Fisheries (DAFF1), as the lead agent for aquaculture management and development in South Africa, intends to establish and manage a sea-based Aquaculture Development Zone (ADZ) in Algoa Bay in the Eastern Cape. DAFF recently successfully established the first sea-based ADZ in Saldanha Bay in the Western Cape and has received an Environmental Authorisation for a land based ADZ in the Eastern Cape at Qolora. A Sea-based ADZ typically consists of a selection of designated precincts that provide opportunities for existing aquaculture operations to expand and new ones to be established. ADZs are intended to boost investor confidence by providing ‘investment ready’ platforms with strategic environmental approvals and management policies already in place, allowing commercial aquaculture operations to be set up without the need for lengthy, complex and expensive approval processes. It is anticipated that an ADZ will create incentives for industry growth, provide marine aquaculture services and enhance consumer confidence. An ADZ can provide economic benefits to the local community through job creation and regional economic diversification.

Aquaculture is one of the sectors that form part of Operation Phakisa under the Ocean’s Economy in South Africa. Operation Phakisa is an initiative of the South African government which aims to implement priority economic and social programmes better, faster and more effectively. Operation Phakisa was launched by the President of the Republic in October 2014. The sector offers significant potential for rural development, especially for marginalised coastal communities. The proposed development will provide employment opportunities for the local and regional communities.

The proposed development triggers several Listed Activities in the Environmental Impact Assessment (EIA) Regulations, 2014 (as amended by Government Notice No. 40772 of 7 April 2017), promulgated in terms of the National Environmental Management Act (Act No. 107 of 1998) (NEMA). DAFF is therefore required to apply for Environmental Authorisation to the National Department of Environmental Affairs (DEA). DAFF appointed Anchor Research & Monitoring (Pty) Ltd (Anchor) to undertake the Basic Assessment (BA) process for the proposed Aquaculture Development Zone in terms of the National Environmental Management Act 107 of 1998, as amended (NEMA).

A Basic Assessment process must be undertaken in compliance with Government Notice (GN) R. 326 of 2017 (2014 Environmental Impact Assessment (EIA) Regulations as amended) and with the guideline documents for EIA processes and stakeholder consultation, as produced by the Department of Environmental Affairs.

This report documents the stakeholder process conducted for the proposed Algoa Bay sea-based Aquaculture Development Zone Basic Assessment process (note that the Background Information Document constitutes a standalone document in the BAR as Appendix E).

1 Please note that the Presidency announced a new cabinet and appointed new Ministers in May 2019. The Department of Environmental Affairs was merged with the Fisheries and Forestry divisions of the Department of Agriculture, Forestry and Fisheries (formerly known as DAFF). The new merged Ministry is legally referred to as the Department of Environment, Forestry and Fisheries (DEFF). However, the implementation of the new Departments is still in progress and the Basic Assessment Report continues to refer to DAFF as the applicant and National DEA as the Competent Authority.

1 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

2 PRE-APPLICATION PROCESS STAKEHOLDER CONSULTATION The 2014 EIA Regulations (as amended) stipulate that the final Basic Assessment Report (BAR) has to be submitted within 90 days of receipt of the application by the competent authority. Experience has shown that 90 days for the submission of a BA including a thorough stakeholder consultation process is commonly impossible to achieve. The DEA therefore recommends that a ‘pre-application’ public participation process is conducted where major issues can be resolved before the application is submitted. This means that two stakeholder consultation processes are conducted throughout the Basic Assessment process, one prior to and one after the application is submitted.

Regulation 40(3) which states that: “Potential or registered interested and affected parties, including the competent authority, may be provided with an opportunity to comment on reports and plans […] prior to submission of an application but must be provided an opportunity to comment on such reports once an application has been submitted to the competent authority.”

The Regulations do not prescribe exactly when such pre-application stakeholder consultation may take place2 and the timing is left up to the discretion of the applicant and competent authority. However, it must be noted that stakeholder consultation must be undertaken at a time or time period that enables all I&APs an opportunity to comment and should there be any doubt by the applicant, EAP or the competent authority that all I&APs have not been given such opportunity, then there can be consideration of redoing or restarting the stakeholder consultation process.

A pre-application meeting was held with the competent authority and other relevant authorities in Cape Town on 30 January 2019 prior to the finalisation of the pre-application Basic Assessment Report. The following Departments attendended this meeting:

• Department of Agriculture, Forestry and Fisheries: Sustainable Aquaculture Management • Department of Environmental Affairs: Integrated Environmental Authorisations • Department of Environmental Affairs: Branch Oceans & Coasts

A pre-application stakeholder consultation process was conducted for a period of 30 days from the 28th March – 30th April 2019. The pre-application consultation was conducted three months prior to submission of the application for environmental authorisation. The pre-application stakeholder consultation process included the following actions:

i. All documents were made available on Anchor’s website at https://anchorenvironmental.co.za/public-documents ii. A public meeting was held at the Port Elizabeth Municipal Hall on 6 March 2019 (minutes and presentation in Appendix F6, attendance register in Appendix F7) iii. An authorities meeting was held at the Eastern Cape Department: Economic Development, Environmental Affairs and Tourism on 6 March 2019. iv. All registered stakeholders were notified via email of a commenting period of 30 days on 28th March 2019 (Appendix F4).16 Radio announcements in isiXhosa on Nkqubela FM during drive time.

2DEA 2017. Public Participation Guideline in Terms of National Environmental Management Act, 1998 Environmental Impact Assessment Regulations. Prepared by the Department of Environmental Affairs.

2 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

v. An advertisement in English was placed in the local newspaper “Port Elizabeth Express” on 5 December 2018 (Appendix F1) to invite stakeholders to register as an Interested and Affected Party; and vi. Notice boards in English were fixed at (See photos in Appendix F1) (note that updated posters will be fixed in the same locations during the application-phase public participation process): • On Hobie Beach near the pier • On the life saving hut at Bluewater Bay Beach • At the popular Blue Flag swimming beach at Wells Estate, St Georges beach vii. Registered letters were sent to key stakeholders as per Regulation 41(2)(b) (Appendix F2). viii. A stakeholder list was compiled and has been maintained (Appendix F3, email addresses and phone numbers are not included to protect the privacy of the stakeholders); ix. A comment and response report was compiled. Note that the Department requested that the comment and response report is included as a stand-alone Appendix to the BAR. Accordingly, the table has been extracted from this report and included in Appendix G of the BAR. x. A Background Information Document (BID) was compiled and uploaded on Anchor’s website (Appendix E of the BAR);

Note that the person conducting the stakeholder consultation process is not obliged by law to wait for a reference number from the competent authority prior to conducting a stakeholder consultation process (including placing an advertisement or holding a public meeting).

3 APPLICATION PROCESS STAKEHOLDER CONSULTATION The application for environmental authorisation was submitted to the DEA on 19 July 2019. The application-phase stakeholder consultation process was conducted from 23 July 2019 to 4 September 2019 and included the following actions:

i. All documents will be made available on Anchor Environmental’s website at https://anchorenvironmental.co.za/public-documents ii. All registered stakeholders were notified via email of a the commenting period and public meeting. iii. Sixteen Radio announcements were made in isiXhosa on Nkqubela FM during drive time to announce the meeting. iv. Two public meetings were held at the following locations (minutes and presentation in Appendix F6, attendance register in Appendix F7): a. Port Elizabeth, 31 July 2019, Main Hall/Reception Area, Port Elizabeth Vuyisile Mini Square, Govan Mbeki Ave, Port Elizabeth Central, Port Elizabeth, 6001, 18:00-21:00 b. Motherwell, 1 August 2019, Motherwell NU2 Community Hall, Chief Poto Street, Motherwell, 6211, 18:00-20:45 v. Updated notice boards in English and IsiXhosa were fixed at (See photos in Appendix F1):

3 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

a. At the Hobie Beach Surf Lifesaving Club b. At the Motherwell ZONKE SPAR - 93 Umnulu Street, Port Elizabeth, Motherwell (No photographic evidence available. Please contact ZONKE SPAR General Manager Wesley Kretzman on 041 462 2771 if confirmation is required). vi. One hardcopy of the Draft BAR and electronic copies on 10 CDs were made available to the public in Port Elizabeth and Motherwell at the following locations: a. Newton Park Library: Hurd St, Newton Park, Port Elizabeth, 6045 b. Motherwell Library: Corner Umlu and Ngqokweni St, Motherwell, Port Elizabeth, 6211 vii. The stakeholder list compiled duering the pre-application process was maintained (Appendix F3, email addresses and phone numbers are not included to protect the privacy of the stakeholders); viii. A comment and response report was compiled. Note that the Department requested that the comment and response report is included as a stand-alone Appendix to the BAR (Appendix G of the BAR). ix. A Background Information Document (BID) was compiled and uploaded on Anchor’s website (Appendix E of the BAR); x. The Draft BAR was couriered to the competent authority in form of two hard copies and an electronic copy on USB;

Once the decision has been issued registered stakeholders will be notified of DEA’s decision and appearl procedure as per EIA regulations.

4 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

4 SUMMARY OF STAKEHOLDER ENGAGEMENT To date, 766 stakeholders have been registered for the proposed development, which includes stakeholders from the 2010-2014 process. The following stakeholder types were registered throughout the Basic Assessment process

Table 1 Stakeholder groups and number of stakeholders registered in each group for the Basic Assessment Process for the proposed Aquacutlrue Development Zone in Algoa Bay.

Stakeholder category Number of stakeholders registered Accommodation 20 Accommodation association 1 Agriculture 1 Animal welfare 3 Aquaculture 15 Aquaculture association 2 Association for the Physically 1 Disabled Aviation 2 Commercial and small-scale fishery 25 Conservation 22 Construction Business 2 Divers and recreational fishers forum 1 Diving industry 4 Environmental Consultancy 15 Event management 2 Fishery association 2 Fishing industry 21 Gov. exclude from public 99 Gov. include in public 25 Heritage 4 Home Owners Association 3 Industry 15 Industry 1 Lifesaving 7 Marine safaris 1 Media 7 Potential investor 5 Private citizen 287 Ratepayers Association 4 Recreational 1

5 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

Stakeholder category Number of stakeholders registered Recreational business 2 Recreational fishery 5 Regional Business Association 1 Research institute 7 Resident 102 Restaurant 5 Sailing 6 Specialist 1 Sports events 8 Surfing committee 3 Tourism agency 1 Tourism operator 9 University 18

The stakeholder database is updated throughout the Basic Assessment process. Any interested and affected parties that wish to register during the 107-day waiting period for decision-making will be notified of the outcome of the decision by the Competent Authority. All registered stakeholders will be notified of the appeal period and applicable regulations.

Three public meetings and one authorities meeting were held during the public participation periods of this project. The minutes these meetings have been included in Appendix F6 of this stakeholder consultation report.

4.1 Pre-application phase During the pre-application meetings, stakeholders were informed of the new application process, the changes made to the project description since 2014, and to provide an overview of the environmental impact assessment. Concerns raised during these meetings were incorporated into the pre-application BAR where required. The pre-application BAR was made available to stakeholders on 28 March 2019 for a commenting period of 30 days.

During the pre-application process, 180 stakeholders submitted comments. Stakeholder comments received during the pre-application process and the response by Anchor, specialists and DAFF are included in the stakeholder comment and response report in Appendix G1 of the Final BAR. It was found that 32% of the comments were against the ADZ, while 31% were explicitly against finfish farming in Algoa Bay. Algoa 1 (Summerstrand site) was rejected by 13% of stakeholders who provided comment, while 17% were explicitly against finfish farming at Algoa 1 (Figure 1). It is important to note that the results presented below are not derived from a structured survey, but instead, the comments were interpreted and assigned a category to provide a high level understanding of the sentiment of registered stakeholders. These results therefore do not necessarily represent the sentiment of all people in Port Elizabeth or beyond.

6 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

Furthermore, it was noticeable that a large proportion of stakeholders did not appear to be familiar with the project description and were either unaware of DAFF’s intention to apply for bivalve farming at Algoa 1 and 6 and/or that other sites are considered in this application for environmental authorisation. An increased understanding of the difference between the two farming types and the impacts thereof would likely result in greater support for Algoa 6 and perhaps for bivalve farming at Algoa 1.

1.00, 0% 2.00, 1% 5.00, 3% 5.00, 3%

Neutral

Against Algoa 6 23.00, 13% 58.00, 32% In support In support of Algoa 6&7 only

Against Algoa 1 (finfish and bivalve) 30.00, 17% Against finfish at Algoa 1

Against finfish

Against ADZ 55.00, 31%

Figure 1 Interpretation of 180 comments submitted during the pre-application phase for the Basic Assessment process for the proposed sea-based Aquaculture Development Zone in Algoa Bay. Note the above data was obtained by interpreting the comments provided (i.e. this information was not the obtained from a survey) and does not necessarily represent the sentiment of all people in Port Elizabeth or beyond.

Of the 180 comments submitted, five comments were in support of the development, stating job creation, business opportunities for SMMEs and economic growth as the reasons. Eighteen comments were provided against the proposed development, although no reasoning was provided by these stakeholders. The remainder of the comments were negative and provided at least one reason for the opposition (156 stakeholders). The reasoned negative comments have been analysed for their content and the results are presented below.

The comments were assigned 23 broad categories, which included among others, concerns expressed regarding impacts on marine ecology, visual aesthetics, negative economic impacts, feasibility of the proposed ADZ etc. (Table 2 shows the categories that were assigned). Some categories were subdivided into multiple topics. For example, marine ecology was divided into 25 topics, including impacts on birds and cetaceans, benthic habitat, water quality etc. It is important to note that the categories and sub-categories/topics are not mutually exclusive. For example, the impact on recreational activities as a whole includes the perceived increase in risk of a shark attack. With regards to the sub-categories, generic marine ecological impacts encompass individual impacts

7 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation on cetaceans, penguins, benthos etc. These categories were derived from the types of answers provided to stakeholders with the sole purpose to demonstrate the level of engagement of stakeholders.

Table 2 Commenting categories and sub-categories derived from the stakeholder comments and answers. It is important to note that this information was not derived from a structured survey.

Comment category and sub-category Number of Number of comments stakeholders that provided comment on a category Positive economic impact and new job opportunities 5 5 Negative economic impacts 106 81

Negative economic impact generic 74

Job losses 32 Shark risk to recreational users 72 72 Impacts on marine ecology 125 62

Marine ecological impacts (generic) 26

Water quality only (ecology) 15

Chemical pollution 12

Cetacean entanglement 10

Penguins 9

Reef sensitivity general 8

Benthic impacts 5

Apex predator interaction 4

Disease transfer from finfish cages 4

Algoa 1 overlaps with Humpback dolphin sanctuary 3

Escapes 3

Pelagic fish stock as feed 3

Reef sensitivity specific to antifouling and antibiotics 3

Sensitive marine environments 3

Contribution to nutrient loading and HAB 2

Introduction of alien species not considered 2

Mediterranean mussel (alien species) 2

Sharks and their prey 2

Stocking densities and environmental issues 2

Sustainable food 2

Birds and cetaceans 1

Impact on marine predators 1

Impact on squid nursery area at Algoa 1 1

Impact on Swartkops Estuary. 1

Release of petrochemicals 1 Water quality deterioration - recreation 99 54

8 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

Comment category and sub-category Number of Number of comments stakeholders that provided comment on a category

Feed on beaches 32

Water quality, blue flag status 28

Water quality only (human health E. coli) 22

Water quality only human health chemicals 13

Mussel harvesting could be jeopardised 1

Surface currents not considered 3 Negative impact on recreation 49 45

Ocean swimming and events 26

Recreational activities as a whole 13

Reef and SCUBA diving 7

Sailing 2

Recreational fishing sector 1 Visual and aesthetics 32 28

Algoa 1 (Summerstrand site) 28

Algoa 6 (PE Harbour site) 3

Algoa 7 (Nqgura Harbour site) 1 Site selection 26 26

Site selection in general (why Algoa Bay?) 22

Go to Algoa 7 4 Economic feasibility of ADZ 38 25

Wave feasibility 16

E. coli in receiving environment 12

Days for servicing vessels not considered 4

Harmful Algae Blooms 3

Bird predation 1

Climate change 1

Microplastics and food safety 1 Not enough information provided 30 18

Lack of quantitative economic study 11

Algoa 7 not assessed to same detail 8

Appeal request by minister was not met 6

Full EIA should be conducted 4

Lack of transparency due to incomplete assessment 1 Implementation queries 13 12

How to manage impacts on sensitive habitats 7

Who is responsible for implementation 5

How are dead fish disposed of 1

9 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

Comment category and sub-category Number of Number of comments stakeholders that provided comment on a category Land-based ADZ as an alternative 12 12 Impact on beaches 11 11

Debris on beaches 5

Beaches will be destroyed (not specific) 4

No consideration was given to sand movement 2 Marine Spatial Planning not done 11 9

Marine spatial planning 8

Priority given to certain ocean users 2

How can Algoa 7 be simply excised from the MPA. 1 Need and desirability 11 9

The proposed ADZ will not contribute to food security 5

Impact on SMMEs is the same as contribution to economic growth 2

Job opportunities 2

Benefit to ecosystem and Metropolitan Municipality 1

Small-scale fisherfolk are excluded 1 Impacts on fishing industry 9 9

Small-scale and commercial fishing sector 6

Chokka industry 3 Shortcomings of the stakeholder consultation process 13 8

Lack of consultation with important stakeholder groups (e.g. 5 hospitality industry)

Not enough time to comment 3

Public participation does not enable I&APs' informed engagement 3

Algoa 7 communities were not consulted 2 Impact on real estate 5 5 Vessel navigation 4 4 Impact on air quality (fishy smell) 10 3 Impact on aircraft navigation (bird collision with aircrafts) 3 3 Impact on planned water front at PE Harbour 2 2 Violation of environmental rights (Bill of Rights Section 24 reference) 2 2 Corruption 1 1

Negative economic impacts (including potential job losses) as a result of the proposed Aquaculture Development Zone was most frequently mentioned (81 stakeholders), followed by the concern over the increased risk of shark attack as a result of finfish farming (72 stakeholders). A substantial proportion (26 stakeholders) also commented on the impact on ocean swimming and events without mentioning the concern over increased risk of shark attacks. Both of these comment categories are

10 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation mostly applicable to finfish farming at Algoa 1 (Summerstrand site) and to some extent applicable to Algoa 7 (Ngqura Harbour site) (some stakeholders indicated that they would not continue open water swimming if any finfish farms were implemented in Algoa Bay).

Impacts on the marine ecology of Algoa Bay was commented on by 62 stakeholders, amounting to 125 individual comments, which most commonly were concerned with marine ecological impacts as a whole, water quality issues, and chemical pollution arising from finfish farming (Table 2). Overall, marine ecological impacts are more diverse, more negative for finfish farming when compared to bivalve farming, and are more pertinent to Algoa 7, which lies adjacent to the recently proclaimed Addo Marine Protected Area. Due to the fact that stakeholders were mostly unaware of the fact that DAFF intends to apply for bivalve culture in addition to finfish culture, these comments were mostly directed at finfish farming.

Almost one third of stakeholders (54) who provided comment were concerned about water quality deterioration on the beaches, which in some cases was extended to the loss of Blue Flag status of Hobie, Humewood and Kings Beaches in Port Elizabeth. Stakeholders are most concerned about feed and faeces washing up on the beaches posing a health threat to contact recreation. Furthermore, some stakeholders (13) were concerned that chemicals used in finfish culture could harm recreational participants. In the response to stakeholders, it was concluded that (i) chemical pollution from finfish cages is not known to impact humans participating in recreational activities, (ii) uneaten food and faeces/organic waste are not expected to wash up on the beaches situated more than 3 km from the proposed sites, and (iii) finfish farms are not a source of harmful bacteria and viruses. It was highlighted however, that, in as much as the risk of shark attack is higher for open water swimmers than bathers, training and event routes passing Algoa 1 in proximity may be impacted by reduced water quality mainly related to visibility. A paragraph has been included in the description of the affected environment on this matter (Chapter 8 Section 5 on the Socio-economic character) to address the misconception that the proposed development could harm human health or jeopardise the Blue Flag status as a result of water quality deterioration. Other than water quality deterioration, a limited number of stakeholders were concerned about physical impact on beaches, including debris washing up on the beaches and sand depletion as a result of offshore aquaculture structures.

Visual and aesthetic impacts, especially of Algoa 1 (no distinction was made by stakeholders between bivalve and finfish farming, although the latter is likely to have a higher impact) was mentioned by 16% (28) of stakeholders who provided comment.

It was evident that many stakeholders (14.5%) were not aware that the site selection process commenced with the National Strategic Assessment (SEA) for Finfish Culture in South Africa (Hutchings et al. 2011), with seven sites having been considered to date. Stakeholders feel that the Marine Spatial Plan for Algoa Bay that is currently being developed should be considered in a renewed site selection process.

The economic feasibility of the proposed ADZ was questioned by 14% (25) of the stakeholders who provided comment. Most frequently, finfish cage farming feasibility was questioned due to swell height and windy conditions in Algoa Bay. Although very few stakeholders explicitly expressed opposition to bivalve farming at Algoa 6 as a result of environmental impacts, twelve stakeholders questioned feasibility of the proposed site due to land-based pollution sources.

11 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

Some stakeholders felt that not enough information was provided in the pre-application BAR (10% of stakeholders). The most frequently mentioned short coming was the lack of a quantitative socio- economic study to determine the number of jobs gained in comparison the jobs potentially lost, as well as the potential social income gain compared to the potential economic losses as a result of Algoa 1, as per the comments of the Minister in the appeal statement (17 comments provided). The general sentiment is that the risk remains unquantified and therefore unknown. It must be noted here that this issue is mostly applicable to finfish farming at Algoa 1 and would be largely mitigated in Alternative Option B. Some stakeholders requested that a Full Environmental Impact and Reporting (EIA process) should be conducted to ensure that all sites were assessed equally (12 comments provided, including those provided for Algoa 7).

A limited number of stakeholders (7%) were interested to find out how the environmental management and monitoring requirements would be implemented and who would be accountable. Land-based aquaculture was repeatedly suggested as the better option when compared to sea- based culture (7% of stakeholders).

The need and desirability of the proposed project was questioned by 5% of stakeholders who provided comment. Most importantly, it was argued that food security will not be improved by the proposed development as bivalve and finfish products will be mostly grown for the export market and not provide food for poor communities. This statement was made by Britz et al. 2016 and was carried over into the pre-application BAR. However, the ‘Need and Desirability’ Setion was not updated consistently, which mislead the stakeholders. This has been corrected in the Draft BAR.

Eight stakeholders claimed that the stakeholder consultation process was inadequate. It must be noted that the pre-application stakeholder consultation process has informed the Draft BAR and comments provided during the application phase will inform the Final BAR. Anchor is well aware that the proposed project is conentious and stakeholder consultation must be scaled accordingly. This report details how this is achieved.

Impacts of the proposed development which were mentioned infrequently include:

• Impact on the fishing industry (mostly applicable to Algoa 1) • Impact on real estate (mostly applicable to Algoa 1) • Impact on vessel navigation (all sites) • Impact on air quality (mentioned in connection with Algoa 1 and 6) • Impact on aircraft navigation (potential bird collisions with aircrafts) • Impact on planned water front at PE Harbour (applicable to Algoa 1) • The proposed development violates environmental rights (reference to Bill of Rights Section 24). • Corruption

Stakeholder engagement (positive and negative) with the proposed project was successful during the pre-application phase. The histogram in Figure 2 shows that nearly 80% of stakeholders provided comments that covered between zero and five commenting topics (or sub-categories). More than five and up to ten commenting topics were included in 17% of the comments submitted. Only very few comments included more than ten commenting categories.

12 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

80%

70%

60%

50%

40%

30%

20%

10% Percentage of stakeholders 0% 5 10 15 20 25 30 35 More Number of topics covered in comment

Figure 2 Stakeholder engagement level for the pre-application stakeholder consultation process for the Algoa Bay sea-based aquaculture development zone Basic Assessment process. The percentage of stakeholders on the y-axis was calculated from the total number of stakeholders that provided comment (i.e. 179). The number of topics covered in the comments are shown on the x-axis.

Although most comments could be responded to without requiring changes to the pre-application BAR, comments on socio-economic impacts, specifically pertaining to finfish farming at Algoa 1 resulted in substantive revisions, which are highlighted in the Draft BAR.

Overall, it appears that the sentiment captured during this stakeholder consultation process aligns closely with the social preference study conducted for Algoa 1 and 5 by Britz et al in 2016. Based on the choice modelling study conducted by Britz et al 2016 and feedback from stakeholders thus far, it appears that potential ecological impacts and the perception of an increased risk of shark attacks occurring (whether this risk is real or not) were identified as the most important disturbing aspects of the proposed development after marine ecological impacts (note this is finfish farm specific and is mostly applicable to Algoa 1). While mitigation measures have been recommended for negative visual and marine ecological impacts, no meaningful mitigation measures are available for the other aspects other than site selection or site reduction (reference to the visual buffer recommended in the specialist study 2013).

All these aspects are likely to impact negatively on tourism and therefore the economy of Port Elizabeth. However, the perceived higher risk of shark attacks could potentially have a profound direct impact on the local economy, should the Iron Man Event (and other events) be moved to a different location (Iron Man Organisers indicated during the appeal phase that the event would be moved should finfish cages be installed at Algoa 1). Furthermore, this impact could potentially be irreversible and occur during the pilot phase. For this reason, the ‘high’ impact rating on the specialised tourism and businesses benefiting from tourism in the area was reassessed for finfish farming at Algoa 1 (Section 9.5.2.3), this rating cannot be reduced to ‘medium’ after the

13 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation implementation of mitigation measures and will be increased to ‘high’ with a medium confidence in the impact rating.

Britz et al. 2016 concluded on page 25 that: “it is entirely appropriate that the social choice be partly informed by social preference, and not only with reference to expert opinion.” Furthermore, the expert opinion in the final feasibility study by Britz and Sauer (2016) concludes that “For Algoa 1, the socio-economic feasibility was ranked ‘moderately feasible’ for most indicators (Table 7). The unquantified socio-economic costs and trade-offs associated with the ‘tourism and recreation’ economy were however ranked as a ‘very low feasibility’.” The outcomes of the social preference study, the expert opinion as stated above, as well as the comments provided by the public to date (which are mostly congruent with the Britz et al. 2016 study) have guided the EAP towards concluding that Alternative Option A (finfish farming and bivalve culture at Algoa 1) is not recommended.

Considerable changes were incorporated into the Draft BAR as a result of the comments provided. Most importantly, based on the revised significance of negative economic impacts linked to finfish farming at Algoa 1 Option 1 from ‘medium’ to ‘high’ after implementation of mitigation measures, DAFF revised its priorities in respect of mariculture in Algoa Bay and submitted an application for environmental authorisation with Option B as the preferred Alternative Option. Alternative Option B involves:

• Mussel and oyster farming at Algoa 1 Option 1 (Summerstrand site) • Mussel and oyster farming at Algoa 6 (PE Harbour site); and • Finfish farming at Algoa 7 (Ngqura Harbour site)

14 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

4.2 Application-phase The main objective of the application-phase meetings was to present the outcomes of the pre- application public participation process and to demonstrate how comments provided by stakeholders had been considered in the Draft BAR. Engagement with the community broadly supporting the proposed development was intensified by holding a public meeting in Motherwell Community Hall on 1 August 2019.

The Draft BAR was made available to stakeholder for comment from 23 July – 4 September 2019. During this process 28 stakeholder comments were submitted which have been included in Appendix G2 of the Final BAR. Five of these comments were received after 4 September 2019 without a timeous request for extension. (An extension request was either submitted after completion of the commenting period or the comments was submitted without recognising that the commenting period had been completed). Due to the contentious nature of this project, late comments were nevertheless incorporated into the stakeholder consultation process.

53 stakeholders attended the public meeting in Port Elizabeth on 31 July 2019 when compared to 77 during the pre-application process. Only 28 comments were received, comprising 4% of registered stakeholders which compared to 180 comments submitted during the pre-application phase, representing 26% of stakeholders registered at the time. The considerably lower level of public participation during the application-phase could be attributed to several media announcements, which announced that DAFF no longer intended to apply for finfish farming at Algoa 1 Option 1:

• https://prodive.co.za/news/no-fish-farm-protest-paid-off-2/ • https://www.iol.co.za/capetimes/news/victory-for-environmentalists-as-department- dumps-fish-farm-plan-30031501 • https://www.heraldlive.co.za/news/2019-07-22-contraversial-bay-fish-farm-a-step-closer/

Bivalve farming at Algoa 1 Option 1 (Summerstrand site) A number of stakeholders were still concerned about the increased risk of a fatal shark encounter and water quality associated with bivalve farming at Algoa 1 Option 1, as well as the potential knock- on effects on the economy of Port Elizabeth. It should be noted that bivalves extract particles from the water column (microscopic algae and other detritus) and therefore don’t have to be fed in aquaculture. Furthermore, bivalves produce significantly less waste when compared to finfish (organisms higher up in the food chain produce more waste). The lack of feed and low waste production means that water quality deterioration as an environmental impact is lower when compared to finfish farming. Furthermore, bivalves are sessile (i.e. lodged to the ropes or inside baskets). Sharks have been shown to be attracted to activity in the water (thrashing fish in cages) and the smell of food (feed). Although bivalve farms can act as Fish Aggregation Devices (Callier et al. 20173), unlike finfish cages, bivalve farms have been shown to repulse larger marine animals. It has been suggested that it is possible that bivalve farm arrays are not conducive for hunting as navigation through longlines poses a challenge (Callier et al. 2017). In comparison to finfish culture,

3 Callier MD, Byron CJ, Bengtson DA, Cranford PJ, Cross SF, Focken U, Jansen HM, et al. 2017. Attraction and repulsion of mobile wild organisms to finfish and shellfish aquaculture: a review. Reviews in Aquaculture, 0:1-26.

15 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation there is currently no evidence to support the claim that bivalve culture would attract sharks at Algoa 1 Option 1.

The the high negative impact on the economy of Port Elizabeth by finfish farming at Algoa 1 Option 1 was primarily attributed to the fact that Iron Man South Africa indicated during the 2014 appeal phase and the pre-application consultation of the current BA process that the event would be moved should finfish cages be installed at Algoa 1 Option 1. During the application-phase, Iron Man South Africa submitted comment, which stated that the objections and concerns had not changed and that their main concerns remained (1) greater potential for predators such as sharks, (2) economic and tourism impact, and (3) risk of pollution affecting water quality from concentrated bivalve farming. It was not explicitly stated, however, that the event would be moved should bivalve farming be approved at Algoa 1 Option 1 (note that Lindsay Stephen from Iron Man SA also attended the public meeting on 31 July 2019). It was therefore concluded that the negative impact rating of bivalve farming at Algoa 1 Option 1 on Port Elizabeth’s economy would not be revised.

Stakeholders expressed concern regarding the southern part of Algoa 1 (Option 2), which overlaps with the squid breeding area frequented by current fishermen. As breeding areas provide for the best catches, the establishment of a fish farm in the same area would most likely have a significant impact on the local squid industry. DAFF therefore excluded the southern portion of Algoa 1 (Option 2) from the application process. Following the completion of the application-phase public participation process, the South African Squid Management Association (SASMIA) submitted comment4 (Refer to full comment and response in Appendix G2 of the Final Basic Assessment Report). In their comment, SASMIA highlighted that any loss of fishing ground due to Algoa 1 Option 1 would constitute a cumulative impact considering the recent proclamation of the Addo MPA where a significant portion of productive squid fishing grounds have become restricted zones.

The BAR acknowledges that further restricting access to important fishing grounds may contribute to cumulative impacts experienced by the local fishing industry. However, the overall contribution to reducing available fishing grounds is considered low due to the small size of the proposed ADZ compared to the extent of fishing grounds and the fact that the DAFF excluded the southern portion of Algoa 1 (Option 2) from the application process.

SASMIA indicated that they do not have access to the current season’s distribution of catch and effort and cannot, at this time, ascertain the potential economic impact (loss of income) should the ADZ exclude the fleet (currently 123 vessels) from any fishing grounds. Calculation of economic loss due to the displacement of fishing effort is, however, not straightforward, as fishers typically move to other fishing areas with variable cost and catch rate implications. It was concluded that the reduction in size of Algoa 1 would constitute partially effective mitigation (the impact was rated as medium for Algoa 1 Option 1 and as low for Algoa 6).

4 It should be noted that SASMIA registered as a stakeholder in January 2019 and therefore had the opportunity to provide comments during both the pre-application and application-phase stakeholder consultation processes (including two public meetings). However, a request for an extension to submit comment was only submitted after closure of the official period (on 5 September), which had been extended from 28 August to 4 September 2019 for all stakeholders. Anchor accepted a submission on 18 September 2019).

16 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

Finfish farming at Algoa 7 (Nqura Harbour) Finfish farming at Algoa 7 remained a significant concern. Stakeholders frequently referred to marine ecological impacts detailed in the Marine Ecological Specialist Study (Appendix D3 of the BAR), including but not limited to disease transfer from farmed to wild fish, water quality, risk of entanglement (birds, mammals and turtles), and the impact on the endangered African Penguin. As in the pre-application consultation process, the conservation importance of Algoa Bay was highlighted by a number of stakeholders..

Bivalve farming at Algoa 6 (Port Elizabet Harbour site) Bivalve farming at Algoa 6 appears to be mostly supported by stakeholders, although some stakeholders were concerned about the farming of alien and invasive bivalves and the potential impacts thereof (refer to Marine Specialist Report in Appendix D3 for the assessment of this impact). The Mediterranean Mussel is widespread along South Africa’s coastline. The impact of farming Mediterranean Mussel was rated as very low, since mussels are not actively seeded onto ropes, which means that no additional organisms are introduced into the marine environment. The ropes will be left to be colonised by naturally occurring offshore mussel larvae pools (part of the mussel life history is spent offshore). Larvae pools are carried inshore by (1) upwelling-related circulation, (2) internal tidal waves and bores, (3) the local diurnal (or diel) sea breeze, and (4) waves and ocean swell (Pfaff 2015). The potential impact of introducing Pacific oyster was rated as 'medium' before and 'low' after the implementation of mitigation measures. It is noteworthy that despite at least a decade of oyster mariculture in the vicinity of Algoa 6, wild populations of the Pacific oyster have not yet been detected in Algoa Bay and associated estuaries suggesting that conditions are not ideal for the establishment of this species in the wild in this area (note that in order to establish and spread, alien species must be able to reproduce in nature without the interference of humans. Farmed Pacific oysters are hatched in land-based facilities and seeded in baskets when reaching a robust size to grow until they are harvested.)

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5 PUBLIC RESISTANCE AGAINST THE PROPOSED ADZ The Wildlife and Environment Society of South Africa (WESSA) launched an international petition on Azaaz with the title ‘No to Fish Farms in Algoa Bay. Yes to rehabilitating the Swartkops Estuary’. Currently this petition has collected 3 033 signatures. WESSA also published a video on YouTube, advocating that instead of developing finfish farms, DAFF should rather look at rehabilitating the Swartkops Estuary. The video can be accessed online at: https://www.youtube.com/watch?v=SAjCv6tRr10

A protest 'celebration' against proposed Algoa Bay fish farm was undertaken on the 13th July 2019. This protest celebration took place on the city's beachfront, following a unique protest that includes a run, swim, walk and even a snorkel dive. The event took place under the auspices of Adventure Swims ZA as the organisers of the event. This entailed a swim/paddle from Hobie Beach to Humewood Beach and those who chose not to swim walked from one beach to the next. On arrival at the beach the intention was to hand over the memorandum to persons representative of the interests impacted by the proposed ADZ, namely the Municipality, Business, Environment and the EAP. Unfortunately Anchor Research & Monitoring was not able to attend this protest celebration. According to the newsbroadcaster Algoa FM between 1000 and 2000 people took part in this protest. A memorandum was handed over during the public meeting on 31 July 2019, which has been included in Appendix F6 of this report.

6 APPENDICES F1-F7 Appendices F1 to F7 are presented in the remainder of this document in the following order:

1. Proof of the placement of the relevant advertisements and notices 2. Proof that relevant organs of state and key stakeholders were sent written notification of the proposed activities 3. A list of registered I&APs 4. Emails sent to stakeholders 5. Letters submitted by stakeholders 6. Minutes of the authority and public meetings 7. Attendance registers

18 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

APPENDIX F1: PROOF OF THE PLACEMENT OF THE RELEVANT ADVERTISEMENTS AND NOTICES

Advertisement placed in the PE Express on 5 December 2019 for the proposed sea-based Aquaculture Development Zone in Algoa Bay.

19 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

Notice board in English at Hobie Beach Pier. Notice boards are size A2 and laminated to withstand wind and rain.

A Pre-application Process: Hobie Beach

B Application Process: Hobie Beach Surf Lifesaving Club

20 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

C Application Process: Hobie Beach Surf Lifesaving Club – Close-up

21 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

D Application process: Draft Basic Assessment Report in Motherwell Library

E Application process: Draft Basic Assessment Report in Newton Park library

22 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

APPENDIX F2: PROOF THAT THE ORGANS OF STATE AND KEY STAKEHOLDERS RECEIVED WRITTEN NOTIFICATION OF THE PROPOSED ACTIVITIES

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research & monitoring 24 Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

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APPENDIX F3: LIST OF REGISTERED INTERESTED AND AFFECTED PARTIES Stakeholder database for the basic assessment process for the proposed sea-based Aquaculture Development Zone in Algoa Bay. This data base is continuously updated throughout the stakeholder consultation process. Note that contact details have not been provided to protect the privacy of the stakeholder.

NAME AND SURNAME AFFILIATION CATEGORY Michelle Pretorius Department of Agriculture, Forestry and Fisheries Client Maxhoba Jezile Department of Agriculture, Forestry and Fisheries Client Andrea Bernadzeder Department of Agriculture, Forestry and Fisheries Client Zimasa Jika Department of Agriculture, Forestry and Fisheries Client Dayalan Govender Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) Government Charmaine Struwig Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) Government Judy Beaumont Department of Environmental Affairs: Branch Oceans and Coasts Government Nosisekho Mhlahlo Department of Environmental Affairs: Branch Oceans and Coasts Government Lindelani Mudau Department of Environmental Affairs: Branch Oceans and Coasts - Coastal Conservation Strategies Government Nontsasa Tonjeni Department of Environmental Affairs: Branch Oceans and Coasts - Coastal Conservation Strategies Government Yazeed Peterson Department of Environmental Affairs: Branch Oceans and Coasts - Coastal Pollution Management Government Nitasha Baijnath-Pillay Department of Environmental Affairs: Branch Oceans and Coasts - Coastal Pollution Management Government Alan Boyd Department of Environmental Affairs: Branch Oceans and Coasts Government Shonisani Munzhedzi Department of Environmental Affairs: Branch Biodiversity and Conservation Government Simon Malete Department of Environmental Affairs: Branch Biodiversity and Conservation Government Wadzi Mandivenyi Department of Environmental Affairs: Branch Biodiversity and Conservation Government Skumsa Mancotywa Department of Environmental Affairs: Branch Biodiversity and Conservation Government Khathutshelo Nelukalo Department of Environmental Affairs Government Moshibudi Rampedi South African Biodiversity Institute (SANBI) Government Nelson Mbatha Transnet National Ports Authority (TNPA) - National Government Cebile Lzuza Transnet National Ports Authority (TNPA) - National Government Tandi Lebakeng Transnet National Ports Authority (TNPA) - Port of Ngqura Government Jody Kennedy Transnet National Ports Authority (TNPA) - Port of Ngqura Government

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NAME AND SURNAME AFFILIATION CATEGORY Mandilakhe Mdodana Transnet National Ports Authority (TNPA) - Port of Ngqura Government Sandisiwe Mtintsilana Transnet National Ports Authority (TNPA) - Port of Ngqura Government Rajesh Dana Transnet National Ports Authority (TNPA) - Port of Port Elizabeth Government Nelisa Ndulama Transnet National Ports Authority (TNPA) - Port of Port Elizabeth Government Lesa la Grange South African Heritage Resources Agency Government Basson Geldenhuys Department of Public Works Government Francois Gerber Department of Public Works Government Noxolo Nqwazi Nelson Mandela Bay Municipality Government Ted Pillay Sahra Baartman District Municipality Government Joezay Reed Kouga Local Municipality Government Sydney Fadi Sundays River Valley Local Municipality Government Ane Oosthuizen South African National Parks Government Stacey Webb SANCCOB - Port Elisabeth Government Michelle SANCCOB - Port Elisabeth Government Jake Keeton Raggy Charters Tourism operator Nonzuzo Phenduka Eastern Cape Parks and Tourism Agency Tourism agency Kobus Maritz South East Coast Inshore Fishing Association (S.E.C.I.F.A.) Fishing industry Craig Bacon South East Coast Inshore Fishing Association (S.E.C.I.F.A.) Fishing industry Clyde Bodenham South African Longline Hake Fishing industry Kerry Marx South African Longline Hake Fishing industry Wally Croome The SA Commercial Linefish Association (S.A.C.L.A) Fishing industry Keith du Plessis Coega Development Corporation Industry Leander Kruger Ward 1 - Nelson Mandela Municipality Government Dean Biddulph Former councillor Ward 2 - Nelson Mandela Municipality Private citizen Sandile Rwexwana Ward 5 - Nelson Mandela Municipality Government Ntombekaya Celia Mtati Ward 15 - Nelson Mandela Municipality Government Xola Sabani Ward 16 - Nelson Mandela Municipality Government Mvuzo Ernest Mbelekane Ward 60 - Nelson Mandela Municipality Government

research & monitoring 27 Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

NAME AND SURNAME AFFILIATION CATEGORY Nomazulu Mthi Ward 53 - Nelson Mandela Municipality Government Lynette van der Westhuizen Sundays River Ratepayers Association Ratepayers Association Kobus Gerber Nelson Mandela Bay Ratepayers Association Ratepayers Association Tim Hedges Abagold Ltd Aquaculture Christiaan de Wet Private Aquaculture Louise Vosloo Aquaculture Gert le Roux Diamond Coast Abalone (Pty) Ltd Aquaculture Aquaculture Association of SA Aquaculture association SanCor Government Tracey Department of Agriculture, Forestry & Fisheries Government Ah Shene Verdoorn Carolyn Birdlife South Africa Conservation Allemann Kerry Private citizen Attwood Colin University of Cape Town University Beckert Ingo Blue Cap Trading Pty Ltd Industry Beuidenhout Karien Nelson Mandela University University Bok Andre Pure Ocean Aquaculture Aquaculture Botha Willie Kouga Local Municipality Government Britz Pete DIFFS Specialist Bruk Judian Private citizen Cain Fernando NMBM Beach Manager Government Carter Alan CES - Environmental and Social Advisory Services Environmental Consultancy Carter Gavin Mtuzini Aquaculture Projects Aquaculture Cassidy Jared Private citizen Cerini Vernon Private citizen Chalmers Russell Private citizen Christy Greg Private citizen Andre Clarke Synergy-solutions Private citizen Cloete Anton Private citizen

research & monitoring 28 Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

NAME AND SURNAME AFFILIATION CATEGORY Cloete Chrissie Plettenberg Bay Community Environmental Forum Conservation Cohen Mike CEN Integrated Environmental Management Unit Environmental Consultancy Corrigan Bridget Endangered Wildlife Trust (EWT) Conservation Cowley Paul SAIAB Government Gillian van Niekerk Advance Africa Environmental Consultancy Thys De Bruin Private citizen Andre de Wat Buffalo Bull Farming Agriculture Siyabonga Dlulisa Department of Environmental Affairs: Branch Oceans and Coasts - Integrated Coastal Management Government Janet Ebersohn Eco Route Environmental Consultancy Environmental Consultancy Lloyd Edwards Raggy Charters Tourism Operator Leon Els Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) Government Emery Kirsten Private citizen Grace Galuszynski Private citizen Patrick Garratt Two Oceans Aquarium Research institute Gierz Martin PE Deep Sea Angling Club (PEDSAC) Recreational fishery Gon Jenny Wildlife and Environment Society of South Africa (WESSA) Conservation Wayne Goschen South African Environmental Observation Network (SAEON) Government Yadre Gouws Private citizen Gert Greeff ESKOM Government Leticia Greyling Rhodes University University Morgan Griffiths Wildlife and Environment Society of South Africa (WESSA) Conservation Jingles Gxoyiya Bees and Honey Consulting Private citizen Mark Halbert Private citizen Themba Hani Nelson Mandela Bay Municipality Government Douglas Harrowsmith Private citizen Rory Haschick Eastern Cape Development Corporation Government Tom Hecht DIFFS University Chris Heinecken Capfish & FOSS cc Environmental Consultancy

research & monitoring 29 Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

NAME AND SURNAME AFFILIATION CATEGORY Juliet Hermes South African Environmental Observation Network (SAEON) Government Rhett Hiseman Cape Nature Government Zane Hobson Private citizen Greg Hofmeyer Port Elizabeth Museum Heritage Lynn Jackson Private citizen Dave Japp Capfish & FOSS cc Environmental Consultancy Chris Julius Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) Government Kelly William Private citizen Sven Kerwath Department of Agriculture, Forestry & Fisheries Government Mike Klee Mike's Dive Shop Recreational business Kesia Koorts Private citizen AJJ Kotze Private citizen Pamela Labuschagne Private citizen Robert Landman Irvin & Johnson (I&J) Commercial and small-scale fishery Gert Le Roux Private citizen Phillip Lennon Coral Tree Films Media Kai Linder Private citizen Josie Mackenzie Private citizen Bruce Mann Oceanographic Research Institute (ORI) Research institute Alwyn Marais NSPCA (National Council of SPCAs) Animal welfare Benita Maritz The Institute for Maritime Technology Research institute Paul Martin Private citizen Hamish McGregor Private citizen Sue Middleton Department of Agriculture, Forestry & Fisheries Government Greg Miller Private citizen Theresa Milne Private citizen Joram Mkosana Nelson Mandela Bay Municipality Government Sello Mokhanya Eastern Cape Provincial Heritage Resources Authority (ECPHRA) Government

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NAME AND SURNAME AFFILIATION CATEGORY Dino Moodaley South African Squid Management Industrial Association (SASMIA) Commercial and small-scale fishery Christina Moseley Private citizen Dennis Mostert Private citizen Elliot Motsoahole Transnet National Ports Authority (TNPA) Government Peter Myles Tournet Africa Tourism Operator Lisa Nupen Private citizen Larry Oellermann Oceanographic Research Institute (ORI) Research institute Sian O'Keeffe Private citizen Ane Oosthuizen South African National Parks Government Theo Panagis Private citizen Kate Parkinson Private citizen Sanet Petschel Private citizen Grant Pitcher Department of Agriculture, Forestry & Fisheries Government Stephanie Plon Nelson Mandela University University Trevor Probyn Department of Agriculture, Forestry & Fisheries Government David Randle Private citizen Nicole Richoux Rhodes University University Charles Rowe Private citizen Mark Rowe Private citizen Arthur Rump Algoa Bay Yacht Club (ABYC) Sailing Mark Saman Private citizen Rainer Schimpf Ocean Messengers Tourism Operator James Schoeman Private citizen Peter Schwartz Coastal Environmental Trust Conservation Tenjiwe Selani DEA: Oceans and Coast - Management Government Tom Shipton Rhodes University University Mariska Fourie Nelson Mandela Bay Tourism Tourism Operator Kyle Smith South African National Parks Government

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NAME AND SURNAME AFFILIATION CATEGORY Ray Snyders Private citizen Conrad Sparks Cape Peninsula University of Technology (CPUT) University Venessa Strauss Conservation Luc Strydom Private citizen Leslie Ter Morshuizen Aquaculture Innovations Aquaculture Greg Tucker Private citizen Colin Tunstead Sundays River Ratepayers Association Ratepayers Association Thembinkosi Tyali Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) Government Louis Van Aardt Pro Dive South Africa Diving industry Mike van den Heever Pioneer Fishing (Pty) Ltd Commercial and small-scale fishery Denise van der Merwe PE Deep Sea Angling Club (PEDSAC) Recreational fishery Hanneen van der Stoep Overstrand Municipality Government Mike van der Zee Private citizen Eugiene van Niekerk Private citizen Andries Venter NSPCA (National Council of SPCAs) Animal welfare Andrea von Holdt Coega Industrial Development Zone Industry Peter Wakefield Private citizen William Walton Private citizen Wanless Ross Birdlife South Africa Conservation Claudia Weetman Private citizen Bruno Werz Private citizen Philip Whittington East London Museum Research institute Brenton Williams Private citizen Jonathan Booth Birdlife South Africa Conservation Kerry Wright Private citizen Gay Youthed Kromme-Geelhout Conservancy Conservation No Name provided Fisherman Fresh Cc Commercial and small-scale fishery No Name provided LETAP CC Commercial and small-scale fishery

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NAME AND SURNAME AFFILIATION CATEGORY No Name provided UNATHI-WENA FISHING CC Commercial and small-scale fishery No Name provided South East Atlantic Sea Products CC Commercial and small-scale fishery No Name provided ITHEMBA LABANTU FISHING CC Commercial and small-scale fishery No Name provided BLUEFIN FISHING ENTERPRISES CC Commercial and small-scale fishery No Name provided Manicwa Fishing (Pty) Ltd Commercial and small-scale fishery No Name provided EYETHU FISHING (PTY) LTD Fishing Industry No Name provided RISAR FISHING CC Commercial and small-scale fishery No Name provided Basic Trading (Pty) Ltd Industry No Name provided LETAP CC Commercial and small-scale fishery No Name provided Fisherman Fresh Cc Commercial and small-scale fishery No Name provided Mayibuye Fishing (Pty) Ltd Commercial and small-scale fishery No Name provided Umsobomvu Fishing (Pty) Ltd Commercial and small-scale fishery No Name provided Pioneer Fishing (East Coast) (Pty) Ltd Commercial and small-scale fishery No Name provided Trevors Commercial Fishing (Pty) Ltd Commercial and small-scale fishery No Name provided Canan Fishing (Pty) Ltd Commercial and small-scale fishery No Name provided Pegasus Fishing (Pty) Ltd Commercial and small-scale fishery No Name provided Zimkhitha Fishing (Pty) Ltd Commercial and small-scale fishery No Name provided Jayfish Cc Commercial and small-scale fishery No Name provided MAST FISHING (PTY) LTD Commercial and small-scale fishery George Borman Quintax 151 CC - Squid and Hake Handline Fishing Industry No Name provided Copper Moon Trading 612 Pty Ltd Industry No Name provided Tamarin Fishing (Pty) Ltd Commercial and small-scale fishery No Name provided Lithalethu Fishing (Pty) Ltd Commercial and small-scale fishery No Name provided Talhado Fishing Enterprises (Pty) Ltd Commercial and small-scale fishery M Van Heerden Traditional linefish Fishery association Alan Southwood Private Resident Micheal Raimondo Sea Farms Hawston Aquaculture Kerry Wright Cleaner Climate South Africa Environmental Consultancy

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NAME AND SURNAME AFFILIATION CATEGORY Adrian Smith SA Squid Management Industrial Association (SASMIA) Fishery association Christelle du Plessis Habitat Link Consulting Environmental Consultancy Henri Pfister Private citizen Julie Pfister Private citizen Kithi Ngesi Nelson Mandela Bay Municipality Government Louise Nieuwoudt Nelson Mandela Bay Municipality Government Andrew Marriott Business and Economic Sciences Faculty Resident Belinda Clark Private citizen Paul Martin Private citizen Chris Jordaan East Coast Ancestral Sea harvest (ECASH) Fishing industry Kurt Kleinhans Rainbow Ocean Grown Aquaculture Shane Pittard Private citizen Lorien Pichegru Algoa Bay Hope Spot Conservation Andrea Shirley Coega Development Corporation Industry Rolene Kotze Fishing industry Anton Meyer Private citizen Johann Botha Private citizen Redah De Maine Private citizen Sydney Fadi Sundays River Valley Local Municipality Government Kobus Maritz Private citizen Simon Daniel Private citizen Greg Christy Private citizen Andre Bok Private citizen Pamela Mali Nelson Mandela Bay Municipality - Urban Agriculture: EDTA Government Isaac Nokele Nelson Mandela Bay Municipality - Urban Agriculture: EDTA Government Vos Pienaar Bivalve Shellfish Farmers Association of South Africa (BSASA) Aquaculture association Andrew Pritchard Architect Resident Christina Hagen Birdlife South Africa Research institute

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NAME AND SURNAME AFFILIATION CATEGORY Graham Bell Ward 1 committee Government Shirley Parker-Nance Private citizen Claudia Marriott Private citizen Jaco Potgieter Architect Private citizen Christian Bust Arvato South Africa Private citizen Estee Vermeulen NMU - coastal marine research inst University Tracy Weise Ward 1 - Nelson Mandela Municipality Government Jill Miller Nelson Mandela Bay Municipality - Environmental Management Government Pamela Howes Nelson Mandela Bay Municipality - Environmental Management Government Gareth Wilson The Harald Media Albert Mfenyana Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) Government Gerry Pienaar Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) Government Andries Struwig Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) Government Phumla Mzazi-Geja Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) Government Xolani Nikelo Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) Government Thembinkosi Tyali Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) Government Mlu Kosi Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) Government Leon Else Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) Government Zwelinzima Max Private citizen Jeremy Dobbin Nelson Mandela Bay Business Chamber Regional Business Association Norman Myers Private citizen Chris Stage SWARTKOPS SEA SALT/MARINA SEA SALT Private citizen Barb Cohen Private citizen Mzwandile Nkomombini Private citizen Sarah Caulfieid Private citizen Mike Cohen Private citizen Timothy and Isobel Douglas-Jones Resident Mzamohle Mzamohle Construction Industry

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NAME AND SURNAME AFFILIATION CATEGORY Zanda Mkhulisi Transnet National Ports Authority (TNPA) - Port of Port Elizabeth Government Mnyamezeli Williams Nonyondla Dev .Services Private citizen Peter Inman Private citizen Moyna Joseph Private citizen Rainer Private citizen Rainer und Silke Schimpf Expert Tours Marine safaris Tamryn Law Private citizen Nina Bodisch VWSA Private citizen Francois Gous Coastal Medical & Surgical Supplies Private citizen Luzuko Mafu WWS Private citizen Karien van Schalkwyk Private citizen Emma Hay Private citizen Nikki Dryden Private citizen Billie McNaughton Private citizen Paul Wolff Private citizen Shena Wilmot Port Elizabeth Metro B&B Association Accommodation association Eckart Schumann Wildlife and Environment Society of South Africa (WESSA) Conservation Mariska Spoormaker Private citizen Tony Ribbink Sustainable Seas Trust Conservation Desiree Fourie Private citizen Tim Parker-Nance Private citizen Steven Murray Private citizen Chris Mowbray Private citizen Maelle Connan Department of Zoology Institute for Coastal and Research Fellow University Amarein Fourie Private citizen Greg Cuthbert Private citizen Simon Wooldridge Private citizen Glynis van der Walt Private citizen

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NAME AND SURNAME AFFILIATION CATEGORY Ed Grondel Private citizen Guy Rogers Herald Media Angie Vermeulen Private citizen Diane Private citizen Umi ibrahim Private citizen Hennie Marais The Bellbuoy Group at the instruction of the Home Owners Association of Amadada Home Owners Association Neil &Cheryl Dorward 52 The Seagull 21 Marine Drive Summerstrand PE 6001 Private citizen Carol Jackson Private citizen Candice Haydam Private citizen Jenny Thompson Private citizen Kristoff Adelbert Private citizen Kelly Private citizen Brenda and David Wampach Haka Hana Bed & Breakfast Accommodation Lyn Haller Umzantsi Africa Tours Tourism Operator Marion Raupert Private citizen William Duckitt Private citizen Etta Hewitt Private citizen Bev de Lange Private citizen Chris & Mary de Villiers Private citizen Ben Van Heerde Private citizen Johan Private citizen Karl Botha Private citizen Roxi Phelan Private citizen Dt Marlize Private citizen dzeelie Private citizen marlyn Private citizen Adam mereki Private citizen Kapp Nelmarie Private citizen

research & monitoring 37 Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

NAME AND SURNAME AFFILIATION CATEGORY Stephanie Martin Private citizen Audrey Crawford Private citizen Charmaine Keiskama B&B Accommodation Zita van der Sandt Cape Flame Guesthouse Accommodation Michael Henwick Private citizen Geraldene du Plessis Private citizen Sue Wilson Private citizen Susan Moser Private citizen Rolf Kickhofel Private citizen Keith West Private citizen Alan Mounsear-Wilson Private citizen Margaret de Andrade Nelson Mandela Bay Municipality Government Denise Parker-Nance Private citizen Anthony Donald Private citizen Tony Reid Private citizen Garry Stone Private citizen Mick Scheckter Private citizen Phrosne Phillips Private citizen Grizel Hart Private citizen Nawir ibrahim Private citizen Syd Lippstreu Private citizen Barry Carter Private citizen Joanne Anthony-Gooden Private citizen Lindsay Stephen Ironman SA Sports events Punji Naidoo Alushi Foundation Private citizen Benedetta Schafer Private citizen Lisa Rentzke Private citizen Jannie Gie Addo Wildlife Lodge Accommodation

research & monitoring 38 Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

NAME AND SURNAME AFFILIATION CATEGORY Kathy Hoy Private citizen Dale Tucker Private citizen Loodt Buchner Private citizen Russell Beach Lodges Accommodation Michelle Van Aardt Pro Dive South Africa Diving industry Julia Banacj Private citizen Juergen Heckmanns Africa Beach B&B Accommodation Stephen Medcalf Treetops Guesthouse Accommodation Siya Ndzimande Ironman SA Sports events Colin Abrahams South End Museum Trust Heritage SM Slabbert Private citizen Bryan Wintermeyer Private citizen Dylan Bailey Private citizen Wayne Gerber Eastern Province Deep Sea Angling Association Recreational fishery Lindsay Gibaud Private citizen Andrew Stewart Resident Suzanne Theunissen Private citizen Tony Neveling Private citizen Morag Gray Resident Kathy and Jack Dempsey Self-Catering Guest House Accommodation Jill Stewart Conifer Beach House Accommodation Basson Geldenhuys Private citizen Jan Lodge Accommodation Alon Rathbone Property Scene Private citizen Jacques Lombard Private citizen Allan Bezuidenhout Muse Restaurant Restaurant Travor Marshall Private citizen James Ruthven-Smith Private citizen

research & monitoring 39 Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

NAME AND SURNAME AFFILIATION CATEGORY James Flood Private citizen Carrie Brand Private citizen Kristopher Lynch Private citizen Andrew Whitehead Capeparts Distributors Private citizen Alan van Deventer Private citizen Peter McAinsh Private citizen David Lipschitz Resident Carl Walton Private citizen Marguerite Walton Nelson Mandela University University Martin Hartslief Private citizen Chantal Du Pisani Private citizen Ryan Smith Adrenalin Addo Adventure Park Tourism Operator Martin Van Rensburg Private citizen Jacquie Mangold Private citizen Ardiaan van heerden Private citizen Anthony Scholtz Private citizen Richard Donaldson Port Elizabeth Deep Sea Angling Club Recreational fishery Mick John Private citizen Etienne Potgieter Private citizen Travis Smit Private citizen Joost Souverijn Private citizen Gail Pullen Ward 1 Nelson Mandela Bay Municipality Government Bongani Gocina Private citizen Siyabonga Makinana YARD Private citizen Graeme John Lombard The Port Elizabeth Hotel Group Accommodation Chantell van Baalen The Port Elizabeth Hotel Group Accommodation Grant Davies Something Good Roadhouse Restaurant Anle Marais Something Good Roadhouse Restaurant

research & monitoring 40 Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

NAME AND SURNAME AFFILIATION CATEGORY Sunny Something Good Roadhouse Restaurant Davies Something Good Roadhouse Restaurant Chris Holdsworth Private citizen Louis Schoeman BLC Attorneys Private citizen Ria Modeler Open Sky Entertainment Park & Lapa Event management Selvin Meyer Airports Company South Africa (ACSA) Port Elizabeth Aviation Anthony Groom Airports Company South Africa (ACSA) Port Elizabeth Aviation Cathy Holdsworth Private citizen Kate Flood Private citizen Gary M Koekemoer Wildlife and Environment Society of South Africa (WESSA) (Wildlife and Environment Society of South Africa) Conservation Cloverley Lawrence SouthAlgoa BayAfrican National Parks Government H May Mandela Metropolitan Municipality: Directorate Sports, Recreation, Arts and Culture Government Neliswa J Piliso Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) Government Gcobisa Mdoda Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) Government G Murrell Mandela Metropolitan Municipality: Directorate Environmental Management Government Rob Milne South African National Parks Government Zinhle Small Transnet National Ports Authority (TNPA) - Port of Port Elizabeth Government Vusi Mthombeni Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) Government Brynn Adamson Transnet National Ports Authority (TNPA) - Port of Port Elizabeth Government Ndileka Nozo Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) Government Lindelwa Twala Eastern Cape Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) Government Charles Kate Aquagreen Industry Thandiswa Scout Responsible Wife Private citizen Thandiwe Tshoni YARD Private citizen Tuletu Nombona YARD Private citizen Dumisani Jim YARD Private citizen Z Mafu NMBM Government Gillian McAinsh Private citizen

research & monitoring 41 Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

NAME AND SURNAME AFFILIATION CATEGORY Charles Manning Eyethu Fishing Fishing Industry Patrick and Carol Mather-Pike Private citizen Barry Patterson Aristea Environmental Services Environmental Consultancy Michele Dalton World Endurance Africa Holdings (Pty) Ltd – A subsidiary of IRONMAN® Sports events Warrick Stewart Resilience Environmental Advice Environmental Consultancy Nombulelo Mhlekude AHLULE PTY Ltd Industry Alan Straton MYPE Media Phakama Matshaya Ndiyaphambile Trading Industry Linda Jackson Libusisa Trading Industry Vera Massie Anchor EAP Ken Hutchings Anchor EAP Songezo Mtsokoba Anchor EAP Elaine Hopewell Private citizen Private citizen Graeme Hopewell Private citizen Private citizen Lungisa January Laas Private citizen Rodwil Meyer ECDFF - Eastern Cape Divers and Fishers Forum Divers and recreational fishers Andrew Stone Summerstrand SurfLife saving Lifesavingforum John Tudehope Algoabay sailing marina Sailing S Nash Algoa FM Media Octavia Boshoff PamGolding Properties Private citizen Dean Blom Boarolwal casino Private citizen M Frank Private citizen W.J.H Gray Private citizen S Sowazi Sowazi trading Private citizen Nina Rivers NMO Private citizen Elma Duplessis Wildlife and Environment Society of South Africa (WESSA) (Wildlife and Environment Society of South Africa) Conservation Mike Nelson MSPNAlgoa BayConstruction Private citizen Muriel Groep Symuzella Pty Ltd Private citizen

research & monitoring 42 Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

NAME AND SURNAME AFFILIATION CATEGORY Loven Pother Private citizen Mark Benson Benson And Associates Private citizen Lungiswa Masakhe trading Private citizen Amanda Mantutle Coega Development Corporation Industry Derek Zimmerman Rand Int Capital Private citizen Simon Burton Zwembesi Farms (Pty) Ltd Aquaculture N Bodish Individual citizen Private citizen Dave Wampach PJT Partners Private citizen Janet Townsend Resident Anthony Townsend Private citizen W Pretorius Private citizen Misiwe Ngqondela Rudulu fishing Fishing Industry Tembi Mnyamana Tsamse Holding Private citizen Siya Somntu Mamjoli Potential investor Sally Paulet Hik .Abalone.Farm Aquaculture Rowan Timmer Hik .Abalone.Farm Aquaculture Christopher Maduna Government Werner Illenberger Private citizen Gill Neuper Private citizen Liesl Gordon Hik .Abalone.Farm Aquaculture Les Kingma Private citizen Dunyiswa Nyweba Private citizen Joey Elphick Private citizen David Pittaway Nelson Mandela University University Stephen du Preez Private citizen Hannah Truter Private citizen S Holness Nelson Mandela University University Victoria Goodall Private citizen

research & monitoring 43 Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

NAME AND SURNAME AFFILIATION CATEGORY Mziwamadoda Ryan Mooi Entrepreneur Potential investor Clinton Wilson Private citizen Jaydeen Ras Interested in EIA projects to learn Private citizen Nazareth Appalsamy NSPCA Animal welfare Barbara Kinghorn Coral Tree Guest House Accommodation Malcolm Kinghorn Coral Tree Guest House Accommodation Lucienne Human Nelson Mandela University University Lyn Haller Mandela Bay Heritage Trust Heritage Tresia Holtzhausen Nelson Mandela University University John Allan Port Elizabeth Deep Sea Angling Club Recreational fishery Deidre de Vos Nelson Mandela University University Marguerite Smit Resident Elize Kingston Private citizen Pete Fielding Private citizen Ralph West Adventure Swims ZA Sports events Kevin Richards Adventure Swims ZA Sports events Duncan Edwards Adventure Swims ZA Sports events Donna van der Westhuizen Ocean Bay Guest House Accommodation Lynn Odendaal Ocean Bay Guest House Accommodation Mel Smethurst Linkside Lodge B&B Accommodation Linda Devan Sir Roys Guesthouse Accommodation Craig Williams Private citizen B Thomas Resident António Bastos Private citizen Kenneth Pattinson Resident Wendy Claydon Resident Tim Leeson Private citizen Rodney Louis Prodigy Venture Potential investor

research & monitoring 44 Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

NAME AND SURNAME AFFILIATION CATEGORY Marilyn Du Plessis Avocet Guest House Accommodation Anika Joubert Private citizen Margie Gaddin Private citizen Arina Bohler Private citizen Gloria & Hanlie Rens Private citizen Anonymous Private citizen Willem and Gabrielle du Plessis Private citizen Sameer Agherdien Resident Ighsaan Isaacs Private citizen John Saunders Private citizen Eduard Van der Westhuizen Private citizen Karen Barwood Private citizen Sulette Heystek Private citizen Chantal Bezuidenhout Resident Neil Dorward Private citizen Peter and Dianne Haarhoff Private citizen E Mitchell-Wyatt Hartley Guesthouse Accommodation Stacy Private citizen Wayne Mukheibir Resident Grant Bresler Resident Ursula Defferary Private citizen Kim Nkumanda Private citizen Emil Hougaard Resident Lerryn Mew Resident Jenny Rubidge Resident Jill Weakley Resident Philip Myburgh Private citizen Mieke Struwig Private citizen

research & monitoring 45 Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

NAME AND SURNAME AFFILIATION CATEGORY Patrick Brett Private citizen Andre Lemmer Schoenmakerskop Residents’ and Ratepayers’ Association (SRRA) Ratepayers Association Patricia Minnaar Resident David Botha Resident Heather Dowling Resident Eugéne Ceronio Resident Ian Thomson Resident Ralph Ketzner Resident Louis Van Dyk Resident Rodney Idris Algoa Bay Yacht Club Sailing Mark Dawson Algoa Bay Yacht Club Sailing Roger Algoa Bay Yacht Club Sailing Tony Bailessaa Algoa Bay Yacht Club Sailing Charles du Toit Resident Ann Lourens Nelson Mandela University University Jill McLellan Resident Mickey O'Haher Private citizen Pat Reen Resident Irene Ketzner Resident Charles Tregoning Resident Michelle Brown Event management Taryn Bresler Private citizen Cary-Lee Friend Resident Cornelius Poisat Algoa FM Media Margo Schuin Resident Dianne van Zyl Resident Grant Dryden Resident Adrian de Villiers Resident

research & monitoring 46 Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

NAME AND SURNAME AFFILIATION CATEGORY Luc Hosten Private citizen Kathy Cogan Private citizen Andre Venter NELSON MANDELA BAY SURFRIDERS Surfing committee Paula Bush Private citizen Warren van der Merwe Private citizen Graeme PIenaar Private citizen Pieter van Rhijn NELSON MANDELA BAY SURFRIDERS Surfing committee Marchant Kuys Resident Sonja Willemse Private citizen Christopher Dunderdale Private citizen Alice Debaux Resident Jonathan Leitch Private citizen Reg & Sheila Marshall Private citizen Wayne Bolton One Land Love It Conservation Aston Cain Hobie Beach Surf Life Saving Club (HBSLC) Lifesaving Bridget Mcilroy Resident Craig Venter Resident Keith Buhr Algoa Holdings (Pty) Ltd Resident Bronwyn van den Berg Resident Earl Ingram Lifesaving Nelson Mandela Bay Lifesaving Iris Steyn Resident Travis G Private citizen Kay Mc Nish The Paddling Shop Recreational business Danny Darné Resident Karen Mels Resident Lorraine Hewett Private citizen Alex Hofmeyr Resident Tess Kotze Lifesaving Eastern Cape Lifesaving

research & monitoring 47 Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

NAME AND SURNAME AFFILIATION CATEGORY Andy Radford Mandelabay Composite Cluster, including The Composites Group (Pty) Ltd, Mandela Bay Composites Cluster NPC, Industry Deborah Johnson Andrew Frederick Radford Resident Andrew Austin Resident Johan Gerryts Resident Paul Middleton Kings Beach Surf Life Saving Club Lifesaving Karen Austin Private citizen Michelle MacLean Private citizen Grant Dryden Resident Benlloyd Roth Resident Christina van Niekerk Retiefplein home owner Resident Gavin Rogers Private citizen Sharon Tarboton Resident No Name provided Private citizen Retha Smith Resident Greg Tucker Resident Frank Greyling Resident Ashleigh Darné Resident Celeste Naude Nelson Mandela University University Herman van Thiel Berghuijs The Dunes Home Owners Association Eileen Shepherd Resident Paula Archibald Resident Gianluca Acquisto Resident Simone Williams Resident Renaldo Gouws Ward 2 - Nelson Mandela Municipality Government Andrew Baker Private citizen Alex Lopes Private citizen Jenny Rump Zwartkops Conservancy Conservation Natalie Sharp Stellenryck Environmental Solutions Environmental Consultancy

research & monitoring 48 Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

NAME AND SURNAME AFFILIATION CATEGORY Stanford Slabbert Life Saving South Africa Lifesaving Jane Histed Resident Gillian McAinsh Resident D Martin Smith Addo Secrets Safaris Tourism Operator Molly Reed Laboria Residence Resident Michelle van Heerden Resident Bev and Steve MacDonald Resident Howard Loftus Private citizen Nicholas Forsythe Resident Lise Claassen Resident Michelle Barnett Resident Brian Bezuidenhout Association for the Physically Disabled (APD NMB) Association for the Physically Des Topper ResidentDisabled Tracy Hartwig Tourism Operator Maria Stott Resident Rob Green Resident Maurice Millard Summerstrand Surf Lifesaving Club Lifesaving Russel Julie Private citizen Lindy Green Resident Marie Hoensbroech Private citizen Stanford Slabbert Personal capacity (note also submitted on behalf of Life Saving Club) Resident LQ van Staden Resident Richard McIntyre Resident Debbie Bodley Private citizen Neal Green Resident Mark Scherer The Bellbuoy Group at the instruction of the Body Corporate of Retiefplein Home Owners Association Sian O'Keeffe Private citizen Tim Norris Resident

research & monitoring 49 Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

NAME AND SURNAME AFFILIATION CATEGORY Gary Koekemoer Also registered to represent Wildlife and Environment Society of South Africa (WESSA), this is in personal Resident Cyndi Gilbey capacity Private citizen Vaughan McIntyre Private citizen Dennis, Deborah, Sipenati and Private citizen JillBennie and RMThompson Tomlinson Resident Louise Palmer Aurecon Environmental Consultancy Tichy Mashiri Dominion Business Investments Potential investor Geoff Newcombe Resident Chao-Sheng Chang Family Trust Retiefplein home owner Resident R Wahab Retiefplein home owner Resident TJ & MM Knoesen Retiefplein home owner Resident MJ Loftus Retiefplein home owner Resident J Williams Retiefplein home owner Resident PJ Thorp Retiefplein home owner Resident MM Almeida Retiefplein home owner Resident D Robey Retiefplein home owner Resident SJ Page Retiefplein home owner Resident L Grondel Retiefplein home owner Resident Blue Grass Family Trust Retiefplein home owner Resident HM Ball Retiefplein home owner Resident EC Walker Retiefplein home owner Resident CJVR Family Trust Retiefplein home owner Resident DH Morgan Retiefplein home owner Resident P Watts Retiefplein home owner Resident RN Pearton Retiefplein home owner Resident HV Kaplan Retiefplein home owner Resident Nick De Goede South African National Parks Government Kyle Smith South African National Parks Government

research & monitoring 50 Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

NAME AND SURNAME AFFILIATION CATEGORY Michael Barry Nelson Mandela University Heritage Peter Deyzel Marine Training & Consulting Diving industry Evania Snyman Elite SCUBA Diving industry Stewart Norman Capricorn Marine Environmental (Pty) Ltd Environmental Consultancy Prinea McGillivray Echo Foundation Resident Trevor Stroud Echo Foundation Resident Misiwe Ngqondela Private citizen Mpatisi Pantsi Transnet National Ports Authority (TNPA) - Port of Ngqura Government Thuleka Nxele Transnet National Ports Authority (TNPA) - Port of Port Elizabeth Government Zimasa Sani Transnet National Ports Authority (TNPA) - Port of Ngqura Government Shaun Deyzel South African Environmental Observation Network (South African Environmental Observation Network (SAEON)) Research institute Funanani Ditinti Department of Environmental Affairs: Branch Oceans and Coasts - Integrated Environmental Management Government Daisy Kotsedi Department of Environmental Affairs: Branch Oceans and Coasts - Integrated Environmental Management Government Daniel Marnewick Birdlife South Africa (Dale Wright no longer works at BirdLife, initial suggestion Jonathan Booth has replaced him) Conservation Sandile Nzanzeka Ward 23 Motherwell, Markman Industrial Government Roberto Almanza CES - Environmental and Social Advisory Services Environmental Consultancy Millicent Solomons National DEA: Director - Strategic Infrastructure Developments Government Thandeka Mbambo Department of Environmental Affairs: Branch Oceans and Coasts - Integrated Coastal Management Government Matlhodi Mogorosi Integrated Environmental Authorisations Government Fiona Grimett Integrated Environmental Authorisations Government Amahle Magobiyane Phakamisa Fishing Company Fishing Industry Andy Radford Eastern Province Longboard Surfing Association (Note that this person is also registered under Industry. Surfing committee Gisela Brauer Wildlife and Environment Society of South Africa (WESSA) Conservation Mphumze Mofu Malanje Trading Private citizen Roxanne Willemse Private citizen Hilton Prinsloo Khoisan Fisher Private citizen Siya Somntu Insight Media Media Mxoleli Nkuhlu Mamjoli Marine Private citizen

research & monitoring 51 Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

NAME AND SURNAME AFFILIATION CATEGORY Xola Ngcangca Black Fishers Association Fishing industry Sobelo Nkuhlu Private citizen Siya Ntsumpa GTW Foundation/ Wildlife and Environment Society of South Africa (WESSA) Conservation Yanga Mnyamana Department of Environmental Affairs Government Xolani Teyise Department of Agriculture, Forestry and Fisheries Government Otto Njamela Mamjoli Marine Private citizen Bongani Pitoyi Department of Agriculture, Forestry and Fisheries Government Carlo Coetzee AB Marine Recreational Awbrey Arends Khoisan Fisher Private citizen Mervyn Brouard Wildlife and Environment Society of South Africa (WESSA) Conservation John Ria Knysna Oyster Company Fishing Industry Shaldon Gonlag Private citizen Ian Gray Private citizen CR van Wyk Allen Associates Construction Business Johann Dreyer Madiba Bay Leisure Park Aquaculture Mariette Rossous MRA Private citizen Albie Braun Private citizen Susan Tee Private citizen Werner Smit Ironman SA Sports events Isobel Douglas-Jones Wildlife and Environment Society of South Africa (WESSA) Conservation Sharole Moss SEADA Private citizen Nick Wilmot The Port Elizabeth Metro Bed & Breakfast Association (PEMBBA) Private citizen Ntombi Zezethu Construction Construction Business Luthaniso Coto Private citizen DeonD Department of Agriculture, Forestry and Fisheries Government JeanGM Department of Agriculture, Forestry and Fisheries Government JeanG Department of Agriculture, Forestry and Fisheries Government DenhamP Department of Agriculture, Forestry and Fisheries Government

research & monitoring 52 Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

NAME AND SURNAME AFFILIATION CATEGORY Karen Humby South African Squid Management Industrial Association (SASMIA) Fishing Industry William Gqeke Balobi Fishing Enterprises Fishing Industry Mongezi South African Squid Management Industrial Association (SASMIA) Fishing Industry Jim Tucker South African Squid Management Industrial Association (SASMIA) Fishing Industry Neville Brink South African Squid Management Industrial Association (SASMIA) Fishing Industry Charmaine Potgieter South African Squid Management Industrial Association (SASMIA) Fishing Industry Eugene van Niekerk South African Squid Management Industrial Association (SASMIA) Fishing Industry Keith Bowler World Endurance Africa Holdings (Pty) Ltd – A subsidiary of IRONMAN® Sports events Ed Richardson Siyathetha Communications Industry Grant Minnie Propella Industry Gordon Knoesen GT Technology Industry David Allen CIAC AquacultureVentures Division Aquaculture Ronelle Friend Enviro-Quest Environmental Consultancy Verona Veltman Private citizen Cheryl Witte Nelson Mandela Bay Tourism Government Mthulisi Msimanga Nelson Mandela Bay Municipality Government Moira Allen Associates Potential investor Schalk Potgieter Nelson Mandela Bay Municipality - Human Settlement Government Bridget Loggenberg Nelson Mandela Bay Municipality - Human Settlement Government Roxanne George Nelson Mandela Bay Municipality Government Shaun Fitzhenny Nelson Mandela Bay Tourism Government Linda Mdoda Private citizen

research & monitoring 53 Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

APPENDIX F4: EMAILS SENT TO STAKEHOLDERS

54 research & monitoring 10/07/2019 Anchor Environmental Mail - Algoa Bay ADZ - Stakeholder consultation

Anchor Info

Algoa Bay ADZ - Stakeholder consultation 1 message

Anchor Info Fri, Dec 21, 2018 at 5:48 PM To: Anchor Info Bcc: Redacted for the protection of personal information of I&APs

Dear Stakeholder, APPLICATION IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 (ACT NO. 107 OF 1998) ENVIRONMENTAL IMPACT ASSESSMENT REGULATIONS, 2014 (AS AMENDED) FOR ENVIRONMENTAL AUTHORISATION THROUGH A BASIC ASSESSMENT PROCESS: PROPOSED SEA-BASED AQUACULTURE DEVELOPMENT ZONE IN ALGOA BAY, EASTERN CAPE

The Department of Agriculture, Forestry and Fisheries (DAFF), as the lead agent for aquaculture management and development, intends to establish and manage a sea-based Aquaculture Development Zone (ADZ) in Algoa Bay located in the Eastern Cape. A sea-based ADZ usually consists of a selection of designated precincts, which provide opportunities for existing aquaculture operations to expand and new ones to be established. ADZs provide economic benefits to the local community through job creation and regional economic diversification. ADZs are intended to boost investor confidence by providing ‘investment ready’ platforms with strategic environmental approvals and management policies already in place, allowing commercial aquaculture operations to be set up without the need for lengthy, complex and expensive approval processes. It is anticipated that an ADZ will create incentives for industry growth, provide marine aquaculture services and enhance consumer confidence. A The Background Information Document (BID) for this project has been attached in this email.

The proposed ADZ triggers a number of Listed Activities in the Environmental Impact Assessment (EIA) Regulations, 2014 (as amended by Government Notice No. 40772 of 7 April 2017), promulgated in terms of the National Environmental Management Act (Act No. 107 of 1998) (NEMA). DAFF is therefore required to apply for Environmental Authorisation to the National Department of Environmental Affairs (DEA). DAFF appointed Anchor Research & Monitoring (Pty) Ltd (Anchor) as the Environmental Assessment Practitioner (EAP) to undertake the Basic Assessment (BA) process.

Basic Assessment process must be undertaken in compliance with Government Notice (GN) R. 326 of 2017 (2014 Environmental Impact Assessment (EIA) Regulations as amended) and with the guideline documents for EIA processes and stakeholder consultation, as produced by the DEA.

Although not a requirement of the 2014 EIA Regulations, Anchor is undertaking “pre-application” stakeholder engagement to consult with the public and authorities early in the Basic Assessment process. To date, Anchor has compiled the Draft Pre-application Basic Assessment Report (BAR), which will be presented to the DEA in a pre- application meeting early next year. Recommendations tabled at the meeting will be incorporated into the Final Pre- application BAR and will be circulated to the public for comment.

You have been identified as a potential Interested and Affected Party (I&AP). As an I&AP, you will be notified of the stakeholder consultation process periods, including the venue, date and time for the open day that will be held in Port Elizabeth as part of the consultation process.

Please contact us should you not wish to be registered as I&AP for the proposed project.

Please do not hesitate to contact me should you have any questions with regards to the proposed project or stakeholder consultation process.

Kind regards,

Vera Massie

-- Anchor Environmental Consultants (Pty) Ltd

8 Steenberg House Silverwood Close, Tokai, 7975 https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-a%3Ar-198895241438641226%7Cmsg-a%3Ar28557610… 1/2 10/07/2019 Anchor Environmental Mail - Algoa Bay ADZ - Stakeholder consultation

Phone: +27 21 701 3420 Fax: +27 21 701 5280 Email: [email protected] Website: https://anchorenvironmental.co.za

DAFF BAR_pre-application_BAR_Appendix C - BID Dec 2018.pdf 753K

https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-a%3Ar-198895241438641226%7Cmsg-a%3Ar28557610… 2/2 10/07/2019 Anchor Environmental Mail - Invitation to attend authorities meeting

Vera Massie

Invitation to attend authorities meeting 1 message

Vera Massie 8 February 2019 at 14:29 To: Zanda Mkhulisi Transnet National Ports Authority PLZ , [email protected], [email protected], [email protected], [email protected], [email protected], Xolani Nikelo , [email protected], [email protected], Dayalan Govender , "Nelson Mbatha [Transnet NPA DBN]" , [email protected], [email protected], [email protected], Mandilakhe Mdodana Transnet National Ports Authority NGQ , Sandisiwe Mtintsilana Transnet National Ports Authority NGQ , [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], Pamela Nomhle Mali , [email protected], [email protected]

Dear All,

Anchor has been appointed by DAFF to conduct the Basic Assessment process for the proposed Algoa Bay sea- based Aquaculture Development Zone (ADZ). We are in the process of finalising the pre-application Basic Assessment Report and will be conducting the pre-application public participation process for the project in March. We are intending to set-up an authority meeting as part of the initial consultation period to ensure early involvement in the project.

The Provincial Department of Environmental Affairs (DEDEA), Transnet (Port of Nqura, Port of Port Elizabeth and National), as well as the Mandela Bay Municipality have been identified as critical entities to attend the authority meeting.

We would like to invite you to attend the authority meeting.

Kindly could you disclose your availability for the following dates: 4-7th March 2019. The time of the meeting will be scheduled around midday or after lunch (TBC).

Please could you also indicate to me if you feel that I have left out an important entity in your organisation so I can extend the invitation.

Please respond to this invitation as soon as possible with your preferred date.

Thank you,

Kind regards

Vera

-- Vera Massie- Liebau - Environmental Consultant

Anchor Environmental Consultants 8 Steenberg House Silverwood Close, Tokai, 7975

Phone: +27 21 701 3420 Fax: +27 21 701 5280 Email: [email protected] Website: https://anchorenvironmental.co.za/

https://mail.google.com/mail/u/0?ik=febaf18206&view=pt&search=all&permthid=thread-a%3Ar3278737918179777537%7Cmsg-a%3Ar91269444… 1/1 10/07/2019 Anchor Environmental Mail - Public meeting: Algoa Bay Aquaculture Development Zone

Anchor Info

Public meeting: Algoa Bay Aquaculture Development Zone 1 message

Anchor Info Tue, Feb 26, 2019 at 2:48 PM To: Anchor Info Bcc: Redacted for the protection of personal information of I&APs

Dear Stakeholder,

Anchor Research & Monitoring (Pty) Ltd (Anchor) was appointed by the Department of Agriculture, Forestry and Fisheries (DAFF) as the Environmental Assessment Practitioner (EAP) to conduct the Basic Assessment (BA) process for an Environmental Authorisation (EA) application in terms of the National Environmental Management Act (Act 107 of 1998) (NEMA) for a proposed sea-based Aquaculture Development Zone (ADZ) in Algoa Bay, Eastern Cape.

You are herewith invited to attend the pre-application phase public meeting for the proposed project.

Date: 6th March 2019 Time: 18:00 - 20:30 Venue: City Hall Auditorium in Port Elizabeth. Vuyisile Mini Square, Govan Mbeki Ave, Port Elizabeth Central, Port Elizabeth, 6001

Please note that an application for Environmental Authorisation has NOT yet been submitted to the competent authority (i.e. National Department of Environmental Affairs).

The objective of the pre-application meeting is to provide an overview of the proposed project and to present the preliminary results of the environmental impact assessment. The commenting period will be opened at the public meeting and will be concluded on the 5th April 2019 (end of business).

Thank you,

Kind regards,

Songezo Mtsokoba Anchor Environmental Consultants (Pty) Ltd 8 Steenberg House Silverwood Close, Tokai, 7975

Phone: +27 21 701 3420 Fax: +27 21 701 5280 Email: [email protected] Website: https://anchorenvironmental.co.za

https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-a%3Ar-4372463099636114782%7Cmsg-a%3Ar7295909… 1/1 10/07/2019 Anchor Environmental Mail - NB: Algoa Bay ADZ public meeting - Change to Main Hall!

Anchor Info

NB: Algoa Bay ADZ public meeting - Change to Main Hall! 1 message

Anchor Info Tue, Mar 5, 2019 at 12:11 PM To: Anchor Info Bcc: Redacted for the protection of personal information of I&APs

Dear Stakeholder,

Due to flooding at the City Hall Auditorium, the venue for the public meeting for the Algoa Bay Aquaculture Development Zone Environmental Authorisation application has been moved to the Main Hall/Reception Area on the ground floor.

The date and time remain the same. Details for the meeting are shown below:

Date: 6th March 2019 Time: 18:00 - 20:30 Venue: Main Hall/Reception Area, Port Elizabeth. Vuyisile Mini Square, Govan Mbeki Ave, Port Elizabeth Central, Port Elizabeth, 6001

Please find the agenda for the meeting attached.

Kind regards,

Vera Massie

-- Anchor Environmental Consultants (Pty) Ltd

8 Steenberg House Silverwood Close, Tokai, 7975

Phone: +27 21 701 3420 Fax: +27 21 701 5280 Email: [email protected] Website: https://anchorenvironmental.co.za

2019_03_06_Algoa ADZ Public meeting agenda.pdf 105K

https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-a%3Ar-2467918849555482070%7Cmsg-a%3Ar-2395895… 1/1 10/07/2019 Anchor Environmental Mail - Algoa Bay ADZ - Authorities meeting

Vera Massie

Algoa Bay ADZ - Authorities meeting 1 message

Vera Massie 8 March 2019 at 18:01 To: Dayalan Govender , Mandilakhe Mdodana Transnet National Ports Authority NGQ , Siyabonga Dlulisa , Isaac Nokele , Jill Miller , Andries Struwig , Xolani Nikelo , [email protected], Zanda Mkhulisi Transnet National Ports Authority PLZ , [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected], [email protected] Cc: Ken Hutchings , Songezo Mtsokoba , ZimasaJ , MaxhobaAJ , MichellePR

Dear All,

Thank you very much for attending the authorities meeting for the proposed sea-based Aquaculture Development Zone in Algoa Bay, which was held on 6 March 2019 at the Eastern Cape Department: Economic Development, Environmental Affairs and Tourism in Port Elizabeth.

Please find the presentation for this meeting attached for your reference.

Our sincere apologies that there was not enough time for everybody to provide comments or table questions during the meeting. As discussed, if you wish to, you can provide your comments/questions in writing by 15th February for inclusion in the minutes of this meeting (to be circulated within the next two weeks).

Alternatively, you can await the opening of the consultation period (within the next two weeks) where the pre- application BAR will be made available to you and provide comment on the published documents.

Please submit your written comments to: Vera Massie: [email protected]

Please do not hesitate to contact me if you have any questions.

Kind regards

Vera

-- Vera Massie- Liebau - Environmental Consultant

Anchor Environmental Consultants 8 Steenberg House Silverwood Close, Tokai, 7975

Phone: +27 21 701 3420 Fax: +27 21 701 5280 Email: [email protected] Website: https://anchorenvironmental.co.za/

Algoa Bay BA Presentation - Authorities meeting 20180306.pdf 2170K

https://mail.google.com/mail/u/0?ik=febaf18206&view=pt&search=all&permthid=thread-a%3Ar-8764136935417668587%7Cmsg-a%3Ar73023278… 1/1 10/07/2019 Anchor Environmental Mail - Algoa ADZ - Pre-application public participation

Anchor Info

Algoa ADZ - Pre-application public participation 1 message

Anchor Info Tue, Apr 9, 2019 at 3:14 PM To: Anchor Info Bcc: Redacted for the protection of personal information of I&APs

Dear Stakeholder, APPLICATION IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 (ACT NO. 107 OF 1998) ENVIRONMENTAL IMPACT ASSESSMENT REGULATIONS, 2014 (AS AMENDED) FOR ENVIRONMENTAL AUTHORISATION THROUGH A BASIC ASSESSMENT PROCESS: PROPOSED SEA-BASED AQUACULTURE DEVELOPMENT ZONE IN ALGOA BAY, EASTERN CAPE

The Department of Agriculture, Forestry and Fisheries (DAFF), as the lead agent for aquaculture management and development, intends to establish and manage a sea-based Aquaculture Development Zone (ADZ) in Algoa Bay located in the Eastern Cape. A sea-based ADZ usually consists of a selection of designated precincts, which provide opportunities for existing aquaculture operations to expand and new ones to be established. ADZs provide economic benefits to the local community through job creation and regional economic diversification. ADZs are intended to boost investor confidence by providing ‘investment ready’ platforms with strategic environmental approvals and management policies already in place, allowing commercial aquaculture operations to be set up without the need for lengthy, complex and expensive approval processes. It is anticipated that an ADZ will create incentives for industry growth, provide marine aquaculture services and enhance consumer confidence.

The proposed ADZ triggers a number of Listed Activities in the Environmental Impact Assessment (EIA) Regulations, 2014 (as amended by Government Notice No. 40772 of 7 April 2017), promulgated in terms of the National Environmental Management Act (Act No. 107 of 1998) (NEMA). DAFF is therefore required to apply for Environmental Authorisation to the National Department of Environmental Affairs (DEA). DAFF appointed Anchor Research & Monitoring (Pty) Ltd (Anchor) as the Environmental Assessment Practitioner (EAP) to undertake the Basic Assessment (BA) process.

A Basic Assessment process must be undertaken in compliance with Government Notice (GN) R. 326 of 2017 (2014 Environmental Impact Assessment (EIA) Regulations as amended) and with the guideline documents for EIA processes and stakeholder consultation, as produced by the DEA.

Anchor has compiled the Pre-application Basic Assessment Report (BAR), which can be downloaded on our website at https://anchorenvironmental.co.za/node/344

(If you navigate to our website without the direct link, click on the 'Public Documents' tab and select the 'Algoa Bay Aquaculture Development Zone' project link)

You are herewith notified of the start of the 30 day pre-application public participation phase (public participation phase 1 of 2). Please submit your comments on the pre-application Basic Assessment Report by Tuesday 30 April 2019 (note that this notification was sent out to stakeholders on 28 March 2019).

Going forward, DAFF intends to submit the application for Environmental Authorisation to the Department of Environmental Affairs at the end of May 2019. A second public participation process will be held during the application phase, where a public meeting will be held in Port Elizabeth. As a stakeholder you will be notified of the details of the next meeting.

Please do not hesitate to contact me should you have any questions with regards to the proposed project or stakeholder consultation process.

Kind regards,

Vera Massie

-- Anchor Environmental Consultants (Pty) Ltd https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-a%3Ar-7157477575910361945%7Cmsg-a%3Ar2065580… 1/2 10/07/2019 Anchor Environmental Mail - Algoa ADZ - Pre-application public participation

8 Steenberg House Silverwood Close, Tokai, 7975

Phone: +27 21 701 3420 Fax: +27 21 701 5280 Email: [email protected] Website: https://anchorenvironmental.co.za

https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-a%3Ar-7157477575910361945%7Cmsg-a%3Ar2065580… 2/2 10/07/2019 Anchor Environmental Mail - Algoa Bay ADZ: Draft Minutes Public Meeting

Anchor Info

Algoa Bay ADZ: Draft Minutes Public Meeting 1 message

Anchor Info Tue, Apr 23, 2019 at 3:06 PM To: Redacted for the protection of personal information of I&APs

Dear Stakeholder,

Thank you for attending the public meeting for the proposed Algoa Bay Aquaculture Development Zone on 6 March 2019 in Port Elizabeth.

Please find attached the Draft minutes of the meeting. My apologies for the delay in sending you these. We would like to ensure that stakeholder concerns were adequately captured.

Please provide us with your comments on the minutes by Friday 10th May 2019. Thereafter, the minutes will be corrected if required and will be circulated to all stakeholders and uploaded on our website.

Please be aware that despite precautionary measures that we have taken, our notifications appear to be categorised as spam by a number of email service providers. Please make sure you add this email address: [email protected] to your contacts to ensure that you receive future updates on this project (there may be other avenues to tag our email address as safe depending on the service provider).

Thank you,

Kind regards

Vera

-- Anchor Environmental Consultants (Pty) Ltd

8 Steenberg House Silverwood Close, Tokai, 7975

Phone: +27 21 701 3420 Fax: +27 21 701 5280 Email: [email protected] Website: https://anchorenvironmental.co.za

Algoa Bay ADZ Public meeting 20180306 Draft minutes.pdf 503K

https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-a%3Ar484614371659123866%7Cmsg-a%3Ar-78818812… 1/1 10/07/2019 Anchor Environmental Mail - Algoa Bay ADZ: Authorities meeting draft minutes

Anchor Info

Algoa Bay ADZ: Authorities meeting draft minutes 1 message

Anchor Info Wed, Apr 24, 2019 at 3:30 PM To: [email protected]

Dear All,

Thank you for attending the authorities meeting for the proposed Algoa Bay Aquaculture Development Zone project on 6 March 2019 in Port Elizabeth.

Please find attached the Draft minutes of the meeting. My apologies for the delay in sending you these. We would like to ensure that your comments were adequately captured.

Please provide us with your comments on the minutes by Friday 10th May 2019. Thereafter, the minutes will be corrected if required and will be circulated to all stakeholders and uploaded on our website.

Please be aware that despite precautionary measures that we have taken, our notifications appear to be categorised as spam by a number of email service providers. Please make sure you add this email address: [email protected] to your contacts to ensure that you receive future updates on this project (there may be other avenues to tag our email address as safe depending on the service provider).

Thank you,

Kind regards

Vera

-- Anchor Environmental Consultants (Pty) Ltd

8 Steenberg House Silverwood Close, Tokai, 7975

Phone: +27 21 701 3420 Fax: +27 21 701 5280 Email: [email protected] Website: https://anchorenvironmental.co.za

Algoa Bay ADZ Author meeting 20180306 Draft minutes.pdf 442K

https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-a%3Ar6557317233713730369%7Cmsg-a%3Ar70750199… 1/1 10/07/2019 Anchor Environmental Mail - Algoa ADZ - Reminder

Anchor Info

Algoa ADZ - Reminder 1 message

Anchor Info Thu, Apr 25, 2019 at 12:44 PM To: Redacted for the protection of personal information of I&APs

Dear Stakeholder,

Please be aware that despite precautionary measures that we have taken, our notifications appear to be categorised as spam by a number of email service providers. Please make sure you add this email address: info@ anchorenvironmental.co.za to your contacts to ensure that you receive future updates on this project (there may be other avenues to tag our email address as safe depending on the service provider).

Please note that the pre-application phase commenting period ends on 30 April 2019. Please refer to the notice below, which was sent to you on 28 March 2019.

Kind regards,

Vera Massie

Dear Stakeholder,

APPLICATION IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 (ACT NO. 107 OF 1998) ENVIRONMENTAL IMPACT ASSESSMENT REGULATIONS, 2014 (AS AMENDED) FOR ENVIRONMENTAL AUTHORISATION THROUGH A BASIC ASSESSMENT PROCESS: PROPOSED SEA-BASED AQUACULTURE DEVELOPMENT ZONE IN ALGOA BAY, EASTERN CAPE

The Department of Agriculture, Forestry and Fisheries (DAFF), as the lead agent for aquaculture management and development, intends to establish and manage a sea-based Aquaculture Development Zone (ADZ) in Algoa Bay located in the Eastern Cape. A sea-based ADZ usually consists of a selection of designated precincts, which provide opportunities for existing aquaculture operations to expand and new ones to be established. ADZs provide economic benefits to the local community through job creation and regional economic diversification. ADZs are intended to boost investor confidence by providing ‘investment ready’ platforms with strategic environmental approvals and management policies already in place, allowing commercial aquaculture operations to be set up without the need for lengthy, complex and expensive approval processes. It is anticipated that an ADZ will create incentives for industry growth, provide marine aquaculture services and enhance consumer confidence.

The proposed ADZ triggers a number of Listed Activities in the Environmental Impact Assessment (EIA) Regulations, 2014 (as amended by Government Notice No. 40772 of 7 April 2017), promulgated in terms of the National Environmental Management Act (Act No. 107 of 1998) (NEMA). DAFF is therefore required to apply for Environmental Authorisation to the National Department of Environmental Affairs (DEA). DAFF appointed Anchor Research & Monitoring (Pty) Ltd (Anchor) as the Environmental Assessment Practitioner (EAP) to undertake the Basic Assessment (BA) process.

A Basic Assessment process must be undertaken in compliance with Government Notice (GN) R. 326 of 2017 (2014 Environmental Impact Assessment (EIA) Regulations as amended) and with the guideline documents for EIA processes and stakeholder consultation, as produced by the DEA.

Anchor has compiled the Pre-application Basic Assessment Report (BAR), which can be downloaded on our website at https://anchorenvironmental.co.za/node/344

(If you navigate to our website without the direct link, click on the 'Public Documents' tab and select the 'Algoa Bay Aquaculture Development Zone' project link)

You are herewith notified of the start of the 30 day pre-application public participation phase (public participation phase 1 of 2). Please submit your comments on the pre-application Basic Assessment Report by Tuesday 30 April 2019 (note that this notification was sent out to stakeholders on 28 March 2019).

Going forward, DAFF intends to submit the application for Environmental Authorisation to the Department of Environmental Affairs at the end of May 2019. A second public participation process will be held during the application https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-a%3Ar-7598392284888358032%7Cmsg-a%3Ar9172341… 1/2 10/07/2019 Anchor Environmental Mail - Algoa ADZ - Reminder phase, where comments may be submitted and a public meeting will be held in Port Elizabeth. As a stakeholder you will be notified of the details of the next meeting.

Please do not hesitate to contact me should you have any questions with regards to the proposed project or stakeholder consultation process.

-- Anchor Environmental Consultants (Pty) Ltd

8 Steenberg House Silverwood Close, Tokai, 7975

Phone: +27 21 701 3420 Fax: +27 21 701 5280 Email: [email protected] Website: https://anchorenvironmental.co.za

https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-a%3Ar-7598392284888358032%7Cmsg-a%3Ar9172341… 2/2 10/07/2019 Anchor Environmental Mail - Algoa Bay ADZ: Update

Anchor Info

Algoa Bay ADZ: Update 1 message

Anchor Info Mon, May 6, 2019 at 3:49 PM To: Redacted for the protection of personal information of I&APs

Dear Stakeholders,

Thank you for submitting your comments during the pre-application public participation period (28 March - 30 April 2019). We will respond to your comments in due course. Your comments and our response will be included in the stakeholder consultation report to be compiled for the Draft Basic Assessment Report (BAR). Please note that your name and contact details as shown in the signature of your email will be accessible to the public as our conversation will be printed as proof for public consultation.

Note that your submission of comment automatically registers you as a stakeholder for this process and that notifications will be sent to you going forward.

Please be aware that despite precautionary measures that we have taken, our notifications appear to be categorised as spam by a number of email service providers. Please make sure you add this email address: [email protected] to your contacts to ensure that you receive future updates on this project (there may be other avenues to tag our email address as safe depending on the service provider).

Kind Regards,

Vera Massie

-- Anchor Environmental Consultants (Pty) Ltd

8 Steenberg House Silverwood Close, Tokai, 7975

Phone: +27 21 701 3420 Fax: +27 21 701 5280 Email: [email protected] Website: https://anchorenvironmental.co.za

https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-a%3Ar4384591731436385828%7Cmsg-a%3Ar83111297… 1/1 10/07/2019 Anchor Environmental Mail - Algoa Bay ADZ: Delay in public participation

Anchor Info

Algoa Bay ADZ: Delay in public participation 1 message

Anchor Info Fri, Jun 14, 2019 at 3:47 PM To: Anchor Info Bcc: Redacted for the protection of personal information of I&APs

Dear Stakeholder,

The second round of public participation (application phase) has been delayed due to the large volumes of comments received during the pre-application phase.

We are currently compiling the Draft Basic Assessment Report by incorporating the input from stakeholders received during the pre-application phase.

We anticipate that the application-phase public participation round will commence in the first week of July 2019. Please note that the next phase of the public participation process will include a public meeting in Port Elizabeth. You will be notified of the opening and duration of the public participation phase, as well as the details of the public meeting.

We apologise for the delay and appreciate your patience.

Kind regards,

Vera Massie

-- Anchor Environmental Consultants (Pty) Ltd

8 Steenberg House Silverwood Close, Tokai, 7975

Phone: +27 21 701 3420 Fax: +27 21 701 5280 Email: [email protected] Website: https://anchorenvironmental.co.za

https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-a%3Ar-1913199855850656902%7Cmsg-a%3Ar2118782… 1/1 11/10/2019 Anchor Environmental Mail - Algoa Bay ADZ - Application Phase Consultation

Anchor Info

Algoa Bay ADZ - Application Phase Consultation 1 message

Anchor Info Fri, Jul 19, 2019 at 5:05 PM To: Anchor Info Bcc: Redacted for protection of personal information

Dear Stakeholder,

RE: Algoa Bay Sea-Based Aquaculture Development Zone Basic Assessment Process

Anchor has finalised the Draft Basic Assessment Report by incorporating input from stakeholders received during the pre-application public participation process, which was completed on 30 April 2019.

DAFF has submitted the application for environmental authorisation. It is important to note that, based on the revised significance of negative economic impacts linked to finfish farming at Algoa 1 Option 1 from ‘medium’ to ‘high’ after implementation of mitigation measures, DAFF has revised its priorities in respect of mariculture in Algoa Bay and has nominated Option B as the preferred Alternative Option. Alternative Option B involves:

Mussel and oyster farming at Algoa 1 Option 1 (Summerstrand site)

Mussel and oyster farming at Algoa 6 (PE Harbour site); and

Finfish farming at Algoa 7 (Ngqura Harbour site)

You are herewith notified of the upcoming application-phase public participation process (Public Participation Phase 2 of 2), which will commence on 23 July 2019. Please submit your comments on the Draft Basic Assessment Report (BAR) by Wednesday 28 August 2019.

Note that the Draft Basic Assessment Report and Appendices are already available on our website for download at https://anchorenvironmental.co.za/node/344

(If you navigate to our website without the direct link, click on the 'Public Documents' tab and select the 'Algoa Bay Aquaculture Development Zone' project link)

The Draft BAR (hard copy and ten electronic copies on CD at each location) will be made available during operating hours by 23 July 2019 at the following locations:

Newton Park Library: Hurd St, Newton Park, Port Elizabeth, 6045

Motherwell Library: Corner Umlu and Ngqokweni St, Motherwell, Port Elizabeth, 6211

Two public meetings will be held in Port Elizabeth during the upcoming public participation process:

Date: 31 July 2019 Time: 18:00 - 20:30 Venue: Main Hall/Reception Area, Port Elizabeth Vuyisile Mini Square, Govan Mbeki Ave, Port Elizabeth Central, Port Elizabeth, 6001 https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-a%3Ar2984719473896670825%7Cmsg-a%3Ar94102484… 1/2 11/10/2019 Anchor Environmental Mail - Algoa Bay ADZ - Application Phase Consultation

Date: 1 August 2019 Time: 18:00 - 20:30 Venue: Motherwell NU2 Community Hall, Chief Poto Street, Motherwell, 6211

The objective of the application-phase meeting is to present the outcomes of the pre-application public participation process and how comments provided by stakeholders were considered in the Draft BAR.

Please do not hesitate to contact me should you have any questions with regards to the proposed project or stakeholder consultation process.

Kind regards,

Vera Massie

-- Anchor Research & Monitoring (Pty) Ltd as part of the Anchor Environmental Group of Companies

8 Steenberg House Silverwood Close, Tokai, 7975

Phone: +27 21 701 3420 Fax: +27 21 701 5280 Email: [email protected] Website: https://anchorenvironmental.co.za

https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-a%3Ar2984719473896670825%7Cmsg-a%3Ar94102484… 2/2 11/10/2019 Anchor Environmental Mail - Algoa Bay ADZ - Consultation closes 28 Aug

Anchor Info

Algoa Bay ADZ - Consultation closes 28 Aug 1 message

Anchor Info Fri, Aug 16, 2019 at 4:35 PM To: Anchor Info Bcc: Redacted for protection of personal information

Dear Stakeholders,

This email serves as a reminder that the application-phase public participation phase for the proposed Algoa Bay Aquaculture Development Zone closes on 28 August 2019.

The Draft Basic Assessment Report and Appendices are available on our website for download at https:// anchorenvironmental.co.za/node/344

(If you navigate to our website without the direct link, click on the 'Public Documents' tab and select the 'Algoa Bay Aquaculture Development Zone' project link)

We have received a reference number for this project from the competent authority following the submission of the application on 22 July 2019:

Applicant: Department of Agriculture, Forestry and Fisheries Reference Number: 14/12/16/3/3/1/2055

Kind regards,

Vera Massie

-- Anchor Research & Monitoring (Pty) Ltd as part of the Anchor Environmental Group of Companies

8 Steenberg House Silverwood Close, Tokai, 7975

Phone: +27 21 701 3420 Fax: +27 21 701 5280 Email: [email protected] Website: https://anchorenvironmental.co.za

https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-a%3Ar-5926449494697209479%7Cmsg-a%3Ar-1314372… 1/1 11/10/2019 Anchor Environmental Mail - Algoa Bay ADZ - Consultation period extended

Anchor Info

Algoa Bay ADZ - Consultation period extended 1 message

Anchor Info Wed, Aug 28, 2019 at 9:48 AM To: Anchor Info Bcc: Redacted for protection of personal information

Dear Stakeholders,

This email serves as a notification that the application-phase public participation phase for the proposed Algoa Bay Aquaculture Development Zone will be extended until Wednesday 4 September 2019 close of business.

The Draft Basic Assessment Report and Appendices are available on our website for download at https:// anchorenvironmental.co.za/node/344

(If you navigate to our website without the direct link, click on the 'Public Documents' tab and select the 'Algoa Bay Aquaculture Development Zone' project link)

The Draft BAR (hard copy and ten electronic copies on CD at each location) is available during operating hours at the following locations:

Newton Park Library: Hurd St, Newton Park, Port Elizabeth, 6045

Motherwell Library: Corner Umlu and Ngqokweni St, Motherwell, Port Elizabeth, 6211

We have received a reference number for this project from the competent authority following the submission of the application on 22 July 2019:

Applicant: Department of Agriculture, Forestry and Fisheries Competent Authority: Department of Environmental Affairs Reference Number: 14/12/16/3/3/1/2055

Kind regards,

Vera Massie

-- Anchor Research & Monitoring (Pty) Ltd as part of the Anchor Environmental Group of Companies

8 Steenberg House Silverwood Close, Tokai, 7975

Phone: +27 21 701 3420 Fax: +27 21 701 5280 Email: [email protected] Website: https://anchorenvironmental.co.za

https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-a%3Ar8122962509977000159%7Cmsg-a%3Ar47419360… 1/1 11/10/2019 Anchor Environmental Mail - Algoa Bay ADZ - Consultation period extended

Anchor Info

Algoa Bay ADZ - Consultation period extended 1 message

Anchor Info Fri, Aug 30, 2019 at 4:30 PM To: Anchor Info Bcc: Redacted for protection of personal information

Dear Stakeholder,

Thank you for attending the application-phase public participation meeting for the Algoa Bay Aquaculture Development Zone project on 31 July and/or 1 August 2019. Please note that you have been registered as a stakeholder for this project on our database.

Unfortunately, we failed to notify you of the extension of the public participation period to 4 September 2019 end of business (the original deadline was 28 August 2019). This notification was sent out to all other stakeholders on 28 August 2019. You are herewith notified that you will receive an additional 3 working days to compensate for this error.

Please provide your comments by Monday 9th September 2019.

We offer our sincerest apologies for this oversight.

The Draft Basic Assessment Report and Appendices are available on our website for download at https:// anchorenvironmental.co.za/node/344

(If you navigate to our website without the direct link, click on the 'Public Documents' tab and select the 'Algoa Bay Aquaculture Development Zone' project link)

The Draft BAR (hard copy and ten electronic copies on CD at each location) is available during operating hours at the following locations:

Newton Park Library: Hurd St, Newton Park, Port Elizabeth, 6045

Motherwell Library: Corner Umlu and Ngqokweni St, Motherwell, Port Elizabeth, 6211

We have received a reference number for this project from the competent authority following the submission of the application on 22 July 2019:

Applicant: Department of Agriculture, Forestry and Fisheries Competent Authority: Department of Environmental Affairs Reference Number: 14/12/16/3/3/1/2055

Kind regards,

Vera Massie

-- Anchor Research & Monitoring (Pty) Ltd as part of the Anchor Environmental Group of Companies

8 Steenberg House Silverwood Close, Tokai, 7975

Phone: +27 21 701 3420 Fax: +27 21 701 5280 Email: [email protected] Website: https://anchorenvironmental.co.za

https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-a%3Ar6634172848460658473%7Cmsg-a%3Ar46613327… 1/1 11/10/2019 Anchor Environmental Mail - Algoa Bay ADZ: Draft Minutes Public Meeting 31 July 2019

Anchor Info

Algoa Bay ADZ: Draft Minutes Public Meeting 31 July 2019 1 message

Anchor Info Fri, Oct 4, 2019 at 3:35 PM To: Anchor Info Bcc: Redacted for the protection of personal information

Dear Stakeholder,

Thank you for attending the public meeting for the proposed Algoa Bay Aquaculture Development Zone on 31 July 2019 in Port Elizabeth.

Please find attached the presentation that was given by Anchor and the Draft minutes of the meeting. We would like to ensure that stakeholder concerns were adequately captured in the minutes.

Please provide us with your comments on the minutes by Thursday 10th October 2019. Thereafter, the minutes will be corrected if required and will be circulated to all stakeholders and uploaded on our website. Please note that the same presentation was given at both public meetings, namely in Port Elizabeth and Motherwell Community.

My sincere apologies for the delay in sending you the Draft Minutes.

Thank you for your understanding.

Kind regards,

Vera Massie

-- Anchor Research and Monitoring (Pty) Ltd as part of the Anchor Environmental Group of Companies

8 Steenberg House Silverwood Close, Tokai, 7975

Phone: +27 21 701 3420 Fax: +27 21 701 5280 Email: [email protected] Website: https://anchorenvironmental.co.za

2 attachments Algoa Bay ADZ Public meeting 20190731 Draft Minutes.pdf 238K Algoa Bay BAR - Public meeting presentation - Application Phase.pdf 4351K

https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-a%3Ar7395580324930104954%7Cmsg-a%3Ar56321169… 1/1 11/10/2019 Anchor Environmental Mail - Algoa Bay ADZ: Draft Minutes Public Meeting 1 August 2019

Anchor Info

Algoa Bay ADZ: Draft Minutes Public Meeting 1 August 2019 1 message

Anchor Info Fri, Oct 4, 2019 at 4:14 PM To: Anchor Info Bcc: Redacted for protection of personal information

Dear Stakeholder,

Thank you for attending the public meeting for the proposed Algoa Bay Aquaculture Development Zone on 1 August 2019 in Motherwell.

Please find attached the presentation that was given by Anchor and the Draft minutes of the meeting. We would like to ensure that stakeholder concerns were adequately captured in the minutes.

Please provide us with your comments on the minutes by Thursday 10th October 2019. Thereafter, the minutes will be corrected if required and will be circulated to all stakeholders and uploaded on our website. Please note that the same presentation was given at both public meetings, namely in Port Elizabeth and Motherwell Community.

My sincere apologies for the delay in sending you the Draft Minutes.

Thank you for your understanding.

Kind regards,

Vera Massie

-- Anchor Research and Monitoring (Pty) Ltd as part of the Anchor Environmental Group of Companies

8 Steenberg House Silverwood Close, Tokai, 7975

Phone: +27 21 701 3420 Fax: +27 21 701 5280 Email: [email protected] Website: https://anchorenvironmental.co.za

2 attachments Algoa Bay ADZ Public meeting 20190801 Draft Minutes.pdf 196K Algoa Bay BAR - Public meeting presentation - Application Phase.pdf 4351K

https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-a%3Ar-884183438120987352%7Cmsg-a%3Ar-38461402… 1/1 Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

55 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

APPENDIX F5: SUBSTANTIVE COMMENTS

56 research & monitoring

Pre-application consultation

Algoa Bay Aquaculture Development Zone

Our Ref:

Enquiries: Briege Williams Date: Monday April 15, 2019 Tel: 021 462 4502 Page No: 1 Email: [email protected] CaseID: 13103

Interim Comment In terms of Section 38 of the National Heritage Resources Act (Act 25 of 1999) Attention: Department of Agriculture Forestry and Fisheries

The Department of Agriculture, Forestry and Fisheries (DAFF), as the lead agent for aquaculture management and development in South Africa, intends to establish and manage a sea-based Aquaculture Development Zone (ADZ) in Algoa Bay in the Eastern Cape.

The South African Heritage Resources Agency (SAHRA) would like to thank you for submitting the Pre-application Basic Assessment Report for the Algoa Bay Aquaculture Development Zone.

Algoa Bay has a rich maritime history, its position as a safe anchorage led to an increased use of the bay and the establishment of Port Elizabeth as a major trading port. The development of the trading industry and the migration of people to this new settlement saw a surge in the number of vessels visiting the bay, however the lack of infrastructure to support this increase in traffic meant that the ships anchored out in the bay were vulnerable to bad weather and rough seas. Storms and gales could result in the wrecking or beaching of many ships, often in single incidents, for example the great gale of 1902 led to the wrecking of 21 vessels in one night. This concentration of wrecking incidents leads to a high potential of maritime cultural heritage being present on the seabed.

Because of the significant maritime history of Algoa Bay, SAHRA advised that a Maritime Archaeological Impact Assessment (AIA) report would be requested as part of the application process therefore this AIA has been produced as part of the Pre-application BAR.

The proposed work is based in three areas, namely Algoa 1, 6 and 7. The areas Algoa 1 and 7 have been identified as having a relatively low number of historical shipwrecks occurring in their vicinity. However, the area that constitutes Algoa 6 has a high concentration of recorded wreckings, mainly because it encompasses the area of the original landing place for the bay.

The maritime AIA has considered the historical significance of all three areas and makes the following recommendations based on the heritage potential in each area.

Algoa Bay Aquaculture Development Zone

Our Ref:

Enquiries: Briege Williams Date: Monday April 15, 2019 Tel: 021 462 4502 Page No: 2 Email: [email protected] CaseID: 13103

• Any geophysical data generated to support the development of aquaculture in this area must be archaeologically reviewed for the presence of historical shipwrecks or related material and to ground truth proposed mooring locations. Datasets that are particularly useful in this regard are magnetometer, side scan sonar and multibeam bathymetric data. It is recommended that the archaeologist is consulted before data are collected to ensure that the survey specifications and data outputs are suitable for archaeological review;

• Any video footage collected support to development of aquaculture in the three areas should ideally also be reviewed by the archaeologist for evidence of shipwreck material on the seabed;

• If geophysical data are not collected, the proposed positions of all moorings must be ground truthed by suitably qualified divers;

• Should the reviews and ground truthing set out above identify wreck material at or near the location of any proposed mooring, micro-siting of the mooring and the possible implementation of an exclusion zone around the archaeological feature should be sufficient to mitigate the risks to the site.

• Should any archaeological material, be accidentally encountered during the course of developing aquaculture operations in any of the proposed areas, work must cease in that area until the project archaeologist and SAHRA have been notified, the find has been assessed by the archaeologist, and agreement has been reached on how to deal with it.

SAHRA supports the above recommendations and reiterates that all efforts must be made to avoid damage and/or disturbance to any cultural heritage material.

Should you have any further queries, please contact the designated official using the case number quoted above in the case header.

Yours faithfully

Algoa Bay Aquaculture Development Zone

Our Ref:

Enquiries: Briege Williams Date: Monday April 15, 2019 Tel: 021 462 4502 Page No: 3 Email: [email protected] CaseID: 13103

______Briege Williams Heritage Officer South African Heritage Resources Agency

______Lesa la Grange Acting Manager: Maritime and Underwater Cultural Heritage South African Heritage Resources Agency

ADMIN: Direct URL to case: http://www.sahra.org.za/node/514209

Terms & Conditions:

1. This approval does not exonerate the applicant from obtaining local authority approval or any other necessary approval for proposed work. 2. If any heritage resources, including graves or human remains, are encountered they must be reported to SAHRA immediately. 3. SAHRA reserves the right to request additional information as required.

Powered by TCPDF (www.tcpdf.org) lronman South Africa (Pty) Ltd Reg No: 2003/031929/07 Vat No: 4340211343 No 7 5th Avenue, Walmer, Port Elizabeth, 6070 Postal: PO Box 40330, Walmer, Port Elizabeth, 6065 Tel: +27 (0)41 581-7990 Fax: +27 (0)41 581-4553 SOUTH AFRICA

ALGOA BAY AQUACULTURE DEVELOPMENT ZONE OBJECTION

To whom it may concern

IRONMAN South Africa is the biggest annual sporting event in Nelson Mandela Bay and utilises the coastal region earmarked for the above-mentioned development. We host four events in Nelson Mandela Bay annually that will be directly affected by this project. Our biggest and most prestigious event is the IRONMAN African Championship.

As such, we would hereby like to submit our formal appeal and grounds for objection against the proposed development:

• The IRONMAN African Championship event is one of only 5 international IRONMAN Championship events globally. The event brings in approximately R100 million in direct spend to the City annually. With 17 hours of live television coverage on SuperSport, valued at R183 million and Facebook Watch doing live streaming to 134 million global viewers, this is unprecedented exposure and promotion for the City as a tourism and sport destination. On average The event is crucially centred around the Port Elizabeth Beachfront. The 2100 athletes are required to swim 3.8km in the sea from Hobie Beach to Kings Beach and back, cycle 180km through Port Elizabeth (much of it along our expansive coastline) and run 42km along the coast. For the 2019 IRONMAN African Championship event there will be around 65 international countries represented and over 600 international athletes traveling to Nelson Mandela Bay to compete in this one day event. Ninety two percent of the 2100 athletes are from outside of Nelson Mandela Bay and each athletes brings on average 2.7 supporters for around 7 nights.

Should the said fish farming operation be introduced, it will result in Nelson Mandela Bay no longer being able to host any IRONMAN or related sporting events which will result in a massive loss of revenue and as previously mentioned, over R100 million in direct spend from the IRONMAN African Championship event alone. Money the City can ill afford to lose.

The reasons for having to move the IRONMAN African Championship from Nelson Mandela Bay should the fish farming take place include:

o Degradation of the sea water quality, due to known side effects of fish farming which will result in the water being declared unfit for the event by international standards as well as the South African Events Act.

o Attracting predator fish and sharks to the waters used for the swim leg of the IRONMAN African Championship as the fish farming will result in the water being declared unfit for the event by international standards as well as the South African EventsAct, Nelson Mandela Bay Beach Office and Disaster Management.

o Waste, fish oil, fish meal, chemicals etc. will create a foul smell which will detract from the beauty of our coastline and negatively impact the IRONMAN African Championship event. The large cages will also spoil the visual beauty of the coastline and will look particularly unsightly on our television production broadcasted around the world.

Directors: KR Bowler; PS Wolff;MR Madwara (SA) AL Messick; JP Gramling; SL Johnston; SM Facteau (USA) Page 2 of 2

o Destruction and degradation of the natural Algoa Bay habitat and its bio diversity which will, in the long term destroy ecotourism in the area: Greater Addo with its Marine Protected Areas, Diving, Whale/Dolphin/Orea and other marine watching activities and their long-term sustainability

o This proposed development is not the best practice in fish farming as there are known side effects of this style of fish farming in holding pens in the open sea. There are better options available.

o Has land based fish farming been investigated?

The proposed development will stop all efforts of positioning Nelson Mandela Bay as the water sport capital of Africa and will cause the cancellation of numerous major sporting events hosted in the Bay. As a result, the City will lose millions in tourism revenue and result in unemployment numbers increasing drastically as hundreds of employment opportunities are directly associated with the various major sporting events that are hosted on the Nelson Mandela Bay beachfront. In addition, future tourism to the City as a result of exposure through the events will be lost.

As IRONMAN South Africa and dedicated residents in Nelson Mandela Bay we strongly object to the proposed sea-based aquaculture development zones in Port Elizabeth.

Keith Bowler

Managing Director: IRONMAN South Africa

Paul Wolff

Director of Operations: IRONMAN South Africa

Directors: KR Bowler; PS Wolff; MR Madwara (SA) AL Messick; JP Gramling; SL Johnston; SM Facteau (USA) � PORT ELIZABETH INTERNATIONALAIRPORT AIRPORTS COMPANY SOUTH AFRICA

25 March 2019

ALGOA SEA BASED AQUACULTURE DEVELOPMENT ZONE

To: Anchor Environmental Consultants (Pty) Ltd

Attention: Vera Massie

During the public participation meeting on 6th March 2019, Port Elizabeth International Airportraised three issues which I would like to capture formally for record keeping.

The reason for this was, on the 19 February 2015 we submitted a letter to the appeal committee with concerns which never showed as any one of the several impacts during Anchor's public participation presentation on 6 March 2019.

1. The South African Civil Aviation Environmental Department has not been recognised as a major stakeholder of the AMC.?

2. Airports Company SA initially requested for two specialist studies be undertaken namely:

• Bird study on potential aviation hazards by an ornithologist. • Aeronautical study for any potential hazards on arrivals, departures, and the general aviation, flying low level coastwise passing Port Elizabeth, and/or training aircraftsdoing circuits and landings.

3. Lastly Airports Company SA would like to know the positioning of the processing plant as this is an incompatible land use surrounding airports. The positioning relates to all three options.

The InternationalCivil Aviation Organization (/CAO) Airport ServicesManual 9137 doc AN-898 Part3 2012 4th edition (Wildlife Control and Reduction) states that airport authorities shoulddo a survey of up to 13km around the airportto identify the incompatible land uses or activities around airports.

As this is a new development the onus willbe on the developers to conduct an assessment to ensure that aviation is not negatively impacted.

Tel +27 41 507 7348 Fax +27 41 507 7340 Administrator Office, Aeropark Office Complex, Block A, 1"t Floor, Allister Miller Drive, Walmer, Eastern Cape. South Africa PO Box 5787, Walmer, Eastern Cape, South Africa, 6065 www.aIrports.co.za

Airpcrts '.::ompany South Africa SOC Ltd Reg No 1993.'004149'30VAT no 49S013o393 i_ PORT ELIZABETH INTERNATIONAL AIRPORT AIRPORTS COMPANY SOUTH AFRICA

The Civil Aviation Regulations- CARS refer to aircraft and passenger safety.

Endangering safety 91. 01. 10 ( 1) No person shall, through any act or omission - (a) endanger the safety of an aircraft or person therein; or (b) cause or permit an aircraftto endanger the safety of any person or property.

The previous appeal is attached for reference

For further clarification please call the undersigned

Anthony Groom Acting Airport Manager Port Elizabeth International Airport Tel: 041 5077386 Cell:0828592522 Email: [email protected]

Tel +27 41 507 7348 Fax +27 41 507 7340 Administrator Office, Aeropark Office Complex, Block A, 1•t Floor, Allister Miller Drive, Walmer, Eastern Cape, South Africa PO Box 5787, Walmer, Eastern Cape, South Africa, 6065 www.a irports.co .za

Airports (:omoany South Africa soc Ltd R2g No 1993/u04149i30VAT ,o 4930138303

Eastern Province Deep Sea Angling Association Objection against 08/04/2019 PROPOSED SEA-BASED AQUACULTURE DEVELOPMENT ZONE IN ALGOA BAY, EASTERN CAPE.

We as the Eastern Province Deep Sea Angling Association further known as EPDSAA hereby wish to lodge an official objection against the allocation and consideration of the proposed sea-based Aquaculture Development Zone (ADZ) in Algoa Bay located in the Eastern Cape by the Department of Agriculture Forestry and Fisheries.

Reasons:

We EPDSAA believe the aquaponics and fish farms to have no direct impact on job creation, and growth in the aquiculture sector has more negatives and harmful impact on the enviroment than the positives it provides. These farms be it fish, oyster or essentially any other type of marine farming are also not very appealing to the eye.

Pollution.

This density of fish creates problems like disease and pollution. The biggest source of pollution is the accumulation of fish waste and uneaten food beneath the sea pens which can degrade the quality of the surrounding water. The amount of pollution from fish farms also depends on how the fish are contained and the quantity contained. We further believe diseases carried by the farmed fish could jump to the wild fish which could have catastrophic consequences for our wild fish population which is already under severe threat. Who will control and monitor these fish farms? Daff unfortunately does not have the infra structure nor the funding or expertise. The department of environmental affair has also expressed its concern regarding aquaculture and its effects on our wild fish stocks. Weather We further believe the weather conditions to be to extreme in Algoa Bay for it to be viable for any type of fish farming and would request to see the results if any of studies with regards to the weather conditions. Pedsac one of our largest fishing clubs is situated in the Port Elizabeth Harbour. The ground swell in the harbour has caused catastrophic damage to the mooring inside this enclosed harbour not to mention what we believe the weather and swell could do to these enclosure or fish pens in the open sea.

Predators Algoa Bay is well known for its shark population varying from the Ragged tooth sharks, Bronze Whalers to the Great White that frequent Bird Island seal population as well as the bay and St Croix area. There is the occasional tiger Shark as well as our seasonal Zambesi sharks. We fear these fish pens would increase the population and prevalence of these sharks in our waters changing the balance of the environment.

Conclusion: In conclusion we believe that there will be no economic benefit to the Algoa Bay area and no significant job creation to validate the creation of the ADZ. We also believe the amount of fish and protein that has to be used to fuel and grow these fish has a severely detrimental effect to the area in which these bait fish are harvested as well as a detrimental effect to the environment (in this case Algoa Bay) where they are farmed. I have not gone into any technical terms in our objection but have rather attempted to keep it as simple and understandable as possible.

Kind Regards

Wayne Gerber EPDSAA Fisheries and Environmental Officer Mobile:074 027 9140

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COMMENT ON ALGOA BAY AQUACULTURE DEVELOPMENT ZONE BASIC ASSESSMENT REPORT

DAFF is seeking DEA approval in terms of the National Environmental Management Act for the development of aquaculture facilities in Algoa Bay, Eastern Cape Province. The environmental impact assessment report and associated specialist study reports associated with the application are comprehensive, informative and thorough. As an IAP I would like to submit the following comment.

While acknowledging that aquaculture development is an important potential economic development sector and that suitable sites for offshore aquaculture are very limited on the South African coastline, the proposal to develop aquaculture facilities at three sites in Algoa Bay has multiple flaws and I do not think DEA should approve the development. The following issues are of major concern.

Conservation: The siting of aquaculture developments close to and, in the case of Algoa 7, within, a marine protected area does not align with the conservation objectives of MPAs. This is basic common sense. Nor is such a development really in line with many of the guiding principles of the NEM: Protected Areas Act (NEM:PA).

Section 48A of NEM:PA outlines activities that are restricted in a MPA – among them are the Discharge or deposit any polluting matter; and Disturbing, altering or destroying the natural environment or altering the water quality. These events will undoubtedly occur in the new Addo MPA and the existing Bird Island MPA as a result of aquaculture activities in Algoa Bay, given the location of Algoa 7 and possibly as a result of Algoa 6 and Algoa 1.

Under Section 55 of NEM:PA SANParks is obliged to manage the new Addo MPA in accordance with NEM:PA. The organisation cannot do this if the aquaculture development is approved.

Section 50 of NEM:PA directs that although the management authority may allow a commercial activity in the park, the activity may not negatively affect the survival of any species or significantly disrupt the integrity of the ecological systems of the park. There is no way that the Algoa Bay ADZ will not have an impact on the ecological integrity of the Addo MPA.

Approving the Algoa Bay ADZ will directly contravene NEM:PA. The DEA proposal to excise the area of the Algoa 7 site from the Addo MPA if authorisation is granted is ridiculous.

Impacts: The Marine Ecology specialist study indicates that “Due to the high diversity of habitats, marine organisms and seabirds in Algoa Bay (several of which are of conservation concern), significant biodiversity importance is attributed to many areas in the Bay”. Consider then the following statements in the Basic Assessment Report and the Marine Ecology report: There is very high potential for disease and parasite transmission from farmed stocks to wild stocks which could affect the natural ecosystem as well as having serious social impacts if fisheries are disrupted. Mitigation measures are not entirely effective, and the overall significance of the impact is estimated as very high without and high with mitigation (see Marine Ecology report). This is a source of serious concern, particularly in the vicinity of a MPA.

In open ocean farmed fish operations it appears that 40-80% of the uneaten food and waste falling out of cages may be eaten by wild fish. This increases the risk of parasite and disease transmission to wild stocks and may also attract piscivores to cages with the associated problems (Marine Ecology Report).

Untreated wastes resulting mainly from uneaten food and faeces of fish in sea cages are discharged directly into the sea and are not an insignificant source of nutrients. Nutrient discharges from yellowtail farms in Australia indicates that this species probably put more nutrients into the sea than other cultured finfish species (Marine Ecology report). Yellowtail would probably be farmed in the Algoa Bay ADZ. The effect of these nutrient discharges from a finfish farm will be greatly exacerbated by sluggish currents that occur about 25 % of the time in Algoa Bay according to in situ monitoring data (Marine Ecology Report). Thus, the probability of negative benthic and water quality impacts resulting from an aquaculture operation in Algoa Bay is high. In an area of significant biodiversity importance this is a particular source of concern particularly since Algoa 7 is inside the Addo MPA.

The farming of 3000 tonnes of yellowtail in Algoa Bay will add an extra 10% to the current dissolved inorganic nitrogen loading of Algoa Bay. Algoa Bay is already stressed from anthropogenic nutrient loading (waste water treatment works and storm water outfalls – Marine Ecology report). Elevated nutrient loading is one of the contributory factors to harmful algal blooms (HABs) and these HABs events can have dire consequences for aquaculture operations. The Marine Ecology report references a report that attributes the increased observation of eutrophic conditions in Algoa Bay, including harmful algal blooms and hypoxia at least in part to current anthropogenic nutrient loading from land-based sources. Adding nutrients from a fish farm will just make the situation worse.

Water Quality: Water quality is a key issue for any aquaculture operation. Consider then: Three waste water treatment works (WWTW) discharge into Algoa Bay and none of the discharges is very far from the proposed aquaculture development sites although the modelling indicates that water quality might be passable with respect to the Cape Recife WWTW discharge. However, there are no effluent dispersal modelling results available for the proposed CDC outfall which would discharge right next to Algoa 7 – discharges to include desalination wastewater, treated domestic wastewater and industrial effluents - classified as a high impact effluent type (high volume and poor water quality). There is no effluent dispersal modelling available for the Fishwater Flats WWTW and the discharge point is apparently close to Algoa 6. Driftsands WWTW discharge is not indicated in the BAR map and there are clearly no effluent dispersal modelling results. It would seem highly likely that polluted water will be a feature of any aquaculture development in Algoa Bay. This factor will almost certainly negatively impact on the general product health and the product market acceptability, particularly with regard to meeting any export health standards.

Physical oceanography: Rapid changes of water temperature can apparently occur in Algoa Bay and changes of 7°C over a 12 hr period have been detected (Marine Ecology report). The report indicates that rapid temperature declines will probably have a negative impact on stock, but the full impact of such rapid temperature decreases are not fully understood. Certainly, along the east coast of South Africa rapid decreases in temperature resulting from wind induced upwelling events have caused significant fish deaths in the past. There is no way of mitigating these temperature fluctuations and the possibility of such fluctuations should be of great concern to aquaculture developers, particularly when the individual fish are still small.

An important percentage of waves in excess of 3 m come from the south west generated by storms in the Southern Ocean. Most of Algoa Bay is protected from these swells by the rocky headland at Cape Recife, but maximum wave heights of 6 m have been recorded along the surf zone of Algoa Bay (Marine Ecology report). It only needs a single storm event with waves in excess of about 4 m to destroy floating cage structures in Algoa Bay. This would result in the loss of the entire stock. Such an event occurred several years ago at the pilot salmon farm at Gansbaai. All the salmon escaped into the marine environment.

For all the reasons listed above I would suggest that Algoa Bay is not a suitable ocean-based aquaculture development site. Much finer environmental control can be exerted in land-based facilities and the risks of losing the entire stock to disease, pollution or storm surf are virtually eliminated. Admittedly start-up costs are higher, but it only needs the loss of a single cohort of cage farmed fish to entirely cancel the additional costs of a land-based facility. There is an Aquaculture Development zone in the Coega IDZ and this should be used for the development.

Very Minor issues: Food and Agriculture Organisation is abbreviated FAO and not (persistently) FOA (Marine Ecology report).

PJ Fielding (IAP, East London)

P.O. Box 15006, Emerald Hill, 6011, Port Elizabeth, Eastern Cape, South Africa Email: [email protected] Mobile: 082 556 1680 URL: www.tournetafrica.com

Vera Massie Anchor Environmental Consultants (Pty) Ltd Tokai, Cape Town

Dear Vera,

Re: Comment on the Algoa Bay Sea-Based ADZ Draft Report

The comments below are based on a desktop research study undertaken by Peter Myles in his capacity as Chairman of the Nelson Mandela Bay Maritime Cluster and as an acknowledged coastal & marine tourism specialist. The purpose of the research was to compare the challenges of marine aquaculture development in Algoa Bay with other countries e.g. Europe, Oceania and Asia, North and South America, and Africa. Peter is an advocate of marine spatial planning as the best management system for reducing potential conflicts of interest especially within the local maritime domain.

First the assessment report is excellent and the inclusion of risk assessment and cost benefit analysis is a step in the right direction. This will substantially reduce the risk of displacement i.e. where a marginally viable development displaces another development which is providing a good return on investment. The producer must identify the marketability of the product, after making a proper evaluation of existing demand and its stability, and of potential future markets. It would be useful to know how many cages are required within an ADZ for a viable finfish farm and bivalves farm (muscles and oysters). Potential indigenous finfish species to be considered include yellowtail, dusky kob, silver kob, yellowfin tuna, sole, geelbek, spotted grunter, white steenbras, white stumpnose, and red roman.

Aquaculture’s struggle for space

The need for coastal spatial planning and the potential benefits of allocated Aquaculture Development Zones (ADZs) are essential to avoid conflict and promote sustainability. Aquaculture is an increasingly important food-producing sector, providing protein for human consumption.

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However, marine aquaculture often struggles for space due to the crowded nature of human activities in many marine coastal areas, and because of limited attention from spatial planning managers. There is a need for integrated coastal spatial planning, emphasizing the establishment of suitable sites for the development of marine aquaculture, termed Aquaculture Development Zones (ADZs), in which aquaculture has secured use and priority over other activities, and where potential adverse environmental impacts and negative interactions with other users are minimized or avoided.

There is also a need to review existing examples of marine aquaculture spatial development worldwide and discuss the proper use of site selection in relation to different legal and regulatory requirements. National or regional authorities in charge of coastal zone management should carry out spatial planning defining optimal sites for aquaculture to promote development of sustainable marine aquaculture and avoid conflict with other users such as coastal and marine tourism, following a participatory approach and adhering to the principles of ecosystem-based management.

Algoa Bay faces huge challenges in the local maritime domain as potential conflicts of interest exist between users e.g. an increase in shipping and offshore bunkering, potential offshore drilling sites for oil and gas, fish farming sites in close proximity to popular recreational beaches, the negative impact of marine aquaculture on the lucrative coastal tourism industry.

Identifying optimal sites

The success of an aquaculture project depends to a large extent on the selection of an appropriate site to establish the farm; this entails an intricate multi-criteria decision- making process. For site selection, in addition to consideration of physical and environmental factors, other crucial aspects concerning the efficiency and economy of the aquaculture operations are central. The producer must identify the marketability of the product, after making a proper evaluation of existing demand and its stability, and of potential future markets.

Once a market has been identified, a suitable site for production must be found which is in accordance with the biology of the cultivated organism and the projected volume of production. Haphazard development of aquaculture without adequate planning and regulation can lead to adverse environmental impacts, lack of economic feasibility, and/or social conflicts. Negative environmental and social conflicts have emerged at broad scales previously where planning has been inadequate, such as seen in the early development of prawn farming in tropical regions.

Spatial planning of aquaculture activities should be a public process aimed at achieving ecological, economic, and social objectives that usually have been specified through a governance process, with a broad participatory approach. Essentially, spatial planning contributes to the process of selecting suitable areas and sites for aquaculture when it is integrated and forward-looking with respect to regulation, management and protection of the marine environment; the allocation of space should address the multiple, cumulative, and potentially conflicting uses of the sea.

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The shared use of public domain areas and the conservation policies adopted for coastal areas reduce the availability of sites. At the same time, however, the demand for aquaculture products is increasing, especially because this activity can supply a constant stream of quality products at stable prices. Preliminary site selection processes should define the geographical location and extent of aquaculture in a determined region. As part of this process, physical, ecological and socio-economic criteria should be taken into account. Next, a location that minimises conflict with the other users of coastal waters, such as shipping, fishing, recreational activities and the energy industry should be identified to site the farm.

In many coastal areas it will be difficult to find suitable sites for aquaculture which do not conflict with pre-existing uses that may well be considered more important socio- economically for the region. As this scenario of multiple pre-existing uses of coastal spatial resources is widespread, it is suggested that the ADZ concept should be considered to provide space for marine aquaculture, and avoid environmental degradation and negative interaction with other traditional users. An ADZ is defined as: ‘a marine area where the development of aquaculture has priority over other uses, and therefore will be primarily dedicated to aquaculture. Identification of an ADZ will result from zoning processes through participatory spatial planning, whereby administrative bodies legally establish that specific spatial areas within a region have priority for aquaculture development’.

The FAO defines an Ecosystem Approach to Aquaculture (EAA) as a strategy for the integration of the activity within the wider ecosystem context that promotes sustainable development, equity and resilience of interlinked socio-ecological systems. A key principle of this approach is that aquaculture development and management should take account of the full range of ecosystem functions and services, and should not threaten the sustained delivery of these to society.

Aquaculture should be developed in the context of ecosystem functions, which entails estimating assimilative and production carrying capacities, and adapting farming practices considering both ecological and social components. The EAA provides the strategy including steps, process and tools to facilitate the definition of ADZs. Another consideration is that aquaculture should help improve human well-being and equity for local communities. Following the IUCN (2009) and FAO recommendations selection of ADZs should be based on a participatory approach. It should promote social acceptability by applying the precautionary principle, and consider the potential of adaptive management.

Based on these principles, political decisions on the use of coastal space, following spatial planning, should favour aquaculture in coastal regions with reduced social confrontation. Therefore, ADZs should be identified in all coastal areas where a potential space for aquaculture exists, and be included in national and regional administrative structures alongside other sectors, serving as a tool for the integration of aquaculture into coastal zone management. It is clear, however, that the designation of an ADZ is not enough to guarantee sustainable aquaculture. Within an ADZ, the specific site selection and the production per site must match ecosystem carrying capacities and a permanent monitoring programme within the relevant water body (which could be an ADZ) is needed to assess the impacts of each farm.

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Other potential issues, such as diseases, can be spread in ADZs and therefore bio- security aspects must also be considered. Spatial planning for selection of ADZs is already widespread globally, although they exist under very diverse legislative and administrative arrangements and are referred to by an array of names.

Conclusions

Because management of marine aquaculture should be ecosystem-based, balancing ecological, economical, and social objectives for sustainable development, national or regional authorities in charge of coastal zone management must use spatial planning for identifying suitable ADZs, and implement them more widely.

Development of aquaculture spatial plans as a framework for the establishment of ADZs, will help avoid negative externalities, provide business opportunities, and decouple environmental degradation and aquaculture development. It is essential that, for ADZs to be effective, they should be accompanied by a clear national/sub-national (regional or other national administrative subdivision) regulatory framework and regulated under optimal governance, in which the different procedures for licensing and leasing aquaculture activities are clearly outlined.

Finally, site selection and definition of ADZs are only the first step towards sustainable aquaculture. To follow up, one or several ADZs should be defined within an AZA, each with a management plan in accordance with the EIA, ongoing monitoring, and provisions for adaptive management. There should be appropriate stakeholder participation, and information about the ADZ should be made available to the public.

In a future, with improved technology, aquaculture systems will move away from inshore to open waters. Offshore mariculture may be an option to avoid issues of competition for space, reducing environmental impact and negative public perceptions. In this emerging scenario, ADZs also need to be selected by spatial planning processes within the exclusive economic zones of each country; or even further, beyond the 200 nautical miles belt of national jurisdiction. Therefore new analytical frameworks will be necessary to define appropriate aquaculture site selection, closely linked to aquaculture technological developments. Selection of an ADZ should be an adaptive process, in order to respond to the potential beneficial and negative effects of climate change and weather uncertainty, some that must be taken into consideration for future marine spatial planning.

Prepared by: Peter Myles Prepared for: Anchor Research & Monitoring

21st April 2019

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N Dryden Port Elizabeth 24 April 2019 To whom it may concern

Herewith are my initial comments to the proposed fish farm in Algoa Bay after going through the document from your site.

Firstly, I would like to state that I am not opposed to aquaculture as such, my main concern it with regards to Algoa 1 coming up as a potential site again. So I am not saying the whole idea is bad, I am basically saying that I do not agree with Algoa 1 being used as a site for any type of aquaculture.

In this letter of comment I am taking 2 small paragraphs from the doc which I downloaded from the site: The proposed development is therefore in line with the projects and programmes identified in the IDP on condition that the mariculture industry develops organically without unfair and/or negative impacts on other priority projects/programmes

The individual benefits of a project overstate the true benefits if the project diminishes benefits elsewhere in the area. The economic desirability is therefore essential to determine whether the proposed development compliments economic planning as reflected in spatial development planning. It is not sufficient that the development results in some positive spin-offs if it is not compatible with planning guidance designed to maximise the overall economic potential of an area.

Just taking the above 2 statements into account, I cannot see how Algoa 1 can be put on the tables as a good option to use. It came up as extremely marginal economically in the initial proposal time a few years ago. There are some high quality reefs in very close proximity to the proposed area. There is a high risk of disease and parasite transmission to these wild areas from the fish farm. There is also a high risk of red tide in the area – has been coming in to PE for the last 5 years or so for some reason and this will kill off the fish and it turn cause chaos on the currently unspoilt reefs. Keeping this reef which is used extensively by dive charters and is well known internationally should be a priority by putting the fish farm elsewhere. What about the current chokka industry in the area? Many people rely on the chokka industry for their livelihood and there is a risk that the chokka industry could get affected by Algoa 1 being a site for aquaculture.

With regards to the 2nd paragraph, at the moment the beachfront of Port Elizabeth is a hive of tourist activity. 20 years ago it was not the same, but over the years it has developed into a sought after tourist destination. Tourism is ‘easy money’ brought into a city as once a city is on the ‘tourist map’ all one has to do is make sure it stays on the map to continue to bring in money. Some people at the meetings seem to think that only ‘white people’ in Summerstrand get the benefit of this, but this is really not true. Many tourists are from overseas and they support many of the more African type of souvenir shops and entrepreneurs all of whom rely on their sales for their livelihoods. Many people also work in the numerous hotels and guest houses on the beachfront. If occupancy goes down then the first people to lose their jobs are the ones that work in those types of establishments. Whether people agree with it or not, Ironman has been very instrumental in helping put PE on the tourist map so to speak. The race brings in a lot of money for the metro and it also raises funds for underprivileged kids in the community. Without the race (which will be the case if the fish farm goes ahead) tourism will get affected to a degree, but more than that, the kids that receive huge benefit from the race being held here will no longer receive that benefit. Ironman will just find new beneficiaries wherever they relocate to. Bell Bouy challenge has just been upgraded to an international race. This race will no longer be able to be swum if the fish farm is at Algoa 1. International surf championships take place at Pipe beach. These will be at risk. The blue flag status of our beaches should in fact get revoked. The ‘Wild Side’ of PE is known for its shark risk, but the bay is known to be safe – why experiment with this changing? PE has eventually been put on the map as the water sport capital of South Africa……why change this? Why do something negative to a current positive in order to create a 1000 jobs? So in order to secure 1000 jobs through aquaculture, I feel that a similar number of people will suffer from job losses from hospitality industry workers, to chokka fishermen, to the kids that currently get blessed each year. In other words I feel that the individual benefits that have been put down in the proposal will overstate the true benefits as I feel that it will diminish the current benefits in the area. It will certainly not maximise the overall economic potential of an area. E H Schumann : COMMENTS ON THE PRE-APPLICATION BASIC ASSESSMENT REPORT: APRIL, 2019 PROPOSED SEA-BASED AQUACULTURE DEVELOPMENT ZONE IN ALGOA BAY, EASTERN CAPE

1. OVERVIEW The pre-BAR makes a plea for the development of a mariculture zone in South African waters in terms of dwindling ocean resources, and the fact that such activities are proving successful in other world areas. It is argued that aquaculture could provide opportunities for the socio- economic development and beneficiation of poor communities and creating employment and human capital development. However, the South African coastline has very limited locations where aquaculture could be considered, and after assessing conditions the conclusion is made that the only possible location for such activity is Algoa Bay. Nonetheless a project such as this should only be considered if it can be shown to be economically viable while not damaging existing enterprises or adversely and permanently harming the environment. Groups which have expressed concern or opposition to a fish farm in Algoa Bay include the following: non-motorised water sports and recreation, yachting, scuba diving, recreational skiboat linefishing, commercial fishing including small pelagic, squid jig fishery, traditional line fishery and shark longline, shipping and industry, marine ecotourism, the Airports Company of SA, and environmental groupings. The pre-BAR makes the assertion that certain sectors within the local community oppose the proposal mostly due to potential conflict with existing industries and conservation initiatives. It is therefore to be expected that these entities will argue against the need for this activity. It is then a matter of getting a balance, considering which groups will benefit, and which groups will be adversely affected. Moreover, in doing such an assessment, numbers of people as well as economic impact must be considered. At the same time the skills levels for the jobs being created must be specified to ascertain which groups will actually benefit. The manner in which this is addressed in the pre-BAR and accompanying documents is highly problematic. Thus estimates of job creation in the first proposal were listed at 94,350, while this has now been decreased to 1,700 jobs for the entire ADZ at full production, a substantial reduction, even though it may still be too high. On the other hand, the potential loss of jobs in the tourism industry and the restriction or cancellation of open-water swimming and related events such as Iron Man, the Splash Festival, Ocean Series etc. has been minimized even though the numbers are likely to be substantially higher than any job-creation. However, quite apart from the above economic and social considerations, the pre-BAR falls short in presenting an adequate assessment of environmental conditions. In particular, in considering wave statistics for the various sites a totally inadequate wave record is used. More comprehensive wave records are available, and a report is given in §2.1 which indicates that the Algoa sites 1 and 7 can expect breaking waves of more than 6 m at times. This will mean that the whole structure

1 of the cages will need to be reconsidered and strengthened which may make the operation economically unfeasible. Then the assessment of suitable water quality at Algoa site 6 ignores available data on faecal coliform pollution. The measurements presented in §2.2 indicate that a bivalve farm will not be able to function satisfactorily at this proposed site. Finally, an aspect raised previously is ignored in this BAR, namely the effect of wind drift in transporting wastes and fish faeces onto prime Blue Flag beaches within an hour or two; the cumulative effect is also not considered. Quite clearly this will affect the manner in which tourists and holiday-makers will utilise these amenities. These three contentious issues are detailed below.

2. DETAILED CONCERNS 2.1 Waves Waves are one of the most important criteria for establishing where aquaculture zones can be safely established, and in fact the reason why Algoa Bay was selected is because of the protection that Cape Recife offers to dominant waves from the south-west. It is then strange that so little attention is paid in the report to establishing the wave statistics at the identified sites. The report does not give much detail about wave data collected, but §2.1.1.1 Oceanographic Data Collection states that the data presented here were collected over an 11 month period from Algoa 2, which lies approximately 4 km to the north (SOUTH?) of Algoa 7, and later monitoring equipment was deployed within precincts Algoa 1 and 5 in early 2013. No information appears to be available on the precise position, equipment used (ADCP?), water depth or analysis techniques. The report on waves comprises the following: Significant wave height, defined as the average of the highest 1/3 of waves for a given period (in this case 8 min per every hour), approximated 1 m for 60 % of the time monitored, and was less than 2 m for 95 % of the time (Figure 7). Significant wave heights of 3.5 m or higher were experienced 1 % of the time. This equates to approximately 3 days (72.6 hr). The maximum significant wave height recorded was 5 m with a wave period of 13 seconds. Wave period approximated one wave every 12 seconds 41 % of the time, and generally ranged from 9 to 15 seconds (90 % of the time). Two figures depicting these results are included. In the pre-application BAR one paragraph records that maximum wave heights of 6 m have been recorded along the surf zone of Algoa Bay by MacLachlan (1983), possibly from easterly swell, and Council for Scientific and Industrial Research (CSIR, 1987) buoy-data have recorded wave heights of between 0.5-5.0 m (87% of waves between 1-3 m) in summer and between 1.0-6.5 m in winter approaching the Bay at Cape Recife. In response to criticism about the lack of substantial wave data in the first report of 2014, the applicants stated: The wave climate is currently being monitored at both Algoa 1 and Algoa 5, but it must always be acknowledged that storm generated waves with a return period greater

2 than the monitoring period may not be recorded (i.e. the probability of recording a 1 in 5 or 10 or 50-year storm event is low during a 12-month monitoring study). Waves are actually an important component in the successful operation of fish farms, and indeed one of the main reasons why Algoa Bay was chosen as a potential site is because of the protection offered by Cape Recife to high waves originating in the Southern Ocean. Thus it is disappointing that more information on waves was not presented when there are internet sites where hindcast wave data is available (e.g. ftp://polar.ncep.noaa.gov/pub/history/waves/). The problem with the reported results is then that potential farmers may think significant wave heights of 3.5 m or higher will occur 1% of the time, with no indication of what a 1:50 or 1:100 year wave event could be. As an example of the waves that can be experienced along the Port Elizabeth beachfront (Algoa sites 1 and 6), a storm on 1 September, 2008, caused considerable damage to the foreshore. The hindcast wave data from the above ftp site records a significant wave height of over 9 m south-southeast of Cape Recife (34.5 °S, 26 °E), while the photographs in Figures 1 and 2 show some of the effects of these waves. The first two photographs were taken in North End and show large waves breaking right over the shore-protection dolosse and flooding the streets, while the third photo was taken of the Shark Rock pier later in the day when conditions had abated somewhat.

Figure 1. Waves at North End on 1 September, 2008

Figure 2. Shark Rock Pier on 1 September, 2008.

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Quite clearly it is important to convey this information to any potential farmers, as it is likely that waves were breaking at all the Algoa sites – 1, 6 and 7. Any cages will need to be designed to cope with breaking waves with a significant wave height of 6 m and more, since the last thing that is wanted is a break-up of the cages with the damaged parts washed up on tourist beaches. Consequently, a statement such as Significant wave heights of 3.5 m or higher were experienced 1 % of the time conveys entirely the wrong impression of the waves that can be experienced. In particular, the cages will need to be designed for the extreme cases, not an ‘average situation’. Another aspect which is not considered is the regular servicing of the fish cages. There must be a criterion for the maximum waves that can be handled adequately while the cages are being serviced, and as such it would have been expected that the wave records would have been used to determine the percentage of days available for servicing: this does not appear to have been considered at all in the pre-BAR

2.2 Pollution Status of Algoa 6 Site This site stretches along about 4.8 km of coastline immediately north of the Port Elizabeth harbour. It is a highly degraded area, and the pollution status is subject to the discharges from the Fishwater Flats Water Reclamation Works (FFWRW), where the industrial component discharges into the Papenkuils Canal and thence into the sea, while the domestic component is discharged through the New Brighton Pier pipeline. An investigation by Schumann and Campbell (1999) over a period of 2½ years found substantial variability in a range of water quality criteria, with adverse values being concentrated in specific areas associated with the discharges. The application details water quality data for the Algoa 6 site from samples collected in September, 2009 and October, 2018. Unfortunately, with the acknowledged variability of the area, the positions of the actual sample sites could not be ascertained in the report. Nonetheless, it is apparent that it consisted of very limited sampling, and the results are presented in Table 1 of §2.1.2.1 of the Benthic Mapping report.. – copied below.

Table 1. Water quality data for Algoa 6. P = phosphorus; NH4-N = Ammonium/ammonia - Nitrogen; NO3-N = Nitrate total nitrogen; PO4 = Phosphate; DO = Dissolved oxygen.

Origin Sample date P (mg/l) NH4-N (mg/l) NO3-N (mg/l) PO4 (mg/l) DO (mg/l) Algoa 6 Sept '09 - 0.21 <0.10 0.15 7.06 Algoa 6 Oct '18 0.12 0.63 <0.36 0.37 -

While these values are acceptable, there is no mention made of the unacceptable levels around the discharges reported by Schumann and Campbell (1999), even though this report is listed as a reference. Furthermore, there are no measurements of faecal coliforms reported in the pre-BAR. The Water Quality Guidelines for South African Coastal Waters specify that, for Mariculture the maximum acceptable faecal coliform/E. coli count per 100 ml is: 20 in 80% of the samples and 60 in 95% of the samples.

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Such measurements were made regularly for the Schumann and Campbell (1999) report at a series of fixed boat stations, as well as at specific sites along the coast. The results are depicted in Figure 3.

Figure 3a. Bar graph of average faecal coliforms per 100 ml at the boat stations – P is at the Papenkuils Mouth and C at the New Brighton pipeline. The arrow indicates that the given value is much greater than that given on the axis.

Figure 3b. Bar graph of average faecal coliforms per 100 ml from the NMBM coastal sampling sites. The arrows indicate that the given value is much greater than that given on the axis.

Faecal coliform numbers are rapidly depleted in salt water, and the figures show that the region is very patchy. However, the coastal values (averages of over 80 readings) are exceptionally high – 292,776 at the Papenkuils Mouth with the C1 boat site at 10,234 – and these will vary over the whole area depending on conditions.

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It is then clear that the levels of faecal coliforms in sections of the proposed Algoa 6 site are totally unacceptable for mariculture. The site cannot be considered as a homogeneous unit, and any consideration for a bivalve farm will need much more comprehensive measurements. At this stage it is not clear whether the NMBM is continuing with its function of measuring water quality along the coast, and whether more recent results are available. However, there appears to be no reason to expect conditions to have improved. The section 8.5.2.5 Marine aquaculture (sea-based and land-based) of the pre-BAR lists the following as one of mariculture activities at the Port Elizabeth harbour: • A small oyster breeding station about 2 km from the harbour in the direction of Coega, maintained by Nelson Mandela Metropolitan University (sic) (NMU) for research purposes. It is not clear where this information was obtained, but the Knysna Oyster Company has had an operation cultivating oysters at a site just north of the Port Elizabeth Harbour for a number of years. Their operations have been seriously affected on a number of occasions when high levels of E. coli caused oyster mortalities and closure of the farm for a period by DAFF, Associated illnesses in customers has led to banning of their product from certain markets (John Rice, pers. comm.). This position is right in the south of Algoa 6, and thus not directly impacted by the high levels of E. coli found in the middle reaches. Such pollution would have been transported south by wind, and is indicative of the unacceptable levels farther north in Algoa 6..

2.3 Wind Drift and the Impact on Beaches I lodged an appeal to the Algoa Bay Sea Based Aquaculture Development Zone Basic Assessment Process in 2014 – Appeal No 17. The grounds for my appeal was that the assessment did not consider all the factors involved in transporting material in the upper layers of the ocean, in particular that due to wind drift. It is apparent from the Applicant’s response to my appeal that they did not understand the situation, and as such I have detailed the processes involved below, as well as the consequent impact on Algoa Bay beaches.

2.3.1 Wind Drift It is notoriously difficult to measure transport in the upper layers of the ocean, in particular because both wind and waves are involved, and wind is actually also the generator of waves. Figure 4 details the results of recent measurements in the upper 10m, where wind drift was measured to within a few cm of the surface. It has been generally accepted that drift due to wind and waves in the near-surface (upper 5m and deeper) varies from about 1% to 3% of the wind speed, e.g. Wu (1983) determined a value of 3.1%. However, these results show that such near-surface wind drift can be expected to be considerably more, and at less than a metre depth the wind drift percentage can be expected to be between 5% and 13%. This means that a 20 km/h wind can transport material in the upper metre more than 2 km in the period of an hour.

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Figure 4. Wind and wave drift profile in the upper 10 m with a wind speed of 4.3 m/s and waves with a wave period of 1.9 s and significant wave height of 0.86 m (from Schumann et al., 2019, adapted from Laxague et al., 2017). Note the logarithmic depth scale.

The Acoustic Doppler Current Profilers (ADCPs) used in the assessment to provide current measurements in selected areas cannot measure currents near the surface of the ocean, generally not within 4 or 5 m, but dependant on conditions. Limited details of current measurements are given in the assessment, e.g. in the Dispersion Modelling section, §2.3.2 Ambient Currents, it is stated that: These data included measurements for up to 10 depth bins within the water column, as well as measurements for a near-surface (0-6m) dynamic cell, that moved with the tide, and enabled quantification of typical current velocities and directions under the prevailing wind conditions and served as input data into the model. With no further explanation found, and with the acknowledged shortcomings of the ADCPs, it is unclear how this near-surface ‘dynamic cell’ was measured, and in fact how near to the surface the measurements actually occurred. Note that in response to my original 2014 appeal Anchor Environmental included the following: We are aware that the “surface “ current data from ADCPs are actually 5-10m subsurface, and the figure does show the (8m) in the legend and the diagram, we will reword to “near surface”. However, in this latest assessment there is still a continual reference to ‘surface currents’, but under the circumstances it can be assumed that such currents were actually around 5m from the surface. Without more information it is not clear what the dynamic cell results actually mean and whether these included wind drift currents. Nonetheless, it is of interest that §2.1.2.3 Algoa 1, in the Benthic Mapping section, the following statement is made: Currents were, however, recorded as flowing in all directions at times, and relatively strong flows (>15 cm.s-1) were recorded occasionally flowing towards the North and North West (i.e. into the Bay and towards bathing beaches) at mid- water and surface depths (12.9 – 2.9 m). Moreover, in the Dispersion Modelling section, Table 2.3, the Average current speed surface is given as 53.73 cm/s. No direction is given,

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but on the basis of the above quote it can be assumed that this was also towards the beaches.

2.3.2 Impact on Beaches I had anticipated that the appellant would consider wind drift in any new assessment, but this has not happened. It is therefore necessary to repeat what is known about winds in Algoa Bay, namely wind measurements at the Port Elizabeth airport show that the major axes of wind direction have been determined to lie at about 55°/235° (Schumann and Martin, 1991). The north-easterly winds are most common in the summer period from about November to February, and blow almost directly onto the Pollok-Hobie Beach areas. Autospectra showed an approximate 6-day period peak. A periodicity of 4 to 6 days was confirmed by Schumann (1999), with wind speeds typically in the range of 10 to 25 km/h. There is limited information in the assessment on loading of the water column, however, §2.2.2 of the Dispersion Modelling Report states that: One of the primary impacts of mariculture cage farming is that untreated wastes resulting mainly from uneaten food and faeces from fish in sea cages are discharged directly into the sea, and represent a potentially significant source of nutrients. Studies have documented elevated dissolved nutrients and particular components (POC and PON) both below, and in plumes downstream, of fish cages. These wastes can impact both on the benthic environment and on the water column. It can therefore be expected that, for fish farming, the water column will be contaminated with untreated wastes and faeces. Table 2.7 gives the sinking speed of faeces from yellowtail as 0.7 cm/s, however, the turbulent conditions at sea will keep such faeces in suspension in the water column, so that it can be expected that such faeces will remain in the upper 5 m of the water column for much longer than the sinking speed suggests. Moreover, in the Dispersion Modelling section (§2.3.6, page 17) it is stated that it must be noted that these buoyant wastes are likely to comprise of oils or fats and that these typically pose little danger to human health, therefore acknowledging that these are actually buoyant. Furthermore, clarification is required on what is meant by the statement that the wastes are likely to comprise of oils or fats and that these typically pose little danger to human health. In particular, once the fish farms are established there will be a continual movement of such wastes and faeces onto the beach area, and the cumulative effects must be assessed. Note that a specious argument was made by the appellant to my original appeal by implying that such wastes cannot reach the beaches because onshore current speeds at the shore must be zero. Such boundary conditions are used in modelling, but in practice at a beach conditions are much more complex with waves, undertows, wave setups, rips etc. People who have actually been to a beach will confirm that various items such as seaweed, bluebottles, shells, plastics etc. are regularly deposited on beaches. However, it is not only the beaches which are of concern, since people swimming in the surf zone and deeper will be affected by fish farm wastes before it reaches the shore.

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2.3.3 Algoa 1 and Algoa 7 Figure 5 shows the prevailing north-easterly wind as well as the aquaculture sites 1 and 7 and the relevant beaches.

Figure 5. Winds, aquaculture sites and beaches

From the referenced wind directions, the prevalent north-easterly winds blow almost directly onto the Hobie-Pollok beaches, and typical wind strengths are in the range of 10 to 25 km/h. As already calculated for a 5% wind drift, a 20 km/h wind will bring fish farm wastes in the upper metre of the water column onto the beaches within 2 hours of onset, while anything in the upper 10 cm could reach the beaches within an hour (Figure 4). Stronger winds will obviously further reduce this time, while the impact on swimmers and surfers will be even sooner. It is therefore clear that for Algoa 1, under moderate winds of 20 km/h wastes and faeces from the aquaculture site will be transported from the fish farm site to the beaches within one or two hours. While it must still be ascertained what the long-term effects of these wastes will be, it is also a concern whether swimmers and surfers would knowingly want to swim in water containing recent wastes and faeces (an hour or two old). It should be noted further that the north-easterly winds are most common in the summer, when the beaches are most heavily used. Moreover, events such as the popular Ocean Series and Iron Man Africa also occur during this period. Note that the given average surface (0 to 6m depth) current speed in Table 2.3, namely 0.53.73 cm/s, will transport material about 1.9 km in one hour. Although direction is not specifically given, from the previous discussion it can be assumed that this was primarily towards the beaches. These results therefore confirm that the movement of fish farm wastes will be onto the beaches. The Algoa 7 site lies some 3 to 7 km east and north-east of the beaches at St George’s Strand, Wells Estate and Bluewater Bay. As such it can be expected that these beaches will

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also be impacted by any waste discharged from a fish farm at Algoa 7, with an onshore wind of 20 km/h bringing the discharges ashore between 3 and 7 hours after the onset of the wind.

2.3.5 Conclusion It is clear from an assessment of wind and wave drift in the upper metre or two of the water column that untreated wastes resulting mainly from uneaten food and faeces from fish in sea cages will impact regularly on beaches in the proximity of Algoa 1 and Algoa 7. These beaches, in particular the Kings, Humewood, Hobie and Pollok beaches, are prime holiday destinations and include a number of Blue Flag Beaches. Perceptions are very important, and it is very likely that the fish farms will impact heavily on any tourists/holiday-makers/beach users. Firstly, the visual aspect will be there the whole time, reminding people that the farms are there. Then, the knowledge that any recreational activity – in particular swimming in the surf zone and farther offshore – will be directly in water full of oils and faeces will likely be very off-putting.

REFERENCES Laxague N J M, Özgökmen T M, Haus B K, Novelli G, Shcherbina A, Sutherland P, et al. (2017). Observations of near-surface current shear help describe oceanic oil and plastic transport. Geophysical Research Letters, 44,1-5.

Schumann, E H (1999). Wind-driven mixed layer and coastal upwelling processes off the south coast of South Africa. Journal of Marine Research, 57, 671-691.

Schumann, E H and J A Martin (1991). Climatological aspects of the coastal wind field at Cape Town, Port Elizabeth and Durban. South African Geographical Journal, 73, 48-51.

Schumann, E H and E E Campbell (1999). Pollution status and assimilative capacity of the western sector of Algoa Bay. Confidential Report C55 prepared for the Port Elizabeth Municipality.

Schumann E H, C F MacKay and N A Strydom (2019). Nurdle drifters around South Africa as indicators of ocean structures and dispersion. South African Journal of Science (in press).

Wu J. (1983). Sea-surface drift currents induced by wind and waves. Journal of Physical Oceanography; 13, 1441-1451.

Dr E H Schumann 26 Marine Gardens, Glengarry Crescent, Humewood, Port Elizabeth. Tel: 041 5860632; Mobile: 083 2992092 2019-04-26

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26 April 2019 Dear Anchor Environmental Consultants

Public Comments: Basic Assessment Report (BAR) for Algoa Bay Sea-Based Aquaculture Development Zone (ADZ)

On behalf of the Marine Spatial Planning (MSP) research group of the MSP SARChl Chair at Nelson Mandela University, I would like to submit our comments on the BAR for the Algoa Bay Sea-Based Aquaculture Development Zone.

The report offers a substantial overview of the activities in Algoa Bay as well as the biophysical environment. It mentions the risks to other marine users in the Bay, however the new zoning areas fail to address spatial and dynamic conflicts of congruent marine users. The report also fails to mention the MSP Bill under relevant legislation. Although the MSP Bill is not yet an Act, the MSP framework has been published and provides a substantial description of the MSP process that is to be followed in South African marine waters once the MSP Bill has been passed.

It is thus recommended that decisions regarding development in the marine domain are to be made with co-operative governance processes in mind, guided by abiding to MSP legislation. This means that all marine activities in the Bay, including land-based activities, must be located and conducted in a manner that will not impact on other government departments’ mandates.

We are aware that certain ADZs were screened out during the planning process (e.g. zones 2,3,4, and 5) in order to address the conflicts with shipping, environmental conditions and the marine protected area. However, the current zones, particularly Algoa 1, pose significant spatial and dynamic conflicts to congruent marine users as well as to residential users in the area. Several public meetings on this process have demonstrated that there are strong objections against the placement of ADZ Algoa 1 based on scientific research and public concerns.

According to the environmental application process, Algoa 1 was previously granted environmental authorisation but was suspended owing to 28 appeals. Further studies were conducted to evaluate feasibility of the placement, showing Algoa 1 to be economically incompatible and not economically competitive with the current marine users of the area (e.g. tourism and recreation). The proximity of Algoa 1 to areas used for recreational activities, such as recreational beaches with blue flag status, surfing, sailing and other sporting events (Iron Man) will affect the water quality, which would ultimately have a negative impact on the Bay’s tourism. In addition, the current placement of Algoa 1 positions it downstream from the Cape Recife waste water treatment plant and in the position of the incoming south-west swell, which thus poses a risk to the quality of finfish and bivalve produce. The marine environment is dynamic, therefore static spatial boundaries will not prevent overlap of these marine activities.

The placement of Algoa 6 appears to be feasible and is of less concern to the majority of stakeholders. Lastly, Algoa 7, although it is situated at the edge of the Addo Marine Protected Area and within the restricted use zone, this requires routine monitoring to ensure a healthy MPA and surrounding ecosystems, in addition to mitigation measures in case of an accident.

We recommend that you consider these spatial and dynamic conflicts and that they are communicated clearly to the applicant.

We thank you for the opportunity to submit these comments Your sincerely,

Estee Vermeulen MSP Research Group Nelson Mandela University [email protected] cc Prof. AT Lombard (SARChI MSP Chair)

WESSA - Algoa Bay Branch 28 April 2019

Without prejudice Comments on the proposed Algoa Bay Aquaculture Development Zone as contained in the DAFF’s new Basic Assessment (BAR) process.

1. Introduction:

We are unequivocally opposed to the proposed Algoa Bay Aquaculture Development Zone (ADZ), commonly referred to as the “Fish Farm”, as contained in the Department of Agriculture, Forestry and Fisheries’ (DAFF) new Basic Assessment (BAR) process.

Simply, we believe the March 2019 pre-application Basic Assessment Report (pre-BAR) gets the assessment wrong and that the overall impact on the economy, social and natural environment of Algoa Bay and Nelson Mandela Bay Metro will be significantly negative. We explain our reasoning in the comments under point 3 below.

Having attended the public pre-BAR meeting on the 06 March 2019, having gone through the detail of the over 600 pages of the pre-BAR documents sent to I&AP’s on the 28 March 2019, and having insight from a public meeting of our own, WESSA Algoa Bay Branch (ABB) believes that the BAR doesn’t do the full work required of an environmental impact assessment and in key instances contradicts its own specialist’s findings. Its conclusion that a mitigated aquaculture development of this nature will be beneficial to both the Bay’s eco- system and the human use of the Bay’s resources is therefore both procedurally and substantively flawed.

Further, it is our considered opinion, based on scientific and user input, that an ADZ of the nature proposed by DAFF will have a “tipping point” impact on the nature of the Bay’s ecology and human use of both the Bay’s northern and southern beachfronts and the sea space of the Bay itself.

As a consequence, the proposed ADZ will have a severely negative impact on the economy of Nelson Mandela Bay metropole. We have no doubt that the City’s current initiatives to positively shape the brand of the city as a water-sport/active capital and ecotourism destination will be adversely impacted.

2. Overview:

In short, the new DAFF proposal as contained in the BAR, and as prepared by environmental consultants: Anchor Research & Monitoring Pty Ltd, proposes to establish an ADZ in Algoa Bay comprised of three sites: • Algoa 1, a finfish/bivalve site of 522 ha, approximately 2 km offshore of the Kings Beach to Summerstrand beachfront and in close proximity to the Bell Buoy shipping marker. • Algoa 6, a 470 ha bivalve site that extends the current oyster farm north of PE harbour and is directly opposite the Papenkuil’s River outflow. • Algoa 7, a new finfish 355 ha site, approximately 3 km offshore and situated between the Ngqura harbour wall and St Croix Island.

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The original ADZ proposal initiated in 2011 that was subsequently suspended by the Department of Environmental Affairs (DEA) Minister, Mrs BEE Molewa (now deceased) in August 2015 had originally envisaged two sites, Algoa 1 and Algoa 5 (opposite the mouth of the Sundays River). The new DAFF application replaces that original process and has dropped Algoa 5 from consideration.

The pre-BAR proposal envisages a pilot phase of a 1 000 tons annual production (in total across all three sites) in Year 1 that will be scaled up if deemed viable in Year 4, as follows:

o Algoa 1 site : Total of . Yellow tail: 3252 t = estimated 38 cages OR . Kob: 4911 t = estimated 82 cages o Algoa 7 site: Total of . Yellow tail: 3555 t = estimated 42 cages OR . Kob: 4947 t = estimated 82 cages

(Note: These projections are not how we read the current report itself, especially with reference to the carrying capacity table as reflected in the EMPr, but these numbers have subsequently been clarified in direct correspondence with the Environmental Assessment Practitioner - EAP)

The EAP has clarified that the BAR process going forward is as follows:

• Conclude first round of public participation by end of April 2019 (comments from I&AP’s on the pre-BAR) • May 2019 : Compile Draft BAR considering the comments submitted • 30 May 2019: submission of application for Environmental Authorisation and Draft BAR • June/July 2019: second round of public participation, including the second public meeting • August 2019: Compile Final BAR considering the comments submitted • 31 August 2019: submission of Final BAR • EA decision expected by the end of 2019 • Appeal period January/February 2020

As per DAFF, an ADZ is intended to “boost investor confidence by providing ‘investment ready’ platforms with strategic environmental approvals and management policies already in place, allowing commercial aquaculture operations to be set up without the need for lengthy, complex and expensive approval process” (Pre-BAR pg. 1). The proposed ADZ is seen as a potential contributor to the national Operation Phakisa initiative that seeks to utilize the full potential of South Africa’s ocean resources and provide economic benefits to the local community through job creation and regional economic diversification.

A development of this nature is subject to a number of laws and regulations, the guiding act being the National Environmental Management Act 107 of 1998 (NEMA). NEMA’s foundational principle is the notion of “sustainable development” and specifically requires that any new development must demonstrate its sustainability in the areas of the social,

2 economic and natural environment. It also requires that decisions be taken in a “risk averse and cautious approach”. Simply put, if you are uncertain that the impact of a development will be sustainable, you shouldn’t proceed.

It is therefore the work of an environmental impact assessment to fully investigate what is known, to research further where aspects are unknown, and then on the basis of a balance of probabilities make a call as to whether the sustained benefits of the proposed development outweigh its risks.

WESSA ABB strongly supports a responsible and informed approach to the utilization of our ocean’s resources for the public benefit. It is our view that humans are now in the position to be stewards of the natural environment and we need to take that responsibility seriously. We are not opposed to aquaculture, in any of its forms, be it land-based, estuary, off-shore and deep-sea, but we are clear that the law and processes exist for a purpose and need to be followed, and that we have an incredibly rich natural asset in Algoa Bay that must be managed sustainably.

3. Our comments on the proposed ADZ:

It is our view that the pre-BAR, in its current format, fails to adequately evaluate the full impact of the proposed ADZ and therefore gets it wrong for the following reasons:

1. Algoa 1 isn’t feasible as per the pre-BAR’s own specialists: The economic feasibility study (Britz and Sauer 2016) that informs the pre-BAR finds that the conditions at Algoa 1 are marginal for economic aquaculture and limited mitigation possible. The BAR’s visual impact assessment excludes a major portion of the northern section of Algoa 1, and its socio-economic study finds that the southern portion of Algoa 1 overlaps with a squid nursery area and excludes that portion. The BAR refers to this as an “apparent conflict” and proposes a phased approach (a 1000-ton start-up) with careful monitoring to mitigate. There is a much simpler conclusion to be drawn, namely that the three reports indicate that Algoa 1 is not feasible in its entirety.

2. Algoa 7 hasn’t been evaluated in full: The newly added site, just off Ngqura harbour, has not gone through the same detailed assessment process as the other sites. The pre-BAR uses Algoa 2 and Algoa 5 assessment data as a proxy on issues of oceanography and economic prospects and concludes the site’s positive viability off that basis. Using proxy data is problematic in itself, but importantly the BAR does not assess the impact on nearby communities, nor is it informed by local communities’ input. Algoa 7 is in close proximity to the beaches of Bluewater Bay and St Georges Strand and those communities must (as has happened with Algoa 1) be informed of potential impacts and be heard in the process. This has not happened.

3. High levels of E.coli at Algoa 6 render it unviable: The extension of the current oyster farm, known as Algoa 6, is dedicated to bivalves only. What the BAR fails to evaluate is the impact of specific pollutants in that area on the economic prospects of any operation. Located opposite the mouth of the Papenkuils River, that section of coast is subject to high levels of industrial and human waste pollution (see as reference the work of Drs. E Schumann and E Campbell). In particular, available

3 results show that E. coli levels do not comply with the water quality guidelines for mariculture. The high levels of E.coli (and increasingly micro-plastics) in the water have required the current operation just north of the Port Elizabeth Harbour to close for extended periods and some of its product banned in overseas markets. This site is actually south of the worst pollution and any extension northwards into Algoa 6 will likely encounter higher levels of E. coli pollution.

4. Significantly increased Shark threat (real and perceived) to humans: I&AP’s have consistently raised the issue of the fish farm’s impact on shark behaviour and its subsequent (shark attack) risk to water sport participants and bathers. DAFF has consistently responded that all sea users along the South African coast are at risk of being bitten by sharks. The pre-BAR concludes that “it is probable that marine predators, such as sharks, will be attracted to finfish cages that may be appear to be a source of food” (p.124) and “should the fish cages increase residency times of large sharks in the broader region, the occurrence of sharks may well increase at the bathing beaches” (p.71). The pre-BAR argues that the “only conceivable way” to address the “high degree of uncertainty as to the possible changes in the risk of shark bite incidents” is through extensive monitoring of shark movement patterns at both ADZ precincts before and after the stocking of cages (pre-BAR p.71). There are two concerns with this approach: a. The first being that there is not an equal risk of shark attack along the South African coast. Algoa Bay has had very few shark attacks in its recorded history: localized risk is the issue, not the general risk. IronMan would not contemplate an open-water swim event around Bird Island, yet 60km away, off Hobie Beach, it does do so. b. The second is that the pre-BAR appears to base its assessment on the proximity of bathing beaches, not on the range of open water swimming & snorkeling/spearfishing. The recently held Bell Buoy 5km open water swim is from Pollock Beach to around the Bell Buoy (a distance of 2,5 km) and back. The Ocean Series, 3-Beaches, IronMan, Surf-Lifesaving events all extend 1-2 km out to sea. Aside from specific events, open water swimmers frequent the immediate offshore areas from Pollock through to Kings Beach on a daily basis. Bathing beaches should not be the reference point.

Our view is simple, it is known that finfish farming attracts sharks from studies done elsewhere in the world (see Papastamatiou, Y. et al 2011 Site fidelity and movement of sharks associated with ocean-farming cages in Hawaii) , and thus the only and obvious way to avoid risk to open-water swimmers, surfers, snorkelers/people spearfishing, life-saving participants and bathers is not to install the cages in the first place. After the fact intervention is not a risk-adverse approach - waiting to see if a shark attack occurs is not what we envisage NEMA intends.

The further risk however is the impact on public perception. Fear of sharks and fear of drowning are in our view the primary inhibitors of surf and open sea use. By installing fish cages, irrespective if it is the Year 1’s 12 cages or the intended Year 4’s 105 cages, the introduction of cages will significantly amplify the fear of encountering a shark in the surf and open sea areas in near proximity to the cages. The negative public response to licensing of shark cage diving 60km away at Bird

4 Island illustrates the point. This perception alone we believe will negatively impact and threaten the viability of the IronMan competition, the Ocean Series open water swim events, the Bell Buoy open water race, surfing competitions and the national and local competitions associated with Surf Lifesaving. Were the city to lose those events, the impact on its water-sport capital/active city brand will be irreparable.

5. Revised job creation numbers are overly positive: The original Bloom (2013) socio- economic assessment estimated the number of jobs that would be created at Algoa 1 (section 1) would be 7 650 (1 683 direct) jobs and 22 950 for Algoa 1 (section 2). For Algoa 5 the estimate was 63 750, of which 14 025 would be direct (as cited by Britz et al, 2016, SOE Report under 2.3.1). The new Socio-economic Report (Britz et al, 2016, p. 9) states that “the job creation numbers… are based on an unnamed source and greatly exceed the benchmark figures provided… for cage aquaculture. They are speculative.” And that “the present review (Section 2.3 above) of the Final EIR Socio-economic report (Bloom, 2013) revealed that the projected number of jobs projected was speculative and unrealistically high.” The 2016 SOE Report estimates that “direct employment in the production component of an offshore farm in Algoa Bay is expected to roughly 50 employees for a 1000t/annum pilot scale operation (1 employee per 20 ton) and 80 employees for a 3000t/annum commercial unit (1 employee per 37.5 tons)” and “a figure of one direct on farm employee to one service sector employee has been suggested as an approximation of indirect jobs… thus 100 total jobs for a 1000t production unit and 160 for a 3000t unit are projected” (Britz et al SOE Report, 2016, p. 53). Using the pre-BAR and SOE’s estimates, and assuming the maximum volume as per the EAP, the job creation potential ranges from 420 - 525 jobs for Algoa 1 & 7, and 740 jobs for Algoa 6 (as per the pre-BAR, pg. 120), thus an (estimated) total of 1 160 – 1 265 jobs for the entire ADZ at full production. This is a substantial difference to the initially estimated 94 350 jobs of the first proposal. There are two key concerns with this revision: a. The revised estimate in turn is questionable. The pre-BAR does not go into detail as to how a pilot 12-cage operation (1 000 tons) would create 50 direct jobs and 50 indirect jobs, and what the nature/level of those jobs would be. Are those full-time jobs, seasonal jobs, minimum-wage jobs, etc.? b. The key piece of information that is missing is the potential loss of jobs. If we are correct that fish cages will negatively impact tourism and open-water swimming (and related events), and those events are lost to the city, what would the job loss be as a consequence? The pre-BAR (yet again) fails to assess this impact (see point 6 below), without which it is impossible to assess whether an ADZ would have a negative or positive overall impact on job creation.

6. The negative (socio-economic) impact on human use of ocean resources and subsequent impact on local business remains an open question: As a condition of the suspension of the appeal in 2015, the Minister was clear that DAFF (the applicant) had undertaken to do a “detailed analysis of the projected revenue and employment opportunities likely to be created by the proposed project, measured against the perceived loss in revenue and employment opportunities as a result of the proposed project at Algoa 1” (see 4.2.2. Appeal decision LSA 138222 pg. 4). That analysis has not taken place. While the “likely jobs created” assessment has been

5 reviewed, and significantly revised downwards from 94 350 jobs to 1 265, the “likely jobs lost” assessment has been replaced with a “social trade-off analysis”. The pre- BAR (pg. 122) gives the following reason for the change in methodology: “The Bloom (2013) assessment and the objections submitted by stakeholders to the proposed ADZ approval in Algoa Bay identified many possible external costs that should have been incorporated with the feasibility analysis conducted by Britz et al. 2016. However, within the timeframe and budget provided for the previous EIA (Bloom 2012, 2013), comparative feasibility study (Britz et al. 2016) and current BA process, such costing is not feasible, and given the speculative estimates of the revenue production costs, precision in the calculation of external costs is not warranted. The impact assessment was therefore completed based on qualitative data, i.e. the perceptions expressed during the previous EIA process and the results of the social choice modelling experiment conducted by Britz et al. (2016) (Table 21). The rating confidence is therefore medium“.

The social trade-off analysis in turn surveyed 154 persons along the Summerstrand beachfront over the period of a week in June 2016. The survey itself finds that, “About 40% would vote against introducing fish farming in Algoa Bay, while about 50% would vote in favour of introducing it. The main reason for a majority voting for it is the prospect of additional income and job creation” (pre-BAR SE report, pg. 26). Note the importance of “additional” as a qualifier in the context of the responses – who would be opposed to a development that has a net benefit? As a consequence, the feasibility study comments that, “The Final EIR, review 28 appeals, and public perception survey (Hosking, 2016) confirmed that the socio-economic cost to the tourism and recreation sectors of developing the Algoa 1 ADZ was a real, but unquantified concern.” (pre-BAR Feasibility Study, Britz & Sauer, 2016 pg. 15) and subsequently concludes that “Aquaculture is socio-economically ‘moderately feasible’ at both Algoa 1 and Algoa 5 ADZs for most indicators, however the ‘very low’ feasibility ranking in respect of the negative impact on the recreation and tourism economy mitigates against recommending the Algoa 1 ADZ.” (pg. 17). Despite this “low feasibility” DAFF has remained resolute in putting forward Algoa 1 as an aquaculture site. Our concerns with the above are as follows: a. It is our understanding that user-groups or commercial entities whose activities rely on open-water swimming and (scuba diving) access to the Bell Buoy “house” reef system have not been approached by the consultants as to the likely impact of a fish farm at Algoa 1. Nor have those (as far as we are aware) in the down-stream industries (such as B&B/hotel accommodation, event organisers, transport/tour operators, equipment manufacturers, etc.) been consulted. The study itself appears to place the onus of quantifying the negative impact on the 28 appellants and appears to weigh a survey of 154 persons as a greater indicator of public perception than the appeals and 17 000-person petition. We have no doubt that if open-water swimming and the house reef are lost to public use, the loss to the city (and its “water- sports/active” brand) will be substantially greater than the 1 265 jobs gained. b. The “medium” rating makes no sense when there is no comparative basis on which to make the assessment. The pre-BAR assumes a 1 000t, 12 cage operation will sufficiently mitigate. Off what basis? Was the perception of 12

6 cages vs 82 cages in the water tested with I&AP’s? We are of the view that the scale will not make a difference to perceptions of users, users will respond to the visible presence of cages and act on the associated risk. c. That the DAFF/EAP were able to dedicate sufficient budget to comply with all the other appeal requirements yet were unable to comply with their own undertaking supposedly because of budget constraints (but could afford a trade-off analysis) is deficient in the extreme. It is a core concern of the I&AP’s. It is a principal requirement of NEMA (as we understand it) to assess the positive and negative impacts of a development in all three spheres: societal, environmental and economic. To not consider the negative potential impact of such an ADZ defeats the purpose of NEMA and good governance. It also calls into question any budgetary commitments that may be required to facilitate the EMPr, as to whether DAFF will simply claim budget constraints to avoid doing the necessary measurements and follow-on post an EA. d. It is a specious argument to reason that due to the “the speculative estimates of the revenue production costs, precision in the calculation of external costs is not warranted”. It both conflates revenue generation and job creation and stands in sharp contrast to the lengths to which the pre-BAR has gone to assess (and review downwards) the job-creation aspect.

7. Change to the Bay’s reef eco-systems: We remain deeply concerned that the impact of fish fecal matter, antibiotics to treat caged fish, the transfer of diseases (and sea lice?) to wild stock and the chemicals used in anti-fouling will fundamentally alter if not destroy our local reefs. We have two specific concerns: a. Again, in our view the start-small-then-see approach adopted by the pre-BAR is not a risk-adverse approach. The cumulative impact of 12 cages as compared to 82 cages would in our view be significantly different. If we take the case of sharks as an example: while only specific sharks pose a threat to humans, Great Whites and Tiger sharks being the main threat along our coastline, sharks like the Ragged Tooth Sharks (Raggies) are not generally considered as a threat to humans. But Great Whites are a threat to Raggies. The extensive reef systems marked by the Bell Buoy and the reefs off St Croix (adjacent to Algoa 1 and Algoa 7 respectively) are well-known refuges of Raggies. Recently in False Bay the arrival of an Orca pod resulted in Great Whites moving out of the area (and negatively impacted shark cage diving). Currently adult Great Whites frequent Bird Island due to the resident seal population and not the areas now frequented by Raggies. The attraction of Great Whites to finfish cages as a new resident food source will undoubtedly impact the local Raggie behaviour. This impact (of changes in apex predator patterns) has not been assessed by the pre-BAR. b. It needs to be emphasized that Algoa Bay contains some of the world’s most diverse and colourful cold-water reef systems. To jeopardise local wild fish stocks and reef systems on the speculative possibility of an ADZ, is not a risk- adverse approach. In the case of the Bell Buoy reef system this is the “house” reef for scuba-diving tours and training due to its close proximity to the launch sites.

7 8. No consideration given to sand movement: At the pre-BAR public meeting of 06 March 2019, WESSA raised the issue of Algoa Bay sand movement in two respects, the first being the fish cages impact on sand movement and second being that sand movement patterns negate the pre-BAR/DAFF’s assertion that material from cages will settle within 200m of the cages. While there is a localized feature of sand movement where easterly winds and waves move sand offshore, and long-period westerly swell move it onshore, there is also general sand movement pattern that starts from Cape Recife and moves along the Bay’s beaches through to the Alexandria Dunefields and beyond (see the April 2012, Draft Report: Establishment of Coastal Set-back lines for NMBM, prepared by Masande Consultants and Afri- Coast Engineers Pty Ltd). The accretion of sand to form Kings Beach post the building of the PE harbour wall, and the sand accumulated at Hobie Beach post the construction of Shark Rock Pier illustrate the point. Algoa Bay’s beaches are reliant on that general movement to maintain their levels of sand. What would the Bay’s beaches be without sand? The pre-BAR acknowledges that cages slow down the water column. The question we posed is how will (82) cages located in the sand movement corridor impact the supply of sand to the beaches, and why if sand moves from Cape Recife through to the Alexandria Dunefields, would material from the cages not follow the same pattern? This calls into question the conclusion by the pre-BAR/DAFF that cage particles would sink within 200m and/or move out of the Bay, away from the beaches. The pre-BAR document does not address the question raised in the pre-BAR public meeting.

9. Current movement is complex, the partial pre-BAR information leads to incorrect assumptions for Algoa 1: The pre-BAR relies on two key observations in coming to its conclusions about current movement, the first being that “during the four-month monitoring period at Algoa 1, predominately southerly (SE-SW) currents were strongest throughout the water column (Figure 3). This indicates that most of the time, during this seasonal period (February-June) the currents should convey waste from the ADZ out of the bay and away from the popular bathing and surfing beaches.” (Pre-BAR Benthic Mapping report, 2019, pg. 9). The second is that material from the cages will not go beyond a 200m dispersion zone, that material will sink to the sea bed within that area. The pre-BAR maintains that, “modelling of waste (nutrient and chemical) dispersal from a proposed fish farm at Mossel Bay (an area with similar current speeds to Algoa Bay) was conducted by Mead et al. (2009). Settable waste was expected to sink to the sea floor within 200 m of the cages (Mead et al. 2009). (pre-BAR, pg. 74). Our concerns are as follows: a. Why were the current directions not corrected for magnetic declination? b. It is important to note the variability in the water column, and in particular that wind drift in the upper 2 to 5 m can be substantial, and mostly in a different direction to that in the deeper layers. The report mentions “measurements for a near-surface (0-6m) dynamic cell”, without describing how these were made. Nonetheless, “relatively strong flows (>15 cm.s-1) were recorded occasionally flowing towards the North and North West (i.e. into the Bay and towards bathing beaches) at mid-water and surface depths (12.9 – 2.9 m)”. Moreover, in Table 2.3, the “Average current speed surface” is given as 53.73 cm/s. No direction is given, but on the basis of the above quote it can be assumed that this was also towards the beaches. Such a

8 conclusion would tie in with surface drift under prevalent north-easterly winds, where recent results show that untreated wastes resulting mainly from uneaten food and faeces from fish in sea cages will reach the beaches at Algoa 1 within one or two hours, and those inshore of Algoa 7 within three to four hours. Swimmers farther out will obviously be impacted sooner. Recognizing the wind regimes for Algoa Bay, it is evident that the nearshore and beaches will be subject to a continuous accumulation of such wastes and faeces, and the pre-BAR itself acknowledges (pg. 74) that the cumulative effects have not been considered. These beaches, in particular the Kings, Humewood, Hobie and Pollok beaches, are prime holiday destinations and include three Blue Flag Beaches. c. It is also important to note that perceptions are very important, and it is very likely that debris from the fish farms will impact heavily on any tourists/holiday-makers/beach users. Firstly, the visual aspect of the cages will be there the whole time, reminding people that the farms are there. Then, the knowledge that any recreational activity – in particular swimming in the surf zone and farther offshore – will be directly in water full of oils and faeces will likely be very off-putting.

As to current movement for Algoa 7, we cannot comment on the detail given the lack of site specific data but raise the concern about the impact on reef structures to the west of St Croix Island (north of Algoa 7) and the impact it will have for instance on the endangered African Penguin colony (and increasing Cape Cormorant populations) on the Island itself (see point 17).

10. Algoa Bay sea conditions require deep-sea aquaculture facilities, the pre-BAR’s assessment appears to be premised on calm water facilities: Waves are one of the most important criteria for establishing where aquaculture zones can be safely established, and in fact the reason why Algoa Bay was selected is because of the protection that Cape Recife offers to dominant waves from the south-west. It would then be expected that establishing the wave statistics at the identified sites would be a critical aspect, yet wave data was only “collected over an 11 month period from Algoa 2, which lies approximately 4 km to the north (SOUTH?) of Algoa 7”, and later “monitoring equipment was deployed within precincts Algoa 1 and 5 in early 2013”. No information appears to be available on the precise position, equipment used (ADCP?), water depth or analysis techniques? The report on waves comprises the following: “Significant wave height, defined as the average of the highest 1/3 of waves for a given period (in this case 8 min per every hour), approximated 1 m for 60 % of the time monitored, and was less than 2 m for 95 % of the time (Figure 7). Significant wave heights of 3.5 m or higher were experienced 1 % of the time. This equates to approximately 3 days (72.6 hr). The maximum significant wave height recorded was 5 m with a wave period of 13 seconds. Wave period approximated one wave every 12 seconds 41 % of the time, and generally ranged from 9 to 15 seconds (90 % of the time)”. In response to criticism about the lack of substantial wave data in the first report of 2014, the applicants stated: “The wave climate is currently being monitored at both Algoa 1 and Algoa 5, but it must always be acknowledged that storm generated waves with a return period greater than the monitoring period may not be recorded

9 (i.e. the probability of recording a 1 in 5 or 10 or 50-year storm event is low during a 12-month monitoring study)”. It is disappointing that not more information on waves is presented when there are internet sites where hindcast wave data is available (e.g. ftp://polar.ncep.noaa.gov/pub/history/waves/). In the pre-BAR one paragraph records that “maximum wave heights of 6 m have been recorded along the surf zone of Algoa Bay by MacLachlan (1983)”, and Britz et al (2016, pg. 39, 41) find that: “In comparative terms, Algoa Bay is thus much more exposed to swell than other aquaculture industries based on cage aquaculture, for example, the sea bass culture in the Mediterranean, and salmon in fjords in Chile and Norway. The high swell exposure places Algoa Bay in the commercially experimental “offshore cage aquaculture” category requiring a much higher (and more expensive) equipment specification.”

The problem with the reported results is then that potential farmers may think significant wave heights of 3.5 m or higher will occur only 1% of the time, with no indication of what a 1:50 or 1:100 year wave event could be. As an example of the waves that can be experienced along the Port Elizabeth beachfront, a storm on 1 September 2008, caused considerable damage to the foreshore. The hindcast wave data from the above ftp site records a significant wave height of over 9 m south- southeast of Cape Recife (34.5 °S, 26 °E), and it is likely that waves were breaking at all the Algoa sites – 1, 6 and 7. Any cages will need to be designed to cope with breaking waves with a significant wave height of 6 m and more, since the last thing that is wanted is a break-up of the cages with the damaged parts washed up on tourist beaches. Consequently, a statement such as “significant wave heights of 3.5 m or higher were experienced 1 % of the time” conveys entirely the wrong impression of the waves that can be experienced. In particular, the cages will need to be designed for the extreme cases, and not an ‘average situation’.

Another aspect which is not considered is the regular servicing of the fish cages. There must be a criterion for the maximum waves that can be handled adequately while the cages are being serviced, and as such it would have been expected that the wave records would have been used to determine the percentage of days available for servicing: this does not appear to have been considered at all in the pre-BAR. Britz et al (2016) continue “small research vessels performing day trips from Port Elizabeth harbour do not work under ‘poor’ and ‘caution’ conditions. Similar size vessels would be used for pilot aquaculture operations, however larger vessels would be required for commercial operations. The high percentage (ca. 50%) of ‘poor’ and ‘caution’ sea days characterized by windspeeds of >14knots thus places a severe operational constraint on servicing cage farms in the Algoa 1 and Algoa 5 ADZs. This is confirmed by the experience at the Irvin and Johnson pilot cage culture operation adjacent to the Port Elizabeth harbour in Algoa Bay, where 95 sea days were missed in a 12 month period due to unsuitable weather (G. Le Roux, 2016 unpublished data)” and “ Kob requires daily feeding to achieve economic growth and skipping one or two days has been found to significantly reduce growth rates and food conversion ratios (Guy and Smith, 2016). As small craft cannot operate safely 50% of the time in Algoa Bay, this means that the only alternative to effect daily feeding is the use of larger ships out of Nqura Port on which crew can live aboard (Figure 2). The capital cost of such vessels would only be justified by very large economies of scale. The prevailing

10 high wind and swell conditions place a severe operational constraint on servicing fish cages”. The pre-BAR and the Socio-economic Report appear to be using different premises from which to evaluate the ADZ potential? Based on input from various Algoa Bay sea users and with reference to various published studies, we are in agreement with the Socio-economic Report that sea conditions at both Algoa 1 and 7 are not consistently “calm” conditions. If the BAR is premised on an ADZ with calm sea type fish cages and operations, it will not have used the correct assumptions through which to evaluate the economic sustainability of the ADZ.

11. Sea-based fish farms are not the only, nor necessarily best, approach to aquaculture: In the previous application, DAFF had cited food security as a part motivator for the need of an ADZ. In this new process, the pre-BAR argues under the “need and desirability” discussion that aquaculture is the “fastest growing form of food production in the world and a significant source of protein for many people in many countries” and concludes that “aquaculture (which includes mariculture) is best positioned to contribute to food security, wealth and job creation” (pg. 38). We would have two queries to raise in this regard: a. The pre-BAR documents contradict this notion of “food security” and point to the high conversion rate of wild fish stocks as feed for the caged fish. In the supporting Socio-Economic Report (Britz et al 2016, p.18) on the issue of food security, the report states that “5.1. The reviewer finds limited support for the aquaculture projects [sic] claim to improve food security. The principle [sic] food for the finfish is pellets made from wild fish. It seems that a greater mass of wild fish have [sic] to be harvested than can be delivered as finfish product. The finfish farming projects do not offer a substitute to wild fish harvesting if the latter is required as a production input for the former. The project is more accurately described as one to convert low (market) value wild fish into high (market) value finfish. There is economic merit in such production, but it cannot be claimed as a sustainable alternative to wild fish harvesting, if wild fish are a necessary production input”. It is our understanding that an average conversion ratio of 10:1 (wild fish mass: cage fish mass) applies. For Tuna 15.8kg of feed is needed for the tuna to gain 1 kg of body weight (see atuna.com). As such, finfish farming actually exacerbates or amplifies food insecurity. Who exactly would be the intended market of this ADZ, as “high value finfish” is unlikely to be affordable to the average South African citizen? b. Furthermore, the pre-BAR in its discussion of alternatives, considers only different configurations of finfish/bivalve options at the three sites and the no-go option. It doesn’t assess land-based aquaculture as an alternative, despite the Coega Development Zone making a specific provision for such. It argues that the intent of DAFF is to introduce sea-based (specifically finfish and bivalve) aquaculture which mitigates against any land-based options. It doesn’t consider estuary-based earthen pond options, such the current Zini Fish Farm (formerly Mtunzini Fish Farms) in Northern Kwazulu-Natal, that draws water from the Mlalazi Estuary, has 52 earthen ponds and rears both Kob and Grunter. It doesn’t consider seeding of natural fish (Kob) stocks and what impact the cleaning up of the Swartkops estuary (which Kob require to reach maturity) would have on Kob populations of the Bay and thus the increase in catches for traditional fishing and community based small scale

11 fisheries (see masifundise.org for examples of small scale fishing). Finally the pre-BAR doesn’t consider the possibility of aquaponic schemes as an alternative. It appears as if DAFF is locked into only one type of aquaculture, mass-farmed commercial operations. If food security (and local development) was the main driver of DAFF’s consideration of aquaculture in the Bay, why is it not considering alternatives to commercial sea-based finfish farming that may better serve that interest?

12. Priority given to ocean users in the absence of a Marine Spatial Plan is arbitrary: Currently the DEA is in the process of promulgating legislation that enables marine spatial plans (see MSP Bill B9-2017, Government Gazette no. 40726 of 28 March 2017). A specific SARCHI-funded unit has been set up at Nelson Mandela University (NMU) to specifically address this initiative. Academics from that unit (and other) and user groups from Algoa Bay have highlighted the viability of the Bay being a pilot MSP (see Dorrington, R.A. 2018. et al ‘Working together for our oceans: a marine spatial plan for Algoa Bay, South Africa’. South African Journal of Science) given the “substantial body of bio-physical data that exists for the area”. Algoa Bay has the (informal) status as the most scientifically studied/monitored body of water in the Southern Hemisphere. However, in both the original and now new assessment process, potential sites have been excluded on the basis that they conflict with specific users. Algoa 2 and 3 were excluded due to a conflict with harbour traffic, Algoa 4 was excluded because its depth made it commercially unviable to prospective fish-farmers, and Algoa 5 was excluded both because of distance from port (commercial interests) and because it fell within the newly proclaimed (but yet to be gazetted) Marine Protected Area (MPA) that forms part of the Greater Addo Elephant National Park. In effect it means that the pre-BAR/DAFF have ruled in favour of certain users’ and their interests over and above that of other users in the Bay? On what basis? If the MSP is imminent, why rush the ADZ process, why implement an ADZ that will in effect dictate spatial planning of the Bay? Once fish farms are in place, moving them to a new location would be a practical impossibility.

Further to this point, were the ADZ to go ahead as indicated it would render plans for the following initiatives void: a. The North-End Beach to NMB Stadium precinct (Algoa 6 would negate any engineering works planned to re-establish the beach) b. The Hump-back Dolphin sanctuary in the sea off the Pollock Beach to Pine Lodge area (the southern component of Algoa 1 falls within this area) c. Any potential for an Olympic-type sailing area/facility off Hobie Beach (the ADZ impact assessment of the sailing area does not take previous regatta courses into account – given the prevailing south-westerly winds the northern section of Algoa 1 would prevent beach viewing of future regattas/competitive sailing events)

13. The current public participation does not enable I&APs’ informed engagement: There are several concerns about involving and informing I&APs because of the process that the pre-BAR/DAFF has embarked upon, amongst which include the following:

12 a. While the NEMA regulations stipulate a 30-day process for public consultation, the complexity and volume of the pre-Bar and accompanying documents that have been presented to the public during the month of April 2019 (events have included: a National Life-Saving competition, an IronMan, a Bell Buoy open water event, the Splash Festival, several public holidays and final campaign efforts for the upcoming 08 May national and provincial elections) means that the process of understanding what has been presented, consulting with own user constituencies and formulating substantive responses, is effectively reduced to 15 days by the limited time and conflicting events. b. As mentioned before, Algoa 7 has not been through the same process as the other sites and the communities in close proximity have not been involved in giving input into that site. c. Several questions by various parties were raised in the meeting of 06 March, the minutes of that meeting were only circulated on the 23 April. We are still to review the minutes in detail, but from our own quick overview, several of the questions we posed in that meeting have not been addressed in the pre- BAR document. As per the EAP corrections and comments on the minutes are only due back by the 10 May 2019, how then was the pre-BAR public meeting meant to inform the pre-BAR if minutes are considered post input into the pre-Bar (which closes 30 April)? d. In engaging with several user groups that were registered as I&AP’s in the previous ADZ process, it appears several have not received notices of the new process. It appears that the I&AP list of the first process has not been used to inform the new process? Thus many users (originally identified over the original four year period) are unaware of the new process and confused as to its link with the suspended appeal.

14. The pre-BAR requires attention to detail: The pre-BAR may simply require a more careful edit, but there are several detail inconsistencies that impact the understanding of what is being proposed: a. The visual representations of Algoa 1 in the pre-BAR and supporting documents are not consistent and the boundary of the northern and southern section is not consistently marked. Eg. Figure 2 in the Benthic Mapping document, and Figures 20, 30 and 31 in the pre-BAR take on different shapes. We ask (as per the pre-BAR meeting) that a single visual representation is given of all of the sites and that in the case of Algoa 1 that the BAR clearly marks the location of the Bell Buoy, the Blue Flag beaches, the Shark Rock Pier and the harbour. b. In section 8.5 Socio-economic character (pg. 67), the pre-BAR makes reference to “Algoa Bay’s 40km of breath-taking coastline…”. It may seem a trivial point, but the Bay’s public beaches alone equal 40km, the Algoa Bay coastline itself is much longer. c. Under point “10. Environmental Impact Statement”, tables 42 (pg. 150) through to tables 46 (pg. 153) list the identified impacts and their significance, and then give a summary of the positive impacts in table 47 (pg. 157) and the negative impacts in table 48 (pg. 157). However, the summary tables do not appear to tally with the preceding impact tables as number of

13 impacts in a given high/medium/low/very low classification. The confusion may arise due to the different configurations, perhaps a table of each category of impact significance could clarify?

15. The Impact Assessment methodology is flawed: The pre-BAR lists positive and negative impacts and then assesses them on a range of significance from “insignificant” to “very high”. While the ratings have a complicated formula, the separation out into specific issues and their associated ranking has not been substantiated. By example, in our view the loss of the IronMan event is an issue serious enough to be considered on its own, yet it is subsumed under the item “OP- SE3: Negative economic impact on specialist tourism and recreational businesses by finfish culture at Algoa 1” and given a “medium” significance rating after mitigation. We assume that if fish cages are installed in close proximity to the current IronMan open water course, the perception alone of increased shark attack risk will result in the organisers being forced to move the swimming venue (and thus entire event) to a safer coastal venue. Have the organisers agreed that the mitigation measures will address their concerns? The other example is that “OP-SE1: Investment in the local economy…”, “OP-SE2: increased employment, income and skills development” and “OP SE11 lists a positive impact on small businesses…” are all seen and listed as separate positive impacts with different rankings. Yet they are essentially premised on only two potential impacts: increased jobs and increased business to local suppliers. In short it appears that the pre-BAR condenses negative impacts and fleshes out positive impacts which gives the casual reader a more favourable impression of the ADZ’s potential sustainability. A more thorough process is required to accurately identify and assess each separate impact of the development. Furthermore, the case has not been made that the impact of the mitigation measure (a pilot-phase) will actually address the negative impacts identified (see point 16 below). To thus present this as a fait-accompli is incorrect.

16. The 12-cage pilot phase as mitigation will not provide the necessary insight into a full scale 82-cage operation at both Algoa 1 and 7: The pre-BAR’s answer to the several conflicts and objections raised by I&APs is to proceed with, “a precautionary phased approach is proposed for finfish farming in the ADZ, where activities in the first year of operation would be limited to pilot operations producing 1000 tons finfish per annum for the entire ADZ. Bio-physical and socio-economic monitoring studies would be conducted during the first phase of the establishment of the ADZ (see Chapter 9) and would determine the acceptable maximum scale of the ADZ based on observed environmental impacts. The phased approach would be overseen by the ADZ Management Committee (AMC) and the Consultative Forum” (Appendix F: Environmental Management Programme, March 2019, pg.10). We consider this mitigation strategy flawed for the following reasons: a. The scale difference of the pilot project in relation to that of full production will not demonstrate the feasibility of a full operation. A 1 000 (t/annum) operation as opposed to the intended 3 252 (t)/ 4 911 (t) full production (see Overview section), is of an entirely different magnitude. The visual, fecal/food debris, shark attraction, sand retardation, etc. impact of 12 cages vs. that of 82 cages of full production is vastly different.

14 b. As per the I&J pilot project (EC Sea Cage Finfish Pilot Project) that took place north of the current harbour in 2007, finfish operations require 3 – 4 years before the fish are at a size suited to commercial harvesting. As we understand it, the viability of extending the ADZ will be decided after the first year? How would it be possible to assess the feasibility and impact if the pilot operation if the fish are not yet at a commercial size for harvesting? c. The public perception about shark attack risk (and thus change in open water usage) will not differentiate between 12 cages and 82 cages. Any number of cages in close proximity will change users’ perceptions.

17. The risk of the ADZ on the endangered African Penguin (and other bird life) has not been assessed: St Croix Island is currently home to a colony of 18 000 African Penguins. Roughly 50% of the world’s population of African Penguins reside in Algoa Bay and 70% of those live on St Croix Island (as per Dr Lorien Pichegru). African Penguins feed off pelagic fish in the main (90% of their diet) and their numbers have been rapidly declining due to the increased distances they have to venture to find fish to feed their chicks. Our concerns with the proposed ADZ is twofold: a. What will the impact of Algoa 7’s 82 cages and fishing operations in close proximity to the island be on the penguins? b. From where will the pelagic fish for the caged fish’s food pellets be sourced from? Will DAFF increase the current (local) pelagic fish quotas to cater for this increased demand and how will that impact the Penguin’s (and by virtue of that the Gannet colony on Bird Island) natural food supply? These questions are not considered by the Pre-BAR and are of great concern to us.

4. Conclusion:

In conclusion, having now the benefit of an (time constrained) overview of the pre-BAR and supporting documentation, we as the Algoa Bay Branch of WESSA believe the argument made in favour of a sea-based ADZ contradicts itself in parts and in other parts is based on a limited view. We believe as a consequence that the pre-BAR is fundamentally flawed in its assessment and conclusion.

It is our considered view that a more thorough public participation and an equal data assessment of all sites is required, that the cages are falsely premised on calm seas, that the impact on open-water and reef users is significantly underestimated and thus could lead to the potential loss of jobs and closure of related businesses, that the eco-system and economics of the bay will be seriously negatively impacted and ultimately that the ADZ process pre-empts the MSP. It is our view that the proposed fish farms as currently envisaged will fundamentally re-shape the dynamics of Algoa Bay and that its impact will be a significantly negative one on the society, economy and environment.

To this end we call upon the EAP to ensure that the BAR implements, and provides to I&APs, the following before any conclusive recommendation can be made: a. A quantitative socio-economic study (as committed to by DAFF in the appeal) of the potential job and economic loss that Algoa 1 and 7 would have on (direct & indirect) businesses that rely on current and emerging human usage of the Bay

15 b. A comprehensive (and equal) evaluation of all the sites, that includes both an assessment of the presence of substances/organisms that render fish and bivalve products unfit for human consumption (specifically E.coli and micro-plastics) and adequate seasonal measurments for wave and current movement c. A full assessment of sand movement of the Bay, which would assess the likely impact of an ADZ on future sand movement (and beach supply) and its indicative implications for current movement observations. d. The consideration of other aquaculture options that would benefit traditional and previously disadvantaged fishing communities (especially: estuary ponds, seeding of fish stocks and aquaponics) e. Consultation with traditional/previously disadvantaged fishing communities and the NMB’s northern suburbs (specifically: Motherwell, Wells Estate and Blue Water Bay) f. Analysis/learning from existing or failed aquaculture projects (for example: the I&J pilot north of PE harbour, the Mossel Bay aquaculture project, the Coega land-based project, the Hamburg Kob pilot project, the Zini Fish Farm, the Mozambique Kob fish farms, and the Saldanha Bay ADZ/Southern Cross Fish Farm) g. An economic feasibility study of the ADZ premised on heavy sea/deep sea fish cages and support operations h. The supporting data (or full report) of the social impact study (specifically the actual questions posed to the participants and the sampling methodology used).

On behalf of WESSA-ABB

Gary M Koekemoer Chairperson

16

To Whom It May Concern

PEMBBA (Port Elizabeth Metro B&B Association) is the recognised body for B&B establishments in the city and has a membership of over 120 businesses, both accommodation as well as businesses that service the industry.

We wish to express our gravest concern at the proposed Aquaculture farm at both Algoa 1 and Algoa 7.

There are several reasons for our concern listed below:

1) We boast 3 Blue Flag Beaches which our guests use. These have the potential of being polluted by effluent, excess fish food and fish faeces which will wash up on the beaches during our frequent easterly/south easterly winds. 2) The loss of jobs in the tourism industry will FAR OUTWEIGH the gaining of jobs at the fish farm. Even a fraction lost from our industry will be MANY MORE than those gained. i) If you consider JUST our PEMBBA accommodation members – 88 with an average of 5 rooms per establishment and approximately 4 staff per establishment (2 cleaners, 1 gardener and a manager/owner) – 352 direct jobs just in accommodation establishments in PEMBBA. ii) Assuming a 40% occupancy (this is very low) @ R750.00 per room per night, The sums look like this : 440 rooms (average members’ rooms in PEMBBA 88 members x 5 rooms) x 40% = 176 bed nights sold x R750.00 = R132 000.00 income per day x 30 days in a month= R3 960 000.00 per month x 12 months = R47 520 000.00 potential loss from JUST PEMBBA members should Tourism be negatively affected and the industry of small accommodation businesses die. iii) If you consider that AirBnB advertises nearly 1000 rooms, you can calculate the number of staff and income here. iv) The hotels (most of which are on the main beachfront area) all employ MANY staff to man their cleaning/food and beverages/reception/management. v) The direct tourism related businesses – tour guides/activity businesses/ocean based businesses to name but a few – you realise how many people are employed here vi) Restaurants with all their staff. The potential loss of work cannot be overlooked or under estimated. If we look at our 40% occupancy numbers and add R150.00 per person per day for dinner bought at a restaurant, this amounts to R52 800.00 per day x 30 days = R1 584 000.00 x 12 months = R19 008 000.00. (We think you would agree that R150 is VERY low and does not include a bottle of wine or a beer!) 3) The loss of the Aquelle Ocean Series/Bellbouy Race/the nippers/lifesaving champs/ not to mention the possible loss of the Volvo Ocean Race which the city is bidding for will be great. All these events bring in huge amounts of money, not only in bed nights, but also revenue for the city. Their demise because they cannot have the events any more would be a huge loss to the city. 4) The loss of revenue both to the city and to the businesses will run into the billions of Rands (as the small sample calculated above indicates – just add hotels/other accommodation and direct spend businesses into the mix).

Consider IronMan –

This is the report on 10 April 2014 from NMBT

Ironman falls into the sports tourism category and has an exceptional positive impact for the local economy of NMB. The event attracts professional athletes to our destination along with a large group of supporters and spectators from all around the globe. Since 2005 - 2013 IRONMAN South Africa has welcomed 11 838 finishers. This has resulted in a total of R400 million in direct spend revenue injected into NMB and a total of 314 530 overnight stays in the city for 2005 – 2013.

The event itself not only appeals to those within the city at the time but those who can follow the happenings through various media streams. Media values verging at R12 million is generated through the event. This coverage showcases not only the awesome event and athletes but the destinations amazing assets as well as abilities to potential visitors and investors. These events allow for the hosting destination of NMB to show the world that we are capable of hosting world class events.

IRONMAN South Africa celebrated its 10th birthday this year along with Nelson Mandela Bay’s Centenary where Port Elizabeth has been declared a city for 100 years. This has led to a record number of 2371 entries and a sold out IRONMAN South Africa 2014. The field was made up of 82% males and 18% females while 22% of entrants of the full field were international and 88% travelling from of South African entrants came from outside NMB. The top 5 countries represented in 2014 were UK (113 athletes), Argentina (66 athletes), USA (32 athletes), France (30 athletes), Germany (23 athletes).

This year saw roughly 49 275 bed nights sold to athletes and immediate family, however due to coaches, supporters, special guests, sponsors and media travelling to the event an even higher occupancy in accommodation facilities will be totaled. These numbers will increase and be available after the event impact assessment is completed. The average direct spend in the city for 2014 is estimated at R64 million. When one factors in the loss of this sporting event on our city and industry, the loss from this 1 event FAR OUTWEIGHS any profit made from the Fish Farm. IronMan have stated that they WILL find another venue/city if the Fish Farm goes ahead. We simply cannot accept the loss this will bring to our city for a project that has NO guarantee of success.

We would also like to bring it to your attention that, as the only B&B related association in the city, NO-ONE from Anchor Environmental Consulting has contacted me, or any of my committee members for any input on this matter. We find this totally unacceptable as we were very vocal in the previous application and nothing has changed in our view. The fact that an Economic Assessment was urgently requested then, and has been totally ignored this time under the pretense that there were no funds to do it, just goes to show that the will to listen to the residents’ and business’s concerns is not a priority in this assessment/proposal. To do a “survey” on a few 100 people on the beach in June 2016 is utterly unacceptable, what information were they given when asked “if they minded having a fish farm off the coast”. This is unprofessional and totally unacceptable in a matter of such extreme importance.

Shena Wilmot

CHAIRPERSON

Contact # 082 800 4542 www.pembba.co.za FISH FARM DEVELOPMENT FROM KINGS BEACH TO BELLBOUY – 2019

Written by Margo Schuin.

It was with absolute horror to read and hear about the proposed Fish Farm rearing it’s ugly head again. We put this to bed years ago – I even wrote a letter to the Herald those days !!!

LEAVE OUR BEACHES ALONE.

I am 69 years old and have been boogie boarding at Hobie Beach and Kings Beach since I was 6 years old and still do with my Grandchildren.

Now because someone’s palm is being greased, we risk losing the most amazing swimming beaches in South Africa. Bring me any better beach along our South African coastline that is as safe and beautiful as Kings Beach, Hobie Beach and Pipe.

Boogie boarding in Cape Town is unpleasant as the water is too cold, along the KZN coastline the waves break on the sand and there are strong currents.

No more swimming as the fear of sharks will drive us all to the swimming pools. No wonder they want to build a water world where the Boet Erasmus Stadium used to be as this will have to be our new tourist attraction where you will have to pay like you do at Sun City.

You won’t even be able to walk on the beaches because of the smell.

Gone will be Iron Man that brings in Millions, Bellbouy swim, Nippers and life savers and Surfers.

Imagine sitting and having your lunch or supper on the balcony of Ocean Basket or any other of our beachfront restaurants and all you smell is fish faeces and bait. You will think you are dining on a fishing trawler. Gone will be that most gorgeous view that draws us back there time and again.

Imagine having paid top prices for your beachfront accommodation, including Hotels and townhouse complexes to be hit with this smell night and day.

Please invite me to take those who think it is a good proposition along our Beachfront and ask them if they would like to spoil the pristine view with huge fish tanks protruding out of our super clean water and spoiling our sunrise and our view over the ocean.

Wake up PE.

You live in Paradise and you want them to turn it into a rubbish dump.

29 April

PRO DIVE - Algoa Bay Internationally Recognised as a PADI 5 Star Scuba Diving Centre Started in 1996

Proposed Algoa Bay Aquaculture Development Zone

We are unequivocally opposed to the proposed Algoa Bay Aquaculture Development Zone ​ ​ (ADZ), commonly referred to as the “Fish Farm”, as contained in the Department of Agriculture, Forestry and Fisheries’ (DAFF) new Basic Assessment (BAR) process.

Introduction: Pro Dive has been operating from Hobie Beach for 22 years and has been internationally recognised as a PADI 5 Star Career Development Centre. This brand is recognised worldwide drawing divers to Port Elizabeth from all over South Africa and abroad.

We offer the following products: Snorkelling, Kayaking, Scuba diving training, Daily charters, Sales, Servicing and Travel packages.

Economic Impact ● As a commercial operator, Pro Dive has not been consulted regarding the Socio Economic Impact of the Fish Farm which we believe is a huge flaw in the impact study. Particularly if you consider that we are the biggest marine operator in Algoa Bay. ● We employ 14 full time staff and they would be directly affected if we are unable to operate successfully. ● There is a constant flow of tourism income generated from International Divers visiting our area which is growing substantially i.e. accommodation, meals, game safaris is extensive. ● If our charters or training dives become affected this will indirectly impact on all the other components of our dive centre ie. our shop sales, servicing and travel packages. ● Our clients are usually from a middle to upper class having a huge impact on Algoa Bay. ● Tourism creates jobs and sustains the economy and is vital to Algoa Bay. We play a big part in this process.

Bell Buoy Reef, Algoa Bay Bell Buoy is a spectacular and extensive reef system situated approximately 2km from Hobie Beach. The average depth is 12m with pinnacles rising to 5m below the surface. Bell Buoy is made up of gullies and pinnacles which are teeming with fish, soft corals, feather stars, starfish, sea fans & anemones. Many animals from the smallest nudibranch to the resident Ragged-tooth shark shares a spot on this popular reef.

Unbelievable Value of this Reef Bell Buoy is invaluable to our operation due to the following: ● The short boat ride from the beach plays a major role when you consider the logistics to offer both training dives and regular charters. The turnaround time on one dive to Bell Buoy is approx 2 hours. ● The weather plays a huge role in planning our dives and this “short” turnaround time allows us alot more opportunity to dive. ● In the event that our deeper dives (further dive sites - 20km away) are cancelled due to rough sea conditions, Bell Buoy can often be dived as an alternative dive site due to its location. ● There is an increasing demand for divers to dive with sharks in their natural environment and Bell Buoy has the resident Ragged Tooth Sharks. ● It is the “perfect” house reef due to the shallow depth, close location and incredible marine life found there. ● The fact that Bell Buoy is a shallow reef it means that we can accommodate all levels of divers and cater for every-one at this dive site.

Bell Buoy - Training Dives Not only do we use Bell Buoy reef for the entry level training courses but if fulfills a valuable role in many of our training programmes: ● Open Water Course - 2 training dives per course ● Advanced Course - 3 training dives per course ● Specialty Courses e.g. underwater photography - 3 dives per course ● Divemaster Courses - 20 dives per course ● Internship programmes - at least 60 dives per learner over a 6 month programme ● Marine Monitoring dives that we run in conjunction with Dr.Shirley Parker-Nance (approx 10 dives)

Bell Buoy - Diving Charters We offer recreational dives 6 days a week, 363 days of the year. If you consider that our boats take 12 divers per launch and we often have more than one boat running on a particular day this accumulates to thousands of divers per year that visit Bell Buoy Reef.

Impact of the Fish Farm on Bell Boy Reef ● The fish farm is bound to alter the environment and impact on the behaviour of the fish and sharks on the reef . It would be tragic if the Ragged Tooth Sharks moved from this area as this product is growing and a huge draw card for divers worldwide. ● In Cape Town recently the presence of Orcas in the area caused the Great White Sharks to leave . As a result, the resident Cow Sharks have now moved to Seal Island to feed on the seals. Both the Great White Shark Dives and Cow Shark Dives have been affected by this change. ● In the event of more shark presence in the area this could impact on the safety of our divers ● The water quality and visibility could be negatively affected by algal blooms that generally take place with fish farms.

Conclusion: Algoa Bay is one of the most valuable Bay’s in Southern Africa providing refuge for numerous marine animals either while migrating or residing here. This magnificent marine life is drawing substantial interest around the globe with it already being proclaimed as a Hope Spot due to the diversity and incredible marine life that occurs here. Also known as the Bottlenose capital of the world. It is our duty to protect this asset of Algoa Bay for the children of the future and to use this resource wisely.

After studying the report there are major flaws in the sample sizing and testing that has taken place. The fact that we are a business that uses Algoa Bay on a daily basis should be critical in your analysis.

Anchor Research & Monitoring (Pty) Ltd 8 Steenberg House, Silverwood Close 30 April 2019 Tokai Cape Town 7945 Via e-mail: [email protected]

Attention: Ms Vera Massie

RE: COMMENTS ON THE APPLICATION FOR ENVIRONMENTAL AUTHORISATION FOR A PROPOSED SEA-BASED AQUACULTURE DEVELOPMENT ZONE IN ALGOA BAY, EASTERN CAPE

General Comment SANParks does not support a sea-based aquaculture development zone (ADZ) in Algoa Bay. The environmental and socio-economic risks related to an ADZ remain substantive with minimal recourse from the proposed mitigation measures. The highly exposed coastline, prevalence of strong easterly winds, and frequency of harmful algal blooms in Algoa Bay are among many significant environmental limiting factors, while existing developments including two major ports and increasing ship traffic, more recently due to bunkering operations, pose additional risks to the viability of an ADZ. Furthermore, an ADZ will impact and threaten existing socio- economic-bearing industries i.e. marine-based tourism such as accommodation establishments, boat-based tour operations (whale watching, SCUBA diving, sailing etc), fisheries, as well as local and international sporting events. For example the southern portion of the proposed Algoa 1 zone overlaps with a squid nursery area and could therefore impact recruitment and stock status of the squid fishery. The visual impact of the ADZ will permanently alter the sense of place of the Port Elizabeth beachfront and discourage recreational and other users. Previously, SANParks had supported the expansion of the bivalve mariculture zone within the Coega IDZ (Algoa 6), however, increasing levels of pollutants from industrial and human waste, and the specifically high levels of E. coli in this area of the bay, which has led to periodic closure of the operation as well as its product prohibited from international export, renders further expansion unviable. This example demonstrates the challenges in marine species culture in Algoa Bay, and highlights the lack of technical and management technologies to undertake a viable operation with long term benefits to the local and national economy.

Specific Comments 1. Marine Impact Assessment Report: The following environmental impacts associated with finfish cage culture, which are well documented in international studies, are listed in the Report (page 3):

• Incubation and transmission of fish disease and parasites from captive to wild populations. • Pollution of coastal waters due to the discharge of organic wastes. • Escape of genetically distinct fish that compete and interbreed with wild stocks that are often already depleted. • Chemical pollution of marine food chains (& potential risk to human health) due to the use of therapeutic chemicals in the treatment of cultured stock and antifouling treatment of infrastructure.

Page 2 of 3

• Physical hazard to cetaceans and other marine species that may become entangled in ropes and nets. • Piscivorous marine animals (including mammals, sharks, bony fish and birds) attempt to remove fish from the cages and may become tangled in nets, damage nets leading to escapes and stress or harm the cultured stock. Piscivorous marine animals may also be attracted to the cages that act as Fish Attractant Devices (FADs) and in so doing natural foraging behaviours and food webs may be altered. Farmers tend to kill problem predators or use acoustic deterrents. • User conflict due to exclusion from mariculture zones for security reasons.

1.1. Algoa Bay is a biodiversity hotspot along the South African coast, with particularly diverse subtidal invertebrate fauna. This is substantiated in the Marine Specialist Report by Dorrington (2018) citing extraordinary invertebrate diversity on Algoa Bay reefs. The list of impacts does not include the disturbance to ecologically significant and biologically sensitive habitats such as reefs which support a unique diversity of invertebrates and are a key feeding and aggregation site for fish. The hazards associated with the introduction of alien species both directly or indirectly are also not considered.

1.2. The listed potential impacts are assumed to be mitigated through “astute animal husbandry and adaptive management strategies” and include the dedicated monitoring of various impacts during operation. Mitigation measures for several of these impacts have failed in international finfish culture operations where expertise in animal husbandry are well- established. The proposed development is a pioneering initiative in finfish culture in South Africa, however, given the unsuitable location i.e. insufficient shelter as that of a fjord, and sensitivity of the site, it is highly risky to compromise current benefits for perceived gains. The suggested mitigation measures in the Report to address these impacts are untested and therefore severely underestimated, since technologies and strategies for adaptive management of finfish culture are lacking in South Africa.

2. Other impacts substantiated in specialist reports:

• Scuba diving and reef impacts (page 74) Recreational scuba diving: “Given that the study did not take cumulative effects into account, it is recommended that a precautionary principle be followed, especially when considering the potential scale of fish farm development proposed for Algoa Bay. In addition, should any therapeutic or antifouling chemicals used in fish cage culture operations reach the reefs at concentrations that are still effective (the Mead et al. 2009 study assumed a similar dispersal rate and distance as for dissolved nutrients), this would probably cause further deleterious impacts on diving reef communities. The Wright et al. (2019) study did not consider the dispersion or impacts of antifouling chemicals.”

• Dispersion report: Conclusion (page 25) The proposed mariculture operations will add approximately 10% of the current nutrient load into Algoa Bay, which constitutes a significant cumulative impact of nutrient loading into a bay which has been documented as showing symptoms of eutrophication (Lemley et al 2019).

• Benthic report: Conclusion (page 32) The seafloor at Algoa 7 is already disturbed/impacted by the nearby dredge spoil from the Port of Nqura. Algoa 1 maintains a natural benthic state and habitat variability, and supports greater overall diversity, and is therefore more preferable to use Algoa 7.

3. The Socio-Economic report: • The Socio-Economic Impact Assessment for the proposed Algoa Bay sea-based ADZ estimates Medium impacts from the Algoa 1 ADZ on tourist and recreational activities, real Page 3 of 3

estate values (sense of place), and local fishing industries (specifically squid fishing), as well as Medium impacts related to potential leakages and pollution of the environment at Algoa 5. This was done qualitatively and no quantitative surveys to substantiate the “medium” rating is provided. Given the scale of impact both environmentally and socio-economically, a rigorous quantitative analyses that weighs current revenue against perceived revenue from the proposed ADZ must be undertaken. Furthermore, the mere perception of an increase in the risk of shark attacks is sufficient to potentially lose a major tourism driver and income generator such as the International Iron Man event hosted annually in Algoa Bay. • Comparative assessment in the Socio economic report indicates, that although the appellants concerns about tourism impacts are undetermined, the logic followed is realistic, and DAFF concedes that there will be an impact on tourism. • It further determines that the proposed socio economic impact, in terms of jobs and income, of the ADZ was far over reached in the original report (calling it speculative and conjecture, with no evidence), and was downgraded significantly to a mere 50-100 jobs in the current report (by aquaculture industry experts). • Furthermore The Feasibility study indicates that the socio-economic feasibility is only “moderate” with the economic feasibility as “low” (again by aquaculture industry experts).

4. The proposed Algoa 7 site has not been assessed at the same scale of detail as Algoa 1 and Algoa 5. Instead economic and oceanographic elements from the Algoa 2 and Algoa 5 assessments are used in the pre-application BAR to infer that Algoa 7 is a viable site. This assumption is precarious, and failed to consult communities neighbouring this site (St Georges Strand and Bluewater Bay) who will likely be most affected as ocean and beach users.

5. The section on Bunkering failed to consider cumulative risk to the islands and seabird breeding habitats at St Croix. It is not only the release of petrochemical compounds (whether catastrophic or in smaller spills) that is a risk to the aquaculture farm and islands, but also the increased risk in anchorage and connection failure (between bunkering vessels) and ship collisions with the fishfarm, given the proximity to the bunkering and anchorage area. Cumulative impacts on the islands are consequently doubled given the potential interaction between the fishfarm and ships in the area.

Conclusions: Despite several years of research and development, the financial and technical feasibility of sea- based finfish culture has not been demonstrated in South Africa. This is clearly stated in the feasibility study where both the socio-economic and economic feasibility is moderate to low. The insistence of DAFF in developing an ADZ in Algoa Bay seems contrary to most of the economic and environmental considerations, as well as the supporting studies and the will of the people of Port Elizabeth.

SANParks supports finfish mariculture focused on shore-based, recirculating systems that pose lower environmental and economic risk. The success of this technology has been demonstrated on a commercial scale through the operations in the East London IDZ.

Sincerely,

Ms Cloverley Lawrence Marine Scientist South African National Parks Email: [email protected] CC: Dr A Oosthuizen; Nick de Goede, Rob Milne 3 Carradale Percy Owen Street Summerstrand 6001

30 April 2019

Anchor Research & Monitoring 8 Steenberg House Silverwood Close Tokai 7975

Dear Sir/Madam

OBJECTION TO THE DEVELOPMENT OF THE ADZ IN PORT ELIZABETH

I write in my capacity as an interested and affected party as well as a ward 1 committee member who has attended your presentation on the proposed ADZ sites to be located in the bay at Port Elizabeth.

I would like to register my objection to these proposed developments on the following grounds:

1. Negative impact on tourism along a pristine beach at Algoa site 1 which is used by many different communities for recreational activities including the Ironman competition, surfing competitions, diving training and other water sports events that bring a lot of revenue to our city. The Metro will lose the Ironman competition if the proposal goes ahead and will negatively impact the Metro brand as a watersports active capital and ecotourism destination.

2. The fish food waste and fish faeces as well as the antibiotics fed to the fish will result in an oily slime and pollute the waters which will be unpleasant for bathers, surfers, divers etc. Who wants to get into slimy water? The caged fish will be fed antibiotics at times as prevention for diseases which will also spread in the water and affect other species and bathers. The prevailing winds are generally from a north easterly direction for about 8 months of the year which would push the waste towards the beaches. Regrettably the consultants only studied the wind direction in the bay for a mere 4 months of the year (February to May) in which the wind blows in the other direction.

3. The fish farm cages will no doubt attract more sharks into the bay area thereby endangering swimmers, surfers, divers etc. This is a risk that the consultants acknowledge in their report. How can one say that you will monitor shark activity after the event? Evidence from other fish farms abroad acknowledge that sharks are attracted to the fish cages and pose a severe risk.

4. The Humewood area falls directly beneath the flight path of aircraft coming in to land at the airport. This could pose a serious threat to aircraft from seabirds, especially at harvest time.

5. Port Elizabeth is known as the most windy city in South Africa and experiences severe gale force winds periodically. These storms could ultimately result in the cages breaking loose from their anchors and landing onto the beaches, meanwhile the fish will no doubt escape into the wild, posing the threat of diseases to wild fish species.

6. Anchovies, sardines and bait fish, which are the main food sources for our endangered African penguins will be depleted in order to manufacture fish pellets to feed the fish farms. This will negatively impact and threaten the endangered African penguins which already have to swim very far to get enough food to feed their young. The African penguin population in Algoa Bay has plummeted dramatically since the 1970s because of this problem as these fish stocks are being harvested in the bay and exported worldwide. These fish stocks have also been harvested to almost extinction along the west coast of South Africa.

7. The high levels of E.coli at Algoa 6 site render it unviable where there is currently an oyster farm (next to the harbour). The Metro discharges sewerage and industrial waste into the sea at various points within the bay. The Algoa 6 site is located near the mouth of the Papenkuils River where there are usually high levels of industrial and human waste (see as reference the work done by Dr E Schuman). This site has had to close for extended periods due to high levels of E.coli and some of its products banned in European markets, hence any extension of this site for bivalves runs the same risk. More alarmingly, the Metro last publically released the E.coli results of the water quality in the bay over 20 years ago and don’t do so anymore.

8. The new site at Algoa 7 (between St Georges Strand and Coega) has not been extensively researched and the consultants are relying on the research done at other sites in the bay. In addition, the communities at Blue Water Bay and St Georges Strand have not been consulted or invited to submit their comments on these developments.

9. The consultants have somehow missed the importance of the squid nursery which Algoa site 1 will overlap.

It is my view that DAFF should rather be looking at hydroponics or aquaponics on land – farming lettuces and other greens above, with fish below the water. This is sustainable organic farming and would provide food and job opportunities for far more than the projected 1,300 job opportunities with all the other attendant negative effects of an ADZ located in the bay. There is ample space for this kind of development at Coega and could become a thriving industry.

Yours sincerely

______

GAIL PULLEN (MS) 082 334 3480 (Sent electronically)

Dr. S. Parker-Nance Summerstrand Port Elizabeth 28 April 2019

Comments following the pre-application Basic Assessment Report (pre-BAR) of March 2019 on the proposed Algoa Bay Aquaculture Development Zone as contained in the DAFF’s new Basic Assessment (BAR) process.

Statement

The continued persistence to establish aquaculture zones in Algoa Bay without regard for numerous expert studies showing numerous negative impacts on environment and the current users of the natural resource is troublesome. If study after study indicate that, not only will you most probably alter the natural environment, but also due to this endanger current users of the resource, or prohibit continued use of the resource by degrading the economic value of the resource, endangering lives all in favour of the development of open cage finfish aquacultures zone in Algoa Bay, is irresponsible. All indication, both weather conditions (high swell and wind) and natural process (harmful algae blooms and rapid temperature fluctuations), financial feasibility study and preliminary limited social-economic investigation (a reliable actual social-economic study has not been done due to lack of funds), is not a good idea nor sensible one.

In this document I basically reiterate the obvious but in so hope to highlight the many challenges and possible effects this development might have on Algoa Bay, its people and its natural environment. The bay, as in many place in our country, has a very high unemployment percentage and job creation is at the foreground. Care should however be taken that a new endeavour considered marginal in its economic feasibility does not, in net balance, cause job losses in other sectors that already exist.

It is also strongly suggested by all previous studies, reports and information on cause and effect of finfish farming within Algoa Bay that it may have significant impacts on the environment although new amendments made to the Regulations promulgated in terms of NEMA (as amended by Government Notice R326 in 2017) state that all aquaculture activity in the ocean, no matter what the perceived impact, does not need an Environmental Impact Assessment and only Basic Assessment (see as defined in LN2).

The major shortfall of the current BAR are: i) the lack of site specific information (the use of proxy site information), ii) not taking into account effect on neighbouring environments (not understanding the connectivity of habitats and organisms within the bay, iii), largely ignoring the role wind plays in the windy city, iv) understanding large predator movement and possible trophic shifts as well as changes in species distribution and movement within the bay as a result of finfish farming and v) lastly and most alarming ignoring the comments and concerns of many stake holders on various social economic aspect because there are no funds available to gather the information. The absence of a comprehensive social-economic study for all sites proposed and it especially taking into account the possible loss of income and jobs in other sectors due to this development is imperative.

Background and introduction

A number of possible areas were identified as possible aquaculture zones within Algoa Bay.

Figure 1: Proposed aquaculture sites in Algoa Bay.

Diagram 1 give a short synopsis of the process to a) identify, b) obtain authorisation to establish aquaculture zone within Algoa Bay. The initial process was halted by an appeal process that included 28 valid appeals (I don’t know what an invalid appeal is, I don’t know if the number or reason for classifying an appeal invalid was ever communicated to the public) and an objection petition by the public of more than 17 000 individuals.

Diagram 1: Summary of kay event and decision on the establishment of Aquaculture Zones in Algoa Bay.

2009 National SEA for finfish

2010-2014 S&EIR

Environmental Authorisation for July 2014 Algoa 1

October 2014 Appeal

Outcome Minister suspended authorisation to August 2015 of the allow for additional studies Appeal

Outcome of the October Appeal process (as per communication LSA138222 from the Minister of Environmental Affairs of SA)

The following statements were included in the Appeal Decision given by the late Minister of Environmental Affairs Mrs Edna Molewa:

The new allocation includes two sites in addition to Algoa 1 neither considered as feasible in the original EIA. The comparison between Algoa 1 and Algoa 5 showed both sites with low economic feasibility.

Development of Aquaculture Comparative 2016 at Algoa 1 NOT Economically expert study feasible

The 2016 comparative study between Algoa 1 and Algoa 5 include an Economic feasibility study by Britz and Sauer (2016b)

Algoa 1:

 Marginal for economic aquaculture and limited mitigation is possible  NOT economically competitive and therefore economic feasibility is low

Algoa 5:

 Sub-optimal for economic aquaculture and mitigation measures would be impractical or uneconomic to implement which rendered the proposed site not economically competitive

However, DAFF STILL INTENTS TO TAKE Algoa 1 forward into the current application process for environmental authorisation, EVEN WITH EXPERT STUDY INDICATING AT BEST MARGINAL ECONOMIC feasibility. DAFF has identified two new sites to be included in the EIA process and intends 2018/2019 to submit a new application for Environmental Authorisation in terms of the 2017 NEMA EIA Regulations.

DAFF intends to declare an ADZ for farming finfish and bivalves (e.g. mussels and oysters including invasive species) in Algoa Bay and are considereing Algoa 1, Algoa 6 and Algoa 7

DAFF intends to apply for Option A:

Table 1: Copied from BAR document - Pre Application p. 27.

Figure 2: Aquacultures zones under consideration.

The Basic Assessment Report (replacing an Environmental Impact Assessment) incorporates:  Marine specialist study 2019 (Algoa 1, 6 & 7)  Dispersion modelling and habitat mapping 2019 (Algoa 1, 6 & 7)  Maritime and Underwater Cultural Heritage Impact Assessment2019 (Algoa 1, 6 & 7) (ACO Associates)  Comparative Assessments (Rhodes University 2016) (Algoa 1) o Socio-economic Report o Ecological Report o Feasibility study  Marine specialist study 2013 (Algoa 1)  Visual specialist study 2013 (Algoa 1)  Socio-economic specialist study 2013 (Algoa 1)

Specialist studies concluded that:

AlgoaADZ_Pre-appBAR_AppD_2016_SE-Report_3 3.4.3.2 SWELL EXPOSURE: “Maximum significant wave heights of 5m were however recorded at both sites, and wave heights of up to 6.5m have been recorded in Algoa Bay (Anchor Environmental 2013; Roberts, 2016). Both sites are equally exposed to Easterly swells. Thus, while Algoa 1 is more conducive for aquaculture operations in terms of average swell, both sites will require similarly specified cage and mooring systems to withstand the maximum significant swells. In comparative terms, Algoa Bay is thus much more exposed to swell than other aquaculture industries based on cage aquaculture, for example, the sea bass culture in the Mediterranean, and salmon in fjords in Chile and Norway. The high swell exposure places Algoa Bay in the commercially experimental “offshore cage aquaculture” category requiring a much higher (and more expensive) equipment specification.”

AlgoaADZ_Pre-appBAR_AppD_2016_SE-Report_3 3.4.3.3 WIND EXPOSURE: The high wind exposure of Algoa Bay severely limits the number of operational days at sea. A guide to sea conditions for operating small research vessels in Algoa was compiled by the South African Environmental Observation Network (SAEON) based on five years of wind and swell data (Figure 1, Table 3). Small research vessels performing day trips from Port Elizabeth harbour do not work under ‘poor’ and ‘caution’ conditions. Similar size vessels would be used for pilot aquaculture operations; however larger vessels would be required for commercial operations. The high percentage (ca. 50%) of ‘poor’ and ‘caution’ sea days characterized by wind speeds of >14knots thus places a severe operational constraint on servicing cage farms in the Algoa 1 and Algoa 5 ADZs. This is confirmed by the experience at the Irvin and Johnson pilot cage culture operation adjacent to the Port Elizabeth harbour in Algoa Bay, where 95 sea days were missed in a 12-month period due to unsuitable weather (G. Le Roux, 2016 unpublished data). Unscheduled breaks in cage servicing schedules increase the risk of fish escapes, bird predation through torn top nets, mass fish escapes from unmaintained cages, predator attraction and health problems as a result of not removing mortalities. As fish require daily feeding, and staff has to have safe operating conditions, larger and more capital-intensive vessels and automated feeding systems would be required to operate effectively and economically. Cage nets need to be changed one a month, and thus on a farm consisting of 50 cages, vessel capacity to change 3-4 nets would need to be changed on each operational sea day.

AlgoaADZ_Pre-appBAR_AppD_2016_SE-Report_3 3.4.3.4. WEATHER IMPLICATIONS FOR CAGE FARM EQUIPMENT SPECIFICATIONS “Kob requires daily feeding to achieve economic growth and skipping one or two days has been found to significantly reduce growth rates and food conversion ratios (Guy and Smith, 2016). As small craft cannot operate safely 50% of the time in Algoa Bay, this means that the only alternative to effect daily feeding is the use of larger ships out of Nqura Port on which crew can live aboard (Figure 2). The capital cost of such vessels would only be justified by very large economies of scale.”

AlgoaADZ_Pre-appBAR_AppD_2016_SE-Report_3 3.4.3.4 RED TIDE: “Periodic red tides caused by dinoflagellate are a potential threat to the viability of cage aquaculture in Algoa Bay. The now defunct Marine Growers Abalone farm next to the present Nqura Harbour suffered heavy stock losses during two dinoflagellate (species not unidentified) blooms in January 2000 and again in January 2001 (Muller, 2001). The recent extended (December 2013-March 2014) red tide event of the dinoflagellate Lingulodinium polyedrum along the East coast and in Algoa Bay is of particular concern for the viability of cage aquaculture.

From an investment perspective, the production risk and uncertainty associated with red tide events renders suitability of the both Algoa 1 and Algoa 5 for cage aquaculture as very low.”

AlgoaADZ_Pre-appBAR_AppD_2016_SE-Report_3 3.4.3.5 TEMPERATURE “A further temperature effect affecting the viability of kob aquaculture in Algoa Bay is the occurrence of upwelling events in Algoa Bay, which can result in rapid drops in water temperature of the order of 7°C within a matter of hours during East wind conditions prevalent in summer (Roberts, 2016). This is highly stressful for kob and was identified as a problem affecting their performance in the I&J-DST pilot cage culture project undertaken near Port Elizabeth harbour (G. Le Roux, pers comm., 2016). A kob mortality rate of 45% occurred over the one-year trial.”

The above conclusions are based on past events, collected data and facts and it not based on speculation and is not conducive to mediation of these environmental conditions. The facts and data show that Algoa Bay is not conducive to finfish aquaculture due to the marginal economic feasibility, severe swell and wind conditions and periodic harmful bloom events.

The biggest selling point for aquaculture development in Algoa is job creation however in the AlgoaADZ_Pre- appBAR_AppD_2016_SE-Report_3 3.6 EMPLOYMENT: “The present review (Section 2.3 above) of the Final EIR Socio-economic report (Bloom, 2013) revealed that the projected number of jobs projected was speculative and unrealistically high. Direct employment in the production component of an offshore farm in Algoa Bay is expected to be roughly 50 employees for a 1000t/annum pilot scale operation (1 employee per 20 ton) and 80 employees for a 3000t/annum commercial unit (1 employee per 37.5 tons). Further employment opportunities could present themselves in services and value adds, with the most significant the increase in processing workers within Fish Processing Establishments to absorb the extra fish production for the region. The actual number of employment opportunities is difficult to estimate as the existing industries in the region will most likely be able to meet the demand for services in an initial marine aquaculture development phase. Service industries will scale with the development of the sector and success from the first commercial operator will signal whether the industry has a viable future. Services could include boat maintenance, net manufacturing and repairs and commercial diving. Initially however, most services required for a pilot scale operation could be supplied by existing businesses. A figure of one direct on farm employee to one service sector employee has been suggested as an approximation of indirect jobs (Britz, 2014). Thus 100 total jobs for a 1000t production unit and 160 for a 3000t unit are projected.”

From the above one can conclude that: It is believed that exiting industries in the region will most likely be able to meet daman – SO NO NEW JOBS will be created.

Current concerns and understanding of shortcomings of feasibility and impact studies conducted.  The economic feasibility that conditions at Algoa 1 are marginal for economic aquaculture.  Marine, visual and social-economic specialist identified potentially significant impacts on other users and users at Algoa 1 site.  Algoa 6 is to me located between the Port Elizabeth harbour for approximately 4.8 km along the shoreline in 5-12 meter of water opposite the months of the heavily polluted Paperkuils and Swartkops Rivers as well as the effluent pipe from the Fishwater Flats sewerage works (Figures 3 and 4). How would this influence the quality of the shell fish farmed, would it be fit for human consumption? (AlgoaADZ_Pre-appBAR_1 p. 53).

Figure 3: Mouth of the Paperkuils river delivering polluted effluent into the nearshore, Algoa Bay in close proximity to Algoa 6. Dates are indicated on the images.

Figure 4: The pipeline connecting the Fishwater Flats sewerage treatment work to the nearshore close to Algoa 6 (the colour of the water around the end of the pipeline does not suggest partially treated water but looks like raw sewerage) Dates are indicated on the images and as one can see a long standing policy and not a single event.

Table 2: See per-application BAR document p. 56 - Effluent discharge in to Algoa Bay.

 How would antifouling strategies and treatment of fish in the enclosures effect the wild fish populations? Many of the sparid species (popular angling fish such as Red Roman, White Stumpnose) are considered threatened or vulnerable. How would pollutants and pharmaceuticals influence the fitness of wild population of fish in the bay? Especially in Algoa 1 where the aquaculture activities will take place next to Endangered Reef System (NBA 2011).  How will the current distribution of marine predators change?

Figure 5: Dive sites (reef systems) in Algoa Bay.

 What is the loss of income if the recreational fisheries in Algoa Bay decrease or collapses? This would include loss in sale of fishing equipment, boats and loss of employment due to the decrease of this natural resource.  Impact assessment for Algoa 7 was not done and BAR consider is similar to Algoa 5 (proxy site).  What would the effect of pollution due to large shipping activity and Bunkering be on fish held enclosures (fish cannot swim away from pollutants) at Algoa Bay 7.  What would the effect be of upwelling, influx of very cold bottom water, which occurs regularly at Algoa 1 be? Fish cannot avoid the large temperature fluctuation – mentioned as a concern in the BAR – but does not discount Algoa 1 at possible site.  The BAR states: “The Mediterranean mussel is already established in Algoa Bay (see DAFF report nr 1817/1 by Dawson et al. 2019), and therefore the specific risks of alien invasive introduction of the species to the Bay is negligible.” This should be followed up on as I could not find any information on the Mediterranean mussel in Dawson et al. (2019). NB. Preventing further introduction and spread of invasive species is a Priority Action listed in NBA (2011)  This statement in the pre-application BAR is extremely worrying: “Should any future finfish cage operation use frozen fish food at any stage of the production however, there is a small but potentially highly significant risk of disease introduction that could decimate small pelagic stock” this would be devastating for to local economy and the job loss and ripple effect of something like this would not only see effect on the citizens of Algoa Bay but many wild fish species that depend on this food source. It would not only effect the pelagic fisheries but also the entire system, with an associated increase in phytoplankton that it not consumes will initiate a large devastating harmful bloom that will potentially kill a considerable number indiscriminately.  This also fuels another question: Where will the food for these farmed fish come from. Do we see increased stress on our pelagic stock to accommodate the need? Is there a fish meal factory on the horizon for Algoa Bay? Has the pollution impact of this been considered?

It should further be noted (from BAR p. 74) – Especially important at Algoa 1 where is it situated in close proximity of endangered reef systems (Figure 6).

 “Given that the study did not take cumulative effects into account, it is recommended that a precautionary principle be followed, especially when considering the potential scale of fish farm development proposed for Algoa Bay. In addition, should any therapeutic or antifouling chemicals used in fish cage culture operations reach the reefs at concentrations that are still effective (the Mead et al. 2009 study assumed a similar dispersal rate and distance as for dissolved nutrients), this would probably cause further deleterious impacts on diving reef communities. The Wright et al. (2019) study did not consider the dispersion or impacts of antifouling chemicals.

 Figure 6: Appendix 5 of the SEA document indicating location of Critically Endangered or Endangered habitat.

It is essential to ask:

How many jobs will be created and very importantly how many job will be lost in other sectors due to jobs created in this new untested sector.

How much financial gain will be made and who will benefit. The small business, the entrepreneur, people from Port Elizabeth? Or is it large business investments with majority of the money going elsewhere?

The only opinion poll taken relies on the personal perception of 154 people surveyed at Humewood Beach. Humewood beach (situated about 4km from Algoa 1) is situated further from the Algoa 1 then Hobie or Pollock Beaches.

There are a number of reasons for supporting the NO GO option in this Aquaculture application by DAFF.

 Strong wind and high wave conditions at all proposed sites  Harmful Algae bloom (HAB’s) or red tide  Current pollution levels in the Bay and effect of added nutrient  Bunkering activities and liquid hydrocarbon pollution  Possible harm to marine mammals and large predator species.  Transmittance of disease to wild populations  Effect of pharmaceuticals and antifouling on wild populations  Upwelling events that see a rapid drop in temperature  Low feasibility estimate  Job absorption and job loss  Safety to beach and ocean users  Protection of Critical endangered and endangered habitat  Prevent the introduction, establishment and spread of invasive marine species.

I would like to request that the following documentation be made available to the public:

Nel, P, and Winterm D. 2008-2009. Finfish Outgrowing in Sea Cages near the Port Elizabeth Harbour – Environmental Monitoring Programme Reports (1- 4). Prepared for the Department of Environmental Affairs and Tourism and Irvin and Johnson Pty Ltd.

CCA Environmental 2008. Final Basic Assessment Report for Irvin & Johnson’s Proposed Aquaculture Project, Mossel Bay. Prepared for: Department of Environmental Affairs and Tourism.

CSIR (2007): Environmental Impact Assessment for the proposed extension to the container berth and construction of an administration craft basin at the Port of Ngqura. Draft Scoping Report: Chapter 6 ‐ Marine Ecology, Sediment Toxicology and Dredging. Report prepared for Transnet, Durban

Shirley Parker-Nance

RA: Nelson Mandela University

29th April, 2019.

To whom it may concern Att: [email protected]

Lifesaving SA’s objection to placing Aquaculture Zones near bathing beaches.

Lifesaving South Africa’s mission statement states that we are the National Association for Lifesaving and Lifesaving Sport in South Africa. In these roles, Lifesaving SA leads, supports and partners with national and international organisations committed to drowning prevention, water safety supervision, emergency response and sport.

To this end, we have hosted our General Tire LSA National Surf Lifesaving Championships at Kings Beach, Port Elizabeth, for the past three years. This week- long event attracted 1780 competitors and an estimated 2500 supporters to Port Elizabeth from 24th March to 30th March this year. In tourism terms, this year’s event generated in excess of R51million into the Metro’s coffers.

Sadly, should the establishment of an Aquaculture Zone proceed off Port Elizabeth’s beachfront, we will have to seriously consider moving these championships to a safer venue in the years to come.

It is a known and established fact that “Fish Farms” attract marine predators, and Algoa Bays existing shark population will most certainly double or triple in size, which would have an enormously detrimental effect on the usage of the waters of Algoa Bay.

As a safety-based organisation, we will not be able to promote Nelson Mandela Bay, and more specifically Port Elizabeth, as a safe bathing and watersport destination. The increased presence of all predators, especially sharks, will make any usage of the Bay a high risk activity. LSA will be forced to move all our events elsewhere.

Furthermore, our Association promotes lifesaving as a sport to youngsters aged 7 and upwards, known as Nippers, and our trained lifesavers perform voluntary beach duties at seven beachfront clubs during the summer months. All these volunteers will be placed at risk whilst patrolling their beaches at Wells Estate, Bluewater Bay, Brighton, Kings Beach, Humewood, Hobie and Pollok beaches.

Not only will our members be at high risk of possible shark attacks, other predators will also move inshore when all the fish feed and faeces are brought inshore by the various coastal currents. These local beaches will become polluted and both locals and visitors will start avoiding these beaches. Do we really want this to happen?

Tourism is one of the major industries within Nelson Mandela Bay, generating many thousands of jobs and millions of Rands into the local hospitality trade. Our Association is a major supporter of this tourism trade, as our trained lifeguards patrol beaches and pools frequented by locals and holidaymakers. Within the tourism trade, the PE beachfront beaches are touted as possibly the best in South Africa.

Should the Aquaculture Zones within Algoa Bay be approved, all local beaches will become high risk for bathing and all forms of watersport. Prevailing currents within the Bay are from south to north, with over 220 000 tons of sand passing the PE harbour mouth annually, headed towards the Sundays River dune-fields.

Regarding the three proposed Fish Farms: - The Algoa 1 site, between Flat Rocks and Kings Beach, will destroy the safe bathing image of the premier Blue Flag beaches, Hobie, Humewood and Kings Beach. Pollok Beach will be closest to the actual farm and will become the dumping ground of all excess food and fish faeces when the strong onshore easterly winds blow.

- The Algoa 6 site, alongside the Oyster Farm off North End, will destroy the safe bathing image of Brighton, Bluewater Bay and Wells Estate beaches, as the northward currents will deposit all the rubbish onto these sandy beaches.

- The Algoa 7 site, east of the Coega Harbour, will result in decimation of the endangered Penguin colonies on Jaheel, St Croix and Brenton Islands, as the increased shark presence will prohibit future growth of these colonies.

Whilst it has been suggested that 1200 jobs will be created through the establishment of these “Fish Farms”, we must note that many negative issues will arise, including: - Negative perceptions of PE as a watersport destination, including the loss of regional, national and international competitions - Loss of tourism revenue when holidaymakers realise the risks and dangers and go elsewhere for their summer beach vacations - Resultant loss of jobs within the tourism industry, which usually flourishes in the summer months - Easterly onshore winds will blow the smells of the fish and fish food onto the coastal areas, especially Summerstrand and Humewood. - Huge increases in the numbers of seagulls can be expected, resulting in extra mess along the beachfront dunes and beaches - Sightings of sharks close to the beaches will become daily occurrences, similar to what has happened in Plettenberg Bay, where the seal population has grown. - Whale sightings will become less during the whale season, as these mammals will most probably avoid the areas.

Our lifesavers provide services at most of the watersport events hosted in Nelson Mandela Bay, and many of these events will be forced to shut-down, or relocate to other cities, should the “Fish Farms” happen. Some examples include: - Our own General Tire National Surf Lifesaving Championships, currently hosted in the city where our sponsors manufacture General and Continental Tires. - Standard Bank Ironman attracts 2000 competitors and a world-wide audience - Jendamark Bell Buoy Challenge, which recently was the first round of the World Open Water swimming series. - City Lodges Three Beaches challenge, between Pollok and Kings Beach - Summer Triathlon Series - Aquelle Ocean Racing Series, attracting 600 participants fortnightly to Hobie - The Scuba Diving industry will suffer - Kite-Surfing, Hobie Sailing and Stand-Up Paddling will suffer - Surfing will suffer, with national contests at Pipe being placed in jeopardy - Surf Ski paddling will be placed at risk - Lifesaving Club activities at their beaches will become high risk, thereby increasing the risk of drownings along the beachfront.

To summarise, Lifesaving South Africa acknowledges that aquaculture zones can have their place in the ocean, but these must not be anywhere near to bathing and watersport beaches and areas. Sanity must please prevail.

Yours in Lifesaving

Stanford Slabbert Project Manager 082 9900 907

Port Elizabeth, 30th April 2019 The Algoa Bay Hope Spot

The Algoa Bay Hope Spot initiative intends to preserve the unique natural assets present in Algoa Bay by empowering the local community to contribute to marine conservation.

Algoa bay presents one of the richest marine biodiversity on the planet thanks to its climate and oceanic conditions favourable for large number of marine species. The islands in the bay host half of the global population of the iconic but endangered African penguins, and 70% of the vulnerable Cape gannets. These seabirds are decreasing dramatically in the rest of South Africa but are stable the bay. Many other endemic seabird species breed in the bay, which lead BirdLife International to declare the bay a marine Important Bird Area. The bay hosts charismatic species of cetaceans, including killer whales, southern right and humpback whales, and 4 species of dolphins. Its connection with Addo Elephant National Park makes it the only place on Earth where you can spot the big 7, a main tourism attraction. The bay also contains large numbers of endemic invertebrates, seaweeds and fish (such as santers or red romans), is a rare nursery ground for great white sharks, and southern right whales. The world famous sardine run also passes through the bay, feeding a whole suite of apex predators, and attracting international TV crews every year. Estuaries are one of the most threatened habitats in the country, and Algoa Bay includes four estuaries that feed the productivity in the bay with nutrients input, while providing nursery areas for commercially important marine fish and invertebrates.

The effect the fish farm will have on the Bay

All the ecosystems and species would be threatened by the development of an ADZ in the bay. The impact of fish fecal matter, antibiotics to caged fish, and the chemicals used in anti-fouling will fundamentally damage our rich local reef communities. Algoa Bay contains some of the world’s most diverse and colourful cold-water reef systems. To jeopardise local wild fish stocks and reef systems on the speculative possibility of an ADZ, is not a risk-adverse approach.

St Croix Island is the world largest colony of the endangered African Penguin. Populations of African penguins are crashing in South Africa due to a lack of food, and every single conservation effort is currently made to save their numbers. Algoa Bay is the last safe haven for them with stable populations (although not increasing). I am deeply concern that Algoa 7 ADZ will negatively impact penguins, as the associated pollution may likely drive their prey further afield from the penguins’ natural feeding habitat. As penguins are already threatened due to lack of food and local competition with industrial fisheries on their small pelagic prey, additional pressure has to be strictly avoided. In addition, I am concerned that the pelagic fish for the caged fish’s food pellets may be sourced locally, thereby strongly increasing the existing competition between the seabirds and the local fisheries (see further reading below). In that case, that local competition will also affect the Endangered Cape gannets, 70% of which are breeding on Bird Island in Algoa Bay, and the Endangered Cape cormorants. All three species are endemic to South Africa and their numbers are decreasing rapidly.

Regards,

Dr Lorien Pichegru Department of Zoology Institute for Coastal and Marine Research Nelson Mandela University, Port Elizabeth, South Africa. Honorary Consul for France in Port Elizabeth Algoa Bay Hope Spot chairperson email: [email protected]/[email protected] cell: +27 834878574

Further reading:

- Pichegru L, Ryan PG, van Eeden R, Reid T, Grémillet D, Wanless R (2012) Industrial fishing, no-take zones and endangered penguins. Biol. Conserv. 156: 117-125 - Crawford RJM, Altwegg R, Barham BJ, Barham PJ, Durant JM, Dyer BM, Makhado AB, Pichegru L, Ryan PG, Underhill LG, Upfold L, Visagie J, Waller LJ, Whittington PA (2011) Collapse of South Africa’s penguins in the early 21st century: a consideration of food availability. Afr. J. Mar. Sci. 33: 139-156 - Pichegru L, Grémillet D, Crawford RJM, Ryan PG (2010) Marine no-take zone rapidly benefit threatened penguin. Biol. Lett. 6: 498-501 - Ryan PG, Pichegru L, Ropert-Coudert Y, Grémillet D, Kato A (2010) On a wing and a prayer: the foraging ecology of breeding Cape Cormorants. J. Zool. 280: 25-32 - Pichegru L, Ryan PG, Crawford RJM, Grémillet D (2010) Behavioural inertia places a top marine predator at risk from environmental change in the Benguela upwelling system. Mar. Biol. 157: 537- 544 - Pichegru L, Ryan PG, Le Bohec C, van der Lingen CD, Navarro R, Petersen S, Lewis S, van der Westhuizen J, Grémillet D (2009) Overlap between vulnerable top predators and fisheries in the Benguela upwelling system: implications for marine protected areas. Mar. Ecol. Progr. Ser. 391: 199- 208

55 Paterson Road North End Port Elizabeth 6001

Reg No 003-528NPO .

30th April, 2019. To Whom it may concern

Email : [email protected]

Re: Objection to proposed Fish Farms off PE beachfront

On behalf of the Association for the Physically Disabled, also known as APD NMB, we hereby lodge our objection to the proposed Fish Farms that might be established off our coastline.

We have a large team at our premises at 55 Paterson Road, North End, as pictured below, and all our workers livelihoods will be negatively impacted by the enormously detrimental effect that these farms will have on the adjacent areas. Factories such as ours are close to the shoreline, and these fumes will permeate everything.

At APD NMB we have several unique departments that focus on different aspects of our day-to-day activities:  AbilityWear Work Centre  Ability Industrial Work Centre  Ability Social Services  AbilityCare Adult Day Care Centre  Ability Wheelchair Shop & Repair Centre  Ability Recruitment Centre

The proposed “Algoa 6” site is directly opposite our factory in North End, and our entire workforce of 92 people, of which 75% are disabled, and most come from impoverished households within Nelson Mandela Bay, will suffer.

Easterly winds are dominant at certain times of the year, and these onshore winds will blow straight onto our premises. The fumes will permeate into everything, including our stocks of materials and clothing, and we are most concerned that we will lose business when clients reject our manufactured products because of the fishy smell.

Please register us as an Interested and Affected party and acknowledge receipt of our objection. We hope and pray that sanity will prevail and the commercial interests of a few will not be allowed to destroy the livelihoods of so many.

Yours sincerely,

______Brian Bezuidenhout Executive Director 041 – 484 5426

MISSION STATEMENT To promote the advancement of people with disabilities so as to enable them to attain their maximum level of independence and integration in the community and to allow them to take their rightful place in society.

10/07/2019 Anchor Environmental Mail - AQUACULTURE ALGOA - IAP

Anchor Info

AQUACULTURE ALGOA - IAP 1 message

Wally Gray | REZCO Email address Redacted for the protection of personal Tue, Apr 30, 2019 at 10:45 PM information of I&APs To: [email protected] Dear Sirs/Madam, I am registering as an IAP regarding this project. My views are listed in this email: Wally Gray

To all concerned,

My submission is in green, and where I refer to the BAR report those are shown in black.

Algoa 1 is in direct major conflict with tourism and with the brilliant marketing that Port Elizabeth and the Eastern Cape has accomplished in a growing way over at least 10 years now.

Tourism is a major job creator and opportunity for SMMEs, and Algoa 1 will undo what has been accomplished. Quoting the BAR report: Situated on the shores of Algoa Bay the area also has a thriving tourist economy. The Cape Recife Nature Reserve, which is located on the peninsular of Algoa Bay, has a strong wilderness sense of place.

Many Cruise Liners call in at PE.

Tourism has a very high socio-economic impact. Fish farm in Algoa 1 is in direct conflict with Tourism.

Size Reduction is not a remedy: a Small problem in the heart of a Tourism Jewel undermines confidence & multiplies negative effects & outcomes.

Total numbers of jobs created by aquaculture is miniscule compared to job losses of negatively impacted undertakings & negative for future POTENTAL jobs from Tourism.

We agree with Nelson Mandela Bay Goal as Opportunity City.

Quoting the BAR report, which states: - Executing existing and designing and implementing new projects that competitively differentiate Nelson Mandela Bay as a destination city for business, tourism and investment. Agreed wholeheartedly.

Consequently, the proposed ADZ may be in conflict with other uses, however these should not be seen as mutually exclusive as changes in management/operations for all activities can allow for symbiotic relationships. The proper recognition & ranking of the negative impacts in Algoa 1 do not result in symbiotic relationships.

This statement following is not correct needs to be re-assessed & corrected:

https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-f%3A1632273321368049605%7Cmsg-f%3A1632273321… 1/6 10/07/2019 Anchor Environmental Mail - AQUACULTURE ALGOA - IAP Would the approval of this application compromise the integrity of the existing approved and credible municipal IDP and SDF? Both the IDP and SDF support the potential for sustainable job creation, sustainable environmental resources, and sustainable economic development and would therefore not be compromised by the proposed development. It would be compromised by Algoa 1. There are High negative impacts from Algoa 1, both short & long term. Why do something so very negative to Nelson Mandela Bay? Does not make sense at all.

Fish Farm in Algoa 1 is definitely not “Risk Averse.” It damages Existing Investment & Investor Confidence going forward.

Algoa 1 has very low economic feasibility Algoa 1 has low socio-economic impact. The economic feasibility study conducted by Britz and Sauer (2016b) found that conditions at Algoa 1 were marginal for economic aquaculture and limited mitigation was possible. Algoa 1 was found to be not economically competitive and therefore economic feasibility was found to be low (average score of 2.2/5) Socio-Economic Impact assessment and subsequent comparative study conducted in 2016 (Britz et al. 2016; Britz & Warwick 2016) has identified a number of Medium to High negative impacts, mostly related to user conflicts in the Bay, whereby major contributors to employment, and conservation may be negatively affected.

Why put a low productivity unit in a high risk area like Algoa 1? Your BAR statement that Due to lower productivity on the east coast when compared to the west coast, contradicts the viability.

At full production (assuming that the development proves to be feasible and scalable), the impact on local community development has been rated as low

What!!! In their review of the socio-economic specialist study of the previous EIA process, Britz et al. (2016) found limited support for the aquaculture projects claim to improve food security. The principle food for piscivorous finfish is pellets made from wild fish. It seems that a greater mass of wild fish have to be harvested than can be delivered as finfish product.

Bivalve culture….. constitutes a limited source of protein to South African previously disadvantaged communities.

Revenue is likely to be volatile, over the long-term.

Visual Impact: 1. extent of the impact caused by the project would be high 2. high significance given the importance of tourism for the city of Port Elizabeth. 3. Algoa 1 is expected to have a high visual impact on all receptors.

It is NOT ACCEPTABLE that DAFF proposes to farm in Algoa 1, IN SPITE OF & IN CONFLICT WITH 1, 2 & 3 above. Buffer zones are a poor solution to a bad proposal. I don’t agree with this next sentence at all: With mitigation, Algoa 1 was found to have a visual impact significance of moderate and very low for finfish and bivalve farming respectively BAR report itself shows very high negative impact Table 13, page 107 https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-f%3A1632273321368049605%7Cmsg-f%3A1632273321… 2/6 10/07/2019 Anchor Environmental Mail - AQUACULTURE ALGOA - IAP You can’t water down high negative impacts which are facts, by using “mitigating measures” which may or may not be applied. From your own BAR report: A mixed use waterfront development has been proposed for the south side of the harbour and Kings Beach Precinct, with the proposed plan including freight handling, - residential and tourist facilities, and commercial operations geared at increasing the economic development and financial sustainability capacity of Nelson Mandela Bay. All of these activities could be impacted by Algoa 1, Visibility of the project will extend several square kilometres and is defined as high (VRM Africa 2013). The BAR statement that follows is totally contradictory: Humewood beach is South Africa’s oldest blue flag beach and with the recent approval of the Addo MPA, Algoa Bay now balances conservation and environmental protection with economic growth fairly well. It can therefore be concluded that cumulatively, the proposed ADZ will not impact significantly on specialist tourism and recreational activities. This sentence is a direct contradiction, and is not true.

Mitigation measures regarding ship/boat lanes actually WORSEN the visual impact: • Clearly identified beacons and shipping channels must be identified in relation to the ADZ to assist vessels to navigate safely through the area. • Install navigational markers and lights as required by SAMSA regulations.

Declining real estate values WILL have a big negative effect on the economy in Nelson Mandela Bay: It is likely that real estate values in the area may decrease if there are multiple mariculture farms or similar developments that negatively impact on the sense of place

Algoa 1 is located very close to Summerstrand, a popular residential and recreational area. The infrastructure will be visible in the middle-ground area from the tourist receptors along the beach front of the Marine Drive area. Visibility of the project will extend several square kilometres and is defined as High (negative impact). Mitigation would involve the exclusion of the northern portion of Algoa 1 to create a three kilometre exclusion zone buffer from the beach front and a one kilometre buffer exclusion zone buffer around Bell Buoy (Bell SQ) (see Section 2.5.1). With mitigation, the impact would be rated as medium. This last sentence is absolutely not correct. There are no suitable mitigating factors. A Buffer Zone does not fix a wrong decision, nor will it fix declining property prices, nor will it fix a declining local economy.

In a number of cases, like scuba diving & others, the report combines a zone with a high negative impact with a zone with low negative impact, to conclude that the impact is low. That is illogical & totally incorrect.

This worsens the visual impact: The most effective and common mitigation measure is to install predator nets on the cages which prevents seabirds from gaining access from the air. In addition, visual deterrents (e.g. tori line type deterrents for birds) can also be installed. Image result for what does a tori line look like

The impact on whale and dolphin watching was also a particular concern in Mossel Bay where a mariculture project encompassing 36 finfish cages was proposed by Irvin & Johnson. What actually happened to this project proposed by a long experienced business? Did a commercial business like I&J, try it & failed? https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-f%3A1632273321368049605%7Cmsg-f%3A1632273321… 3/6 10/07/2019 Anchor Environmental Mail - AQUACULTURE ALGOA - IAP Why should this particular proposed venture succeed?

Aquaculture at Algoa 1 is CONTRARY TO OUR RIGHTS Chapter 2 of the Constitution of the Republic of South Africa (Act 108 of 1996) - The Bill of Rights Section 24 states that everyone has the right to an environment that is not harmful to their health or wellbeing; and to have the environment protected for the benefit of present and future generations.

In BAR report 8 Negative factors regarded as “Medium” are in fact “High”, which has a major impact on the relative scoring. [The 8 Negative factors are 1. Organic waste discharge…..> to 8. Income Leakage.].

No allowance has been made for rehabilitation measures, impacts or costs in the report.

A phased approach into an unsuitable area Algoa 1, is NOT A SENSIBLE SOLUTION.

DO IT IN THE RIGHT PLACE: While aquaculture contributes to almost half of the global fish supply, it contributes less than 1% of South Africa’s fish supply. The sector offers significant potential for rural development, especially for marginalised coastal communities.

Algoa 7 looks like to most sensible option. This site has undergone an internal feasibility assessment in which it was found to be suitable in terms water depth, shipping traffic, and accessibility (i.e. financial considerations). This site overlaps slightly with the recently approved Addo Marine Protected Area (MPA) but the Department of Environmental Affairs Branch Oceans and Coasts has indicated that the affected portion of this site could potentially be excised should Environmental Authorisation be granted for this precinct. The Department of Environmental Affairs has nonetheless made provision for an aquaculture area of 1000 ha within the proposed MPA (DEA, 2016).

The impact assessment of the alternative options provided by the applicant show that Option C has the lowest overall impact on marine ecology. Option C = Algoa 6 & 7. The impact of finfish culture at Algoa 7 is likely to have a low intensity and therefore is likely to constitute a very low impact after mitigation measures are implemented.

The COEGA SEZ is currently being developed, which includes a land-based Aquaculture Development Zone, which could provide infrastructure support to Algoa 7.

Option C would involve bivalve farming at Algoa 6 and finfish farming at Algoa 7, excluding Algoa 1 altogether and is the most favourable option from an environmental impact perspective.

Algoa 1 should emphatically not be done: SHARKS & PREDATORS It is clear that fish cages may provide a food reward to large sharks (that are potentially dangerous to humans) and in so doing alter their distributional and behavioural patterns. Certainly anti-predator nets are specifically designed to exclude large predators from entering the fish cages (and getting a food reward) and these are routinely used by fish farm operators https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-f%3A1632273321368049605%7Cmsg-f%3A1632273321… 4/6 10/07/2019 Anchor Environmental Mail - AQUACULTURE ALGOA - IAP as such predators are clearly attracted to the cages in the first place. Effective anti- predator nets lower the likelihood of sharks receiving a food reward from within a fish cage, but wild (and escaped fish) are known to concentrate around the outside of fish cage infrastructure that operate as Fish Attractant Devices (FADs).

Recent research suggests that the inshore areas of Algoa Bay are an important nursery area for white sharks.

There is a high degree of uncertainty regarding the threat to human bather safety associated with the development. It is probable that marine predators, such as sharks, will be attracted to finfish cages that may appear to be a source of food.

ACSA ACSA is concerned that aquaculture farms may attract birds and their aggregation would pose a risk to aircraft navigation. Algoa Bay has existing large sea bird colonies which perform daily migrations to and from the roosting sites and these flocks are likely currently passing Algoa 1. This is not the case with Gannets, of which there are large numbers near Addo. So fish farms will change this to detriment of aircraft flight paths. The confidence of the impact rating is, however, considered medium as no detailed information on bird flight paths (i.e. route and height) for the bird species that roost and forage in large flocks (i.e. cormorants, terns and gannets) specifically in Algoa Bay have been considered. However, given the scientific evidence regarding flight height of 25 sea bird species in the North Sea ……. One can’t use & extrapolate data from the North Sea & by guessing apply it to a significantly different environment like PE, particularly for highly important flight paths and risks to flights.

How will this be enforced? Feed must always be stored in closed containers on the maintenance vessels. It is in the interest of farmers to ensure that their stock or feed is not predated on by birds.

Report assumes that mitigating measures will be implemented & adhered to. What track record? Who enforces? What cost?

FISHING & SHIPPING LANES: Algoa 1 has therefore not been assessed for with respect to drifting of anchored ships into the site. It lies within the movement area of the squid fishing vessels which move often through the Algoa 1 area depending on fishing conditions & winds. It’s a mistake to conclude that it does not affect squid fishing vessels. Stakeholders expressed concern regarding the southern part of Algoa 1, which overlaps with the squid breeding area frequented by current fishermen. As breeding areas provide for the best catches, the establishment of a fish farm in the same area will most likely have a significant impact on the local squid industry. https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-f%3A1632273321368049605%7Cmsg-f%3A1632273321… 5/6 10/07/2019 Anchor Environmental Mail - AQUACULTURE ALGOA - IAP

Negative effects on current Fishing: Fishermen in the Algoa Bay area are already suffering from the dwindling supply, limited resources, recently approved Addo MPA, and will not be able to endure further restrictions. There is also a concern that the supply of cheaper fish could force out competition from the traditional boat based fishing companies. Plus the statements on page 131 regarding the fishing industry are contradictory. -

This statement is factually not correct: After mitigation measures are implemented, none of the alternative options have high negative impacts on the socio-economic environment.

The ratings & rankings in Tables 36 & 37 are subjectively biased & should be rigorously re- assessed. Page 142

Table 43 on pages 150 & 151, a number of high impact/high risk factors you state become medium or low. This should be rigorously reviewed. Same applies to table 44.

Definitely disagree with the softening of the high negative/high risk aspects becoming medium or low by subjective mitigating factors.

General comment: One should not promote a project of this nature with significant impacts based on premises like “may” or “could” or “usually” or “likely”. This indicates high risk & low probabilities, or just plain guessing.

WJH Gray MBL Cum Laude, B Sc Eng.

Rezco Collective Investments Ltd is an FSB approved Unit Trust Management Company. Please click on the following link to read the Rezco legal notice: http://rezco.co.za/email-legal-notice/. Preserving Capital* & Creating Wealth. *While the portfolio manager will attempt to minimise risk, it is possible that the investor could incur losses, including the loss of principal invested.

https://mail.google.com/mail/u/1?ik=8b3f0d477d&view=pt&search=all&permthid=thread-f%3A1632273321368049605%7Cmsg-f%3A1632273321… 6/6

Sustainable Seas Trust PO Box 77 Kenton-on-Sea 6191 South Africa

www.sst.org.za ; [email protected] ;  083 640 1588

Date 24th April 2019

State who you are: Dr A J Ribbink

Whom you represent; CEO Sustainable Seas Trust

The effect the fish farm will have on you/your business/Algoa Bay in general Our research with Norwegian laboratories on microplastic associated and other toxins has shown that sea-food from Algoa Bay may have five times the safe level for human consumption in the tissues after only six months. This suggests that bivalves and fish grown in the proposed fish-farm will be unfit for consumption in South Africa and will not be accepted in the export market.

The changes you want to see in the application Either a full analysis is undertaken with us and internationally recognized laboratories in Norway to thoroughly and independently investigate the issue or the entire endeavour to have a fish farm in Algoa Bay is abandoned, which is probably the sensible route.

Your contact details [email protected] ph 083 640 1588

The Sustainable Seas Trust is registered as a charitable, non-profit, public benefit institution. Trust Registration: IT 2203/ 2006 South Africa | NPO Number: 078-120-NPO | PBO Number: 930022444

Andrew Pritchard 18 Bournemouth Street Summerstrand Port Elizabeth 082 901 1147 [email protected]

To whom it concerns

SEA-BASED AQUACULTURE DEVELOPMENT ZONE ALGOA BAY. EASTERN CAPE (project 1808).

I wish to register as an interested an affected party for the SEA BASED AQUACULTURE DEVELOPMENT.

I am a resident in Summerstrand and believe this development will have an impact on myself and the value of my properties in Summerstrand.

I am also a voluntary lifeguard at Summerstand Surf Lifesaving Club and daily user of the sea and believe this development will impact on my safety and the quality of the beaches.

I object strongly to the project on the following basis:

This development will Impact on the natural beauty and cannot possibly be described as an improvement on the scenic, aesthetic quality of our beachfront.

The impact on tourism cannot be positive. Whoever went to a coastal town because they had a fish farm. We have thousands of kilometres of coastline that are not adjacent to swimming beaches and residential dwellings, why not use these areas.

Property prices will be affected. I have two properties that look out over the Pipe surf area. Who will want to buy a flat that looks out on a fish farm and who will reimburse me for the lower price I would get when selling these properties? There will be an increased fishy smell.

The impacts on the marine and coastal environment. The natural balance of the ecosystem will be affected. The food not eaten by the fish in the farm will attract more fish followed by more sharks.

Increased shark activity is inevitable

The water quality will be affected. The fish faeces will be in a greater concentration. When the south-easterly blows this concentration of faeces will be deposited on our beaches.

More pollution on our beaches. The more boating with fishermen will lead to rubbish being deposited in the water (packets, plastics etc)This will not improve tourist industry and the beautiful beaches that attract visitors. As a paddler who regularly paddles on a surf ski to the lighthouse and back there will be more boating activity in this area which increases the probability of boating accidents. I will be under greater risk of being injured.

According to marine biologist there is a good chance this development will increase the occurrence of red tide.

It is for the above-mentioned reasons that I oppose the location of the fish farm, specifically the site close to the Pipe surfing area.

;rs

Andrew Pritchard

☏ +27 (0)41 374 4444  +27 (0)41 374 2444  www.bellbuoy.co.za

• Community Housing and Commercial Property Administration • A Member of the National Association of Managing Agents • Rentals and Sales • Registered with the Estate Agency Affairs Board • Financial Administration • Registered with the Council for Debt Collectors

Tuesday, 30 April 2019

ANCHOR ENVIRONMENTAL CONSULTANTS (PTY) LTD

Email: [email protected]

Dear Sirs

OBJECTION TO PROPOSED SEA-BASED AQUACULTURE DEVELOPMENT ZONE – AMADADA HOA

We write in our capacity as Managing Agents and at the instruction of the Excom of the Home Owners Association of Amadada.

The Excom note with concern that the proposed fish farm is being reconsidered and that one of the sites being considered is located off of Port Elizabeth’s main beachfront area. The Excom hereby note their request to be listed as an Interested and Affected Party, please use the email address [email protected] for all future correspondence.

The Excom would like to advise that on behalf of the Amadada HOA, located in Happy Valley Drive, Summerstrand, they formally object to the fish farm being located in the proposed Algoa Site 1, and note that although the below list is not exhaustive it does detail a number of concerns that the HOA has:

• It will have a significantly negative impact on our tourism; • Port Elizabeth has built itself as a water sports centre in South Africa and each year there are holiday makers and overseas tourists who come to Port Elizabeth for the activities available on our beachfront, these activities may be severely affected by the fish farm. Even if the activities themselves are not directly affected, the perception of Port Elizabeth as having warm, clean and safe sea waters will be severely affected and this will result in a decline in tourists seeking these types of activities • There is potential for the sea water around the farm to be polluted and potentially affect other marine life • Increased debris and pollution from this farm will make its way to our shore; • There may be smells emanating from the farm which will be blown onshore in the easterly wind direction • Port Elizabeth is currently trying to clean up our beachfront area by removing the coal terminal and the fuel tanks, and this just flies in the face of that exercise, and will replace it with another problem

Please contact the writer should you have any queries.

Yours sincerely THE BELLBUOY GROUP

HENNIE MARAIS Property Portfolio Manager e-mail: [email protected]

Copies: Amadada Excom

Bellbuoy (Pty) Limited t/a The Bellbuoy Group - Company Registration No. 2012/019786/07 VAT Reg. No.4170168118 - Debt Collector’s Certificate No.0049099/11 - NAMA Membership No. 1001 Non-Executive Directors: GS McWilliams, MC White / Executive Directors: S Moore-Barnes, C van Heerden P O Box 7660, Newton Park, 6055 - 1st Floor KPMG House, Norvic Drive, Greenacres, Port Elizabeth 6001

DATE: 30 April 2019

From: Earl Ingram (Chairman)

RE: Fish farming in our bay

We Lifesaving Nelson Mandela Bay are totally against fish farms in the bay.

We have 7 clubs affiliated to Lifesaving Nelson Mandela Bay from Bluewater Bay through to Sardinia Bay and all clubs will be affected by fish farming.

Fish farming in the bay will have a negative effect on the sport of lifesaving and any open water swimming event in our district. It is clear that fish farming will attract sharks to close bathing proximity in the bay. The possibility of shark attacks on our members will increase dramatically.

Lifesaving Nelson Mandela Bay has hosted very successful National champs in the last 4 years with the municipality already committing to sponsor the next 3 years. This has been positive for the tourist industry and the community of Nelson Mandela Bay. Fish farming in the bay will result in the loss of these events.

No fish farming in the bay please. Consider other areas but not in the Bay.

Yours in lifesaving

Earl Ingram Chairman

Cell: 072 525 6221 Office: 041 994 5273 Email: [email protected]

President: V. Woodhead, Chairman: E. Ingram, Vice Chairman: Ant Cocks, Treasurer: Ian Mac Gregor, Chief Examiner: Ant Cocks Competition Officer: C. Meintjes, Development Officer: C. Plaatjies, Media Officer: A. Cain, Secretary: G. Ingram 29 April 2019

Francois Gaus CHAIRMAN

SUMMERSTRAND SURF LIFESAVING CLUB

Regarding the Proposed Fish Farm Proposal offSummerstrand (Pollock Beach)

My biggest concern is safety first and foremost to our bathers and our members in the form of nippers and active lifeguard doing voluntary patrol in our waters and beaches. The shark activity will no doubt increase if this project gets the go ahead.

Pollution on the breaches and sea (reefs) itself with excrements from the fish in the proposed cages washing up on our beaches.

The amazing view we currently have of the Be11Bouy and open sea will be obstructed.

Our training ground will be affected, we use this area between Bellbouy, Cape Receive Lighthouse and the Pier as our prime training ground, from swimming, surf ski paddling and Malibu board training. (Shark activity ???)

To mention the other sports activities we involved in as safety officers from Bellboy swimming event, Zsports swimming, diving, triathlons, biathlon's, surfing events, lifesaving events, kids parties, nippers, water safety programs, visitors from various countries and general public recreational swimming and body surfing. This is just to mention a few!

We say NO to the proposed area in front of Summerstrand.

Kind Regards

Chairman

PRESIDENT Dave Collins f CHAIRMAN Fanta Gous I CLUB CAPTAIN Shane Stevens SECRETARY Maurice Millard, E-MAIL [email protected], MOBILE 079 387 9823 ADDRESS PO Box 13418, Govan Mbeki, Port Elizabeth, 6000, WEB www.sslsc.co.za EVENT BOOKING Maurice Millard, E-MAIL [email protected]

ESTABLISHED 2 Shiraaz Villas Frans Street 25 MAY 1958 Parkside PORT ELIZABETH 6020 [email protected] 29 April 2019

Dear Sir/Madam

To Whom It May Concern

Lifesaving clubs are voluntary organisations who act on behalf of the city and the country as custodians to water safety and water safety awareness.

Concerns around the fish farm along the NMB Beaches are as follows: - chemicals used in fish farming to fight off parasites essential for the farming practices are harmful & lethal to the environment, organisms, mammals, birds and fish - interferes with public training route and run off of any chemicals can affect human health given it's proximity to public bathing areas.

We have also investigated further into fish farming practices that we don't object to sustainable and responsible fish farming, we do object to placing these farms so close to public bathing areas.

The public are given opportunities to raise their concerns and objections, let's hope that our voice isn't ignored and that the public's interest is put first.

Regards

HBSLC Chairman Aston Cain

(electronic mail)

Chairperson Vice-Chairperson Secretary Treasurer Nipper Officer Aston Cain Marc Anthony Williams Achmat Ellie Lee Thomas Phillip Campher 0787290855 0606056506 0711803567 0731870357 0829517921

Objection to Algoa Bay Aquaculture Development Zone 1. The negative (socio-economic) impact on human use of ocean resources and subsequent impact on local business A condition of the suspension of the appeal in 2015, the Minister was clear that DAFF (the applicant) had to do a “detailed analysis of the projected revenue and employment opportunities likely to be created by the proposed project, measured against the perceived loss in revenue and employment opportunities as a result of the proposed project at Algoa 1” (see 4.2.2. Appeal decision LSA 138222 pg) This has not been done. While the “likely jobs created” assessment was revised and drastically reduced from over 90 000 jobs to just over 1000 jobs the “likely jobs lost” assessment was not done.No one has approached the current users of the bay as a tourist destination. This being B&B’s, Hotels, Restaurant’s, event organizers, tour operators. Has the city been consulted about the loss of the revenue and jobs created by events such as the Iron Man, and the Bell Buoy swim, which is now part of the first leg of an international swimming event? There are numerous surf competitions, which will also be affected. What about the local scuba diving industry? Has anybody counted the “jobs lost” and the “income to the city lost” ? We were informed at the meeting on the 6th March 2019 in the city hall that no Local business will be involved in the manufacturing, installation or maintenance of the Fish Farm Also from the minutes of this meeting on page 9 – ‘to quantify exactly how many local jobs will be created is not possible at this stage’ . It is of utmost importance that there is an assessment of jobs lost.

2. Algoa 1 isn’t feasible as per the pre-BAR’s own specialists and Algoa 7 hasn’t been evaluated in full. The economic feasibility study (Britz and Sauer 2016) that informs the pre-BAR, finds that the conditions at Algoa 1 are marginal for economic aquaculture and limited mitigation possible. The BAR’s visual impact assessment excludes a major portion of the northern section of Algoa 1, and its socio-economic study finds that the southern portion of Algoa 1 overlaps with a squid nursery area and excludes that portion. The BAR refers to this as an “apparent conflict” and proposes a phased approach (a 1000-ton start-up) with careful monitoring to mitigate. Who will do the cleanup once There is a much simpler conclusion to be drawn, namely that the three reports indicate that Algoa 1 is not feasible in its entirety. Algoa 7 hasn’t been evaluated in full: The newly added site, just off Ngqura harbour, has not gone through the same detailed assessment process as the other sites. The pre-BAR uses Algoa 2 and Algoa 5 assessment data. This is completely unacceptable, as it does not assess the impact on the Blue Water Bay and St Georges Strand community. This community has not been consulted. This area is also a popular stop for whales along our coast. Submitted by Janet Townsend [email protected] Mobile: 0829402131

ZWARTKOPS CONSERVANCY

P O Box 75 • Swartkops • 6209 • Republic of South Africa

PBO 930029083. NPO No.:102-935-NPO

Comments on the proposed Algoa Bay Aquatic Development Zone as contained in DAFF’S new Basic Assessment Process.

The Zwartkops Conservancy is opposed to Algoa 1, 6 & 7 fish farms for the following reasons: These fish farms will affect tourism adversely as Nelson Mandela Bay beaches are known to be safe for swimming, snorkeling, diving, eco tourism & sport events like Iron Man. Fish farms will attract sharks to them. In addition the uneaten fish food and faeces will pollute the water and beaches. There are 3 Blue Flag beaches near Algoa 1 – we cannot afford to lose them. In addition Algoa 6 is near Brighton Beach and Algoa 7 is near Wells Estate & St George’s Strand Beachs all very popular with township residents. In between both sites is Bluewater Bay Beach which is also popular & there is a well established and respected Life Saving Club which does a lot of training and holds national competitions. These would all be adversely affected. Have all these communities been informed of the proposed fish farms near them and consulted? The choice of position for Algoa 6 is unwise as there is bad pollution here from industries at times when Fish Water Flats WWTW malfunctions. In addition waste water from industries along the canal flow into the canal which is considered to be always polluted. This will all come out where the fish farm is! Algoa 7 is right at St Croix Island home of the endangered African Penguin colony. Pollution & increased numbers of sharks will critically endanger them. How will both Algoa 6 & 7 affect the Swartkops Estuary which DEA has declared as a National Project to clean up and save? The Swartkops is a very important nursery for the sea where young fish etc come for part of their life. If it is harmed it will affect fish populations in the sea. With Climate Change storms are proving to be stronger and more violent. This could cause the fish farms to be broken up and destroyed. Would it not be better for the environment, especially the declared Algoa Bay Hope Spot, if there was land based aquaculture?

Jenny Rump Retired Environmental Officer Zwartkops Conservancy 0828530700

Formerly ZWARTKOPS TRUST (Est 1968) www.zwartkopsconservancy.co.za

ZWARTKOPS CONSERVANCY

P O Box 75 • Swartkops • 6209 • Republic of South Africa

PBO 930029083. NPO No.:102-935-NPO

Formerly ZWARTKOPS TRUST (Est 1968) www.zwartkopsconservancy.co.za

☏ +27 (0)41 374 4444  +27 (0)41 374 2444  www.bellbuoy.co.za

 Community Housing and Commercial Property Administration  A Member of the National Association of Managing Agents  Rentals and Sales  Registered with the Estate Agency Affairs Board  Financial Administration  Registered with the Council for Debt Collectors

Tuesday, 30 April 2019

ANCHOR ENVIRONMENTAL CONSULTANTS (PTY) LTD

Email: [email protected]

Dear Sirs

OBJECTION TO PROPOSED SEA-BASED AQUACULTURE DEVELOPMENT ZONE - RETIEFPLEIN

We write in our capacity as Managing Agents and at the instruction of the Trustees of the Body Corporate of Retiefplein.

The trustees note with concern that the proposed fish farm is being reconsidered and that one of the sites being considered is located off of Port Elizabeth’s main beachfront area. The trustees hereby note their request to be listed as an Interested and Affected Party, please use the email address [email protected] as well as [email protected] for all future correspondence.

The trustees would like to advise that on behalf of the Retiefplein Body Corporate, located in Marine Drive, Summerstrand, they formally object to the fish farm being located in the proposed Algoa Site 1, and note that although the below list is not exhaustive it does detail a number of concerns that the body corporate has:

 It will have a significantly negative impact on our tourism;  Port Elizabeth has built itself as a water sports centre in South Africa and each year there are holiday makers and overseas tourists who come to Port Elizabeth for the activities available on our beachfront, these activities may be severely affected by the fish farm. Even if the activities themselves are not directly affected, the perception of Port Elizabeth as having warm, clean and safe sea waters will be severely affected and this will result in a decline in tourists seeking these types of activities  There is potential for the sea water around the farm to be polluted and potentially affect other marine life  Increased debris and pollution from this farm will make its way to our shore;  There may be smells emanating from the farm which will be blown onshore in the easterly wind direction  Port Elizabeth is currently trying to clean up our beachfront area by removing the coal terminal and the fuel tanks, and this just flies in the face of that exercise, and will replace it with another problem

The trustees have also obtained the express consent from the following registered owners at Retiefplein that they too wish to object to the proposal and list themselves as an Interested & Affected Party:

Unit Name E-mail No: 102 Chao-Sheng Chang Family Trust [email protected];[email protected] 104 Wahab (i/t), Mr R [email protected] 105 Knoesen (edo), Mr TJ & Mrs MM [email protected] 107 Christine van Niekerk Trust [email protected] 108 Loftus (edo), Mr MJ [email protected] 113 Williams (edo), Ms J [email protected] 206 Thorp (03'2019), Mrs PJ [email protected] 210 de Almeida (edo), Mr MM [email protected];[email protected] 213 Robey (*R*), Ms D [email protected] 301 Page (edo), Mrs SJ [email protected];[email protected] 304 Grondel, Mrs L [email protected];[email protected] 305 Blue Grass Family Trust [email protected];[email protected]

Bellbuoy (Pty) Limited t/a The Bellbuoy Group - Company Registration No. 2012/019786/07 VAT Reg. No.4170168118 - Debt Collector’s Certificate No.0049099/11 - NAMA Membership No. 1001 Non-Executive Directors: GS McWilliams, MC White / Executive Directors: S Moore-Barnes, C van Heerden P O Box 7660, Newton Park, 6055 - 1st Floor KPMG House, Norvic Drive, Greenacres, Port Elizabeth 6001

306 Ball (edo), Mrs HM [email protected] 308 Smit, Mrs R [email protected] 309 Walker (edo), Mrs EC [email protected] 311 CJVR Family Trust [email protected] 312 Morgan, Dr DH [email protected] 315 Watts (edo), Prof P [email protected] 401 Pearton, Mr RN [email protected] 403 Kaplan, Mr HV [email protected]

Please contact the writer should you have any queries.

Yours sincerely THE BELLBUOY GROUP

MARK SCHERER Business Development & Operational Manager e-mail: [email protected]

Copies: Trustees of the body corporate of Retiefplein

AFFILIATED TO LIFE SAVING SOUTH AFRICA

Postnet Suite #42, P/Bag X40106, Walmer, 6065 Cell: 082 441 5119 email: [email protected] www.kingsbeachslsc.co.za President: Victor Woodhead Chairman: Paul Middleton Vice Chairman: Jason Atkinson 29 April 2019

Dear Sir/Madam

To Whom It May Concern

Lifesaving clubs are voluntary organisations who act on behalf of the city and the country as custodians to water safety and water safety awareness.

Concerns around the fish farm along the NMB Beaches are as follows:

- Safety of all our competitors during lifesaving championships and training during the year on all our beaches - The increase of sharks and thus having a negative result on children/adults learning life skills in water - Chemicals used in fish farming to fight off parasites essential for the farming practices are harmful & lethal to the environment, organisms, mammals, birds and fish - The impact of chemicals can affect human health given its proximity to public bathing areas.

Further investigations into fish farming practices we object to placing these farms so close to public bathing areas and natural marine habitat.

The public are given opportunities to raise their concerns and objections, let's hope that our voice isn't ignored and that the public's interest is put first.

Regards

Kind regards

Paul Middleton Kings Beach Chairman

Letter head/LOGO of your company/institution

Schoenmakerskop Residents’ and Ratepayers’ Association (SRRA)

Date

29 April 2019

State who you are

(Prof.) Andre Lemmer (Chairman SRRA / retired professor of Teacher Education, NMU)

Whom you represent

The ratepayers and residents of our NMB sea-side village, Schoenmakerskop.

The effect the fish farm will have on you/your business/Algoa Bay in general

WE believe that the proposed Algoa Bay Aquaculture Development Zone (ADZ) project is misconceived and will do harm to businesses (e.g. hotels, B & B establishments etc.), the tourism industry, sports events (e.g. the Iron Man competition) and recreational pursuits (e.g. beach-going, swimming and surfing in the sea etc.) in our metro. We do not think this ADZ project will provide sufficient sustainable employment for our Metro. The risk of environmental damage to our Bay eco-system is too great.

The changes you want to see in the application

The envisaged economic benefits of the proposed ‘fish farm’ could still be generated if the project were to be moved to a more appropriate zone, e.g. a more remote ocean site that does not impinge on tourist, business and urban hotspots like Nelson Mandela Bay Metro.

Your contact details

Andre Lemmer, Box 5603, Walmer, 6065 / 112 Marine Drive, Schoenmakerskop, Port Elizabeth.

DATE: 30 April 2019

From: Tess Kotze (LEC SEC)

RE: Fish farming in our bay

We Lifesaving Eastern Cape are object to any fish farms in and around the bay.

LEC have 7 local clubs affiliated to Lifesaving South Africa and Lifesaving Nelson Mandela Bay namely; Brighton Beach, Bluewater Bay, Kings Beach, Humewood Beach, Hobie Beach, Summerstrand and Sardinia Bay and all these clubs will be affected by fish farming.

Fish farming in the bay will have a negative effect on the sport of lifesaving and any open water swimming event in our region. It is clear that fish farming will attract sharks to close bathing proximity in the bay. The possibility of shark attacks on our members will increase dramatically.

Lifesaving Nelson Mandela Bay has hosted National Lifesaving Championships very successfully in the last 4 years with our municipality committing to sponsor the next 3 years to keep this event in the bay. This event and smaller competitions have a positive impact for the tourist industry and the community of Nelson Mandela Bay. Fish farming in the bay will result in the loss of these events.

We urge you to reconsider and cancel any fish farming projects in and around the bay.

Yours in lifesaving

Tess Kotze Tess Kotze Cell: 082 441 5119 D.E. Thompson P.O. Box 12517 Centrahil PORT ELIZABETH 6006

30 April 2019

We the undersigned, Dennis Thompson Deborah Thompson Sipenati Thompson Bennie Thompson

Each in our personal capacities we object to the proposed FISH FARM in ALGOA BAY for the following reasons:

1. We believe that the negative impact that this will have on our city could lead to great financial hardship for our and many other businesses in the city.

2. The negative publicity that the city will receive were any of our international sporting events to be relocated to another venue because of the location of the fish farm would further cause incalculable damage to our city as these events give our city worldwide TV coverage which promotes a substantial amount of immediate and follow on tourism to our city which also disappear. This damage to our tourism industry will definitely cause a loss of direct revenue to the tourism industry in the city and also to all other business in the city that feeds off of this tourism activity.

3. Our biggest concern is for the loss of employment in the tourism sector and also in all other business that supports and feeds off the tourism industry like car rental companies, airlines, restaurants, tour operators and many others too numerous to mention.

4. Besides the negative image that the loss of our international events would have on our city it would further have a devastating effect on many businesses that generate much needed income from these events. They would also probably be forced to reduce staffing as a result of the downturn resulting in even further job losses.

It is actually astounding that there are individuals and companies that are even entertained by the powers that be with fish farm type proposals, which are even considered.

When selling a proposal one would always highlight the possibilities of potential benefit the product will have for the “buyer” or in this case, for our city, in some way or another. The seller/investor on

the other hand will always be on the lookout for profitability as this is the motive that drives business and will also play down any negative aspects which may be raised. At at the end of the day this is actually all about business and how much the investor can be make from the project.

However, to even consider a project at the risk of damaging an existing working industry that has taken many years to develop and grow, which does generate substantial income for business in the city, it has created much needed employment for the people of our city, it has done so for a number of years and will continue to do so given the chance, can only be considered as TOTALLY RECKLESS.

I strongly propose that the fish farm should find another home that will not have a negative effect on the existing business in our city.

I trust that the powers that be will make the correct decision and locate the fish farm at a location that will not damage existing business in a struggling economy.

Dennis Thompson

Debbie Thompson

Sipenati Thompson

Bennie Thompson

�.. nelson mandela bay ,�MUNICIPALITY

WARD 2

Tel: +27 (0) 41 585 0515 Your ref: 1808 Pre Application BAR Cell +27 (0) 83 468 5567

Our ref:Algoa Bay ADZ PO Box 2'15, Port Elizabeth, 6000 Republic of South Africa Date 30 April 2019 e-Mail:[email protected] Who deals with this? Cllr Renaldo Gouws

RE: Proposed Algoa Bay Aquaculture Development Zone:

To whom it may concern,

The Ward 2 Office has perused the mentioned Basic Assessment Report and would like to comment as follows:

The current format of the BAR, the EIA and the Economic Impact does not come across as having been properly considered or investigated. The impact of the proposed development would have dire consequences to the Wards beachfront,as well as impact negatively on the current events and tourism that is taking place in Ward 2 and the broader beachfront in Nelson Mandela Bay.

The following are just some of the concerns that has not been alleviated by the study:

• The Ward has three Blue Flag Beaches. These have the potential of being polluted by effluent, excess fish food and fish faeces which will wash up on the beaches during our frequent easterly/south easterly winds. • The loss of jobs in the tourism industry due to events like the lronman, Aquelle Ocean Series, Bellbouy Race, the Nippers National Championships withdrawing from the city due to the proposed ADZ.

The concerns raised above is already enough to question whether the proposed ADZ is financially viable for the metro as it has huge cost implications with water sports events withdrawing from Nelson Mandela Bay.

Added to the above the BAR doesn't alleviate the concerns with regards to the environmental impact assessment and it even contradicts findings by its very own specialists. The statement that it will be beneficial to both the Bay's ecosystem and the human use of the Bay's resources is therefore flawed.

Due to the high uncertainty of the impact of the proposed Algoa Bay Aquaculture Development Zone (ADZ) we simply cannot in good conscience support it. Another important aspect to consider is the Marine Spatial Plan forAlgoa Bay that has not been passed. This plan will provide a better understanding of the different uses of the Bay as it will consider the various uses of the area in question.

With reference to the above mentioned, as the Ward 2 Councillor in Nelson Mandela Bay and as the elected public representative to speak on behalf of the residents of Ward 2 in Nelson Mandela Bay, I cannot support the proposed ADZ plan in its current form as there are just to many uncertainties and questions that are left unanswered. I thereforealso strongly object to this development in its entirety in its current format.

� �lelson Mandela Bay Municipality E]@NMBmunicipality <, · � www.nelsonmandelabay.gov.za ONE CITY ONE FUTURE

Application consultation

COMMENT ON THE DRAFT BASIC ASSESSMENT REPORT FOR THE PROPOSED AQUACULTURE DEVELOPMENT ZONE IN ALGOA BAY.

This comment is a follow-up on my first comments on the pre-BAR, in April, 2019. Two sites will be considered here, namely the proposed Finfish site at Algoa 7, and the proposed bivalve site at Algoa 6.

1. Algoa 7 Finfish Site 1.1 Waves and Servicing Schedules The wave statistics derived from measurements made at the site S4 and used in the construction of the Port of Ngqura are shown in Figure 1.

(a) Figure 1(a). Position S4 where the wave measurements used to provide the statistics in Figure 1 (b) were made.

Figure 1(b). Return period for significant wave heights at site S4 (courtesy of PRDW).

Extremes Values of Hs at Position S4 (b) RETURN PERIOD (YEARS) 1 5 10 100 10

9 June 1997 East London 8 Storm 7 6 5 Hs(m) 4

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2 Threshold Value: Hs = 3.0 m SOEKOR data set refracted to S4 Buoy Location 1

0 -2 -1 0 1 2 3 4 5 6 7 GUMBEL STANDARD VARIATE Hs Extreme Regression Fit Best Guess Fit

1

The position of S4 is just over 1 km from the western point of Algoa 7, and can therefore be taken as representative of conditions at that site. It shows that the significant wave 5-year return period is about 5 m, while every 10 years significant wave heights of almost 6 m can be expected. Extrapolating for a 100-year wave gives a significant wave height of close to 7 m though an outlier for a 1997 storm at East London shows over 9 m. The Algoa Bay ADZ Economic Feasibility analysis (2016) indicates an overall low to very low economic viability for both the Algoa 1 and Algoa 5 ADZs, and by extension also to Algoa 7 lying between the other two. In particular, the temperature regime is unsuitable for kob aquaculture as its growth rate is uneconomic at the average bay temperature of 18°C, and the regular upwelling events will compromise fish growth and health. Moreover, the high wind and swell exposure limits the number of sea days using small work vessels and conventional cages, requiring an ‘offshore aquaculture’ equipment specification which would increase capital costs substantially. Unscheduled breaks in cage servicing schedules increase the risk of fish escapes, bird predation, mass fish escapes from unmaintained cages, predator attraction and fish health problems. The susceptibility of Algoa Bay to red tide blooms presents an investment uncertainty and a further risk. The Draft BAR AppD1, Benthic Mapping, gives the following specifications for Algoa 7: Significant wave height approximated 1 m for 60 % of the time monitored, and was less than 2 m for 95 % of the time. Significant wave heights of 3.5 m or higher were experienced 1 % of the time. This equates to approximately 3 days (72.6 hr). The maximum significant wave height recorded was 5 m with a wave period of 13 seconds. Wave period approximated one wave every 12 seconds 41 % of the time, and generally ranged from 9 to 15 seconds (90 % of the time). The more comprehensive wave statistics given in Figure 1 show that wave conditions can be expected to be more severe than those given in the Draft BAR. An advantage of Algoa 7 is that it is very close to the Port of Ngqura, expediting servicing schedules. Nonetheless, following on the conclusions of the economic feasibility analysis the cumulative combination of unsuitable environmental conditions, difficult sea-based logistics, uneconomic growth rates, high capital costs and marginal returns must render the overall economic feasibility of the Algoa 7 site to be ‘very low’ for cage culture of indigenous marine species.

1.2 Maintenance of Finfish Farms There are many references to the contaminants produced in fish farms, examples being • Fish on aquafarms spend their entire lives in cramped, filthy enclosures, and many suffer from parasitic infections, diseases, and debilitating injuries. • Contaminants from ocean-based aquafarms (fish excrement, uneaten chemical-laden food, and swarms of parasites) spread to the surrounding ocean • High-tech, high-volume systems control food, and drugs, hormones, and genetic engineering are used to accelerate growth and change reproductive behaviors. High mortality rates, disease, and parasite infestations are common. To a large extent this depends on how well the farm is managed, and according to the report codes of conduct will be established for any fish farm operators(s). However, the effectiveness of such codes of conduct depend on how well they are applied, and records from elsewhere show that in many cases the implementation of such controls leaves a lot to be desired, As a consequence, the following steps must be taken before a fish farm operator is appointed:

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• The codes of conduct must be established by an independent body, with members selected from appropriate government and private structures. Advice must obtained from internationally-recognised specialists. • Any deviations from good management practices must carry appropriate penalties. The authority of the managing authority must be clearly specified and accepted by all operators. • A regular schedule of inspections and reports must be set up, with appropriate penalties for non-compliance. These records must be made public.

1.3 Dispersion onto Local Beaches and Islands Many of the potential contaminants produced by a fish farm are buoyant and will remain in the surface waters. While a percentage of uneaten food and faeces pellets will settle down the water column, there are buoyant wastes comprising of oils or fats. These may not pose a direct danger to human health, but nobody wants to swim in them. None of the current measurements reported are suitable for determining the movement in the surface waters. However, it is known that such movement can be more than 10% of the wind speed, so a 20 km/hr wind will move surface waters by more than 2 km per hour. The report also quotes speeds of up to 1 m/s under strong winds, so that the surface waters at Algoa 7 can reach St Georges Strand within 2 hours. Moreover, Jahleel Island is only about 2.5 km from Algoa 7, with St Croix around 10 km away. It is not known what effect such persistent pollution of sea waters will have on populations of penguins and other marine animals..

2. Algoa 6 Bivalve Site My previous comment detailed the extensive pollution found in the region north of the harbour in the report by Schumann and Campbell (1999). The pre-BAR details water quality data for the Algoa 6 site from only two samples collected in September, 2009 and October, 2018, and totally ignores the unacceptably high levels of faecal coliforms in the above report. The operations of the Knysna Oyster Company at a site just north of the Port Elizabeth Harbour have also been seriously affected on a number of occasions when high levels of E. coli caused oyster mortalities and closure of the farm for a period by DAFF. Associated illnesses in customers has led to banning of their product from certain markets The response by the EAP that the position where the water quality measurements were made will be specified misses the point entirely, since two such measurements cannot describe the variability in water quality found in the area. As a comparison, the report by Schumann and Campbell (1999) considers between 4 and 91measurements (average 34) made at 33 sites along the coast and in the ocean, so that the two point measurements described in the pre-BAR do not add meaningfully to an understanding of the conditions. Furthermore, the EAP states that: More detailed receiving water quality data would not contribute toward the decision-making by the competent authority. DAFF (and the industry) is aware of the risks posed by existing land- based activities in Algoa Bay and has nevertheless decided to go ahead with the application for environmental authorisation for the proposed ADZ (Refer to Chapter 7 of the BAR). An existing oyster company is also battling with water quality at Algoa 6. DAFF is working together with DEA, DWS and the Metropolitan municipality to ensure co-ordinated monitoring of water quality in the bay and ultimately work towards improved situation. Any current challenges around water

3 quality need to be improved for all users in the Bay, not just aquaculture and cannot therefore be accepted as status quo. For this reason, the option of bivalve culture in Algoa 1 is being explored as an option. For the above reason, no detailed information is presented on the bacterial counts at the Algoa 6. It is surprising that DAFF and the industry believe that they don’t need actual measurements to make a decision on whether the Algoa 6 site is suitable for an ADZ site. Surely any potential operator would want to know the water quality before making a decision to commit to such an expensive exercise? Nonetheless, the statement that water quality needs to be improved for all users in the Bay, not just aquaculture, is positive, and hopefully is an indication that the idea is to improve conditions. Moreover, the fact that DAFF is working together with DEA, DWS and the NMB Municipality to ensure co-ordinated monitoring of water quality in the bay and ultimately work towards improved situation is good news. The statements made at the public meeting on 31 July by DAFF representatives also confirmed that they are actively pursuing a programme of improving the water quality in the area. On the other hand, I have found it very difficult to access information on water quality in the coastal areas of Port Elizabeth, and it is not at all clear that such measurements are actually being made. It is also of concern that industrial effluent is being mixed with the sewage at the FFWTW and discharged at the New Brighton Pier – where people are swimming. There are now possibilities of toxic industrial chemicals entering the mix to sea which cannot be good news for any ADZ operator. Consequently, unless additional valid data are presented, there is no guarantee that water quality at the Algoa 6 site is any better than that given in the Schumann and Campbell (1999) report. In fact, with the increases in volumes being discharged it is likely that the water quality has deteriorated further. Under these conditions it is unlikely that any ADZ operator will be prepared to start a new bivalve farm at Algoa 6. In order to improve the possibilities, the stated co-ordinated monitoring of water quality by the DAFF, DEA, DWS and the NMBM must start as soon as possible (unless it is already ongoing?), and steps must be taken to improve the situation. However, in order to gain the confidence and support of society, the following information must be made available to all interested parties: • The positions where these measurements are being made • The parameters that are being measured • The frequency of measurement Quite clearly the results must also be made public, together with any analyses to indicate whether the situation is improving.

Dr E H Schumann 26 Marine Gardens, Glengarry Crescent, Humewood, Port Elizabeth. Tel: 041 5860632; Mobile: 083 2992092 2019-08-23

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COMMENTS ON PROPOSED DEVELOPMENT F SEA-BASED AQUACULTURE

DEVELOPMENT ZONE ALGOA BAY, EASTERN CAPE

Thank you for the opportunity to comment of the proposed development.

In summary the following is our stands: Option Algoa 1 Algoa 6 Algoa 7 Accept / reject

A Finfish & Bivalve Finfish Reject

Bivalve

B Bivalve Bivalve Finfish Reject

C X Bivalve Finfish Reject

D X X X Accept (possibly extend existing farm) Opposed to any Already in place, Opposed to any development maybe extend with development here – Visual local species only here – adjacent impact to MPA

Option 1 – Algoa 1 Summerstrand We find it disconcerting that the department insists in trying to develop an aquaculture industry in front of the tourist beaches, be it Hobby Beach or Summerstrand. During the last authorization from DEAT and the response from the public of Port Elizabeth it must have been very clear that we do not want any development in front of the beaches. Yet again, it is mentioned as an Option 1 - Summerstrand. Any aquaculturing is rejected here due to visual impact. The scenic situation of the sea and horizon in front of Summerstrand affords stunning sunrises across the sea with huge aesthetic appeal. Local websites run daily images of the sunrises and the value of the natural environment is enjoyed by all. The view of cages in front of a rising sun will be totally distracted. In addition the setting of the beaches with the wide open sea is stunning and attracts tourists (and specifically families) to ours beaches. Many sports events also take place and the visual impacts will distract from the attraction of the bay. We oppose any development here.

Option 2 – Algoa 6 – Port Elizabeth harbour It has to be noted that this is a brand new precinct not put forward for aquaculturing before in the previous reports. It is understood that some cultivation of bivalves are taken place there already and that this will be an extension. If there is capacity for extension in this area needs to be seen. Bunkering (an operation that has not been subjected to an EIA by DAFF) is taken place in close proximity of Algoa 6. The effect of spillages of oil and HFO on the bivalves will be catastrophic. Development of local species only may be extended in this area.

Option 3 – Algoa 7 – Port of Ngqura It is also noted that this was never a precinct in the previous reports. It is furthermore noted that the Addo MPA was promulgated on in May 2019, and that the Algoa 7 area was removed as a controlled zone from the original draft gazette notice (published on 3 February 2016). This is not acceptable. The Algoa 7 still occurs directly to the MPA and as such any impacts will be moving up the coast (with the wave actions) and into the MPA. The impact on biodiversity and ecology on the adjacent MPA will be catastrophic – taken into consideration that this is the breeding area and islands of the endangered African penguins and gannets. In addition this is the area where the endangered humpback dolphins also occur. The impacts on biodiversity and ecological disturbance will arise from both the organic loading and excess food particles that will float in the water and sink to the ocean floor. The possibility of formation of decaying organic matter and the formation of hydrogen sulphide can lead to a change in the pH of the water (sulphuric acid) with a total collapse of our corals in the bay. We oppose any development here.

Spatial development plan The Strategic Environmental Assessment (SEA) was undertaken in 2009 for the entire South African coastline to identify suitable aquaculture precincts. During the last 10 year a lot has happen in Algoa Bay and possibly a better way forward is to stop all the insistence in development of an aquaculture industry and work toward using the resources of the bay to the best possible means. It is a concern as well that no mentioning is made of the current Marine Spatial Plan Act, 16 of 2018, and that Algoa Bay has been selected as the first bay where the plan will be rolled out. Interested parties and stakeholders are already in discussion to determine the best utilization of the resources. Possibly DAFF should take a step backwards and investigate how best to sell the bay as an ecotourism destination, utilize all the money spend on EIAs, Specialist studies, etc, to create SME’s in the tourist industry. We request interaction with spatial development planning project Lastly, big cetaceans are local and migrating up and down our coastline and are often entangled in ropes from aquaculture. A week ago a humpback whale was washed out in Port Elizabeth where the entanglement occurred from lobster cages around its tail. We can no longer allow such operations in our bay and endanger these important creatures.

Yours sincerely Ronelle Friend, Environmental Scientist, Enviro-Quest, [email protected], Cll: 0836361156

HEAD OFFICE PO Box 357, Port Elizabeth, 6000, South Africa, Tel: +27 (0) 41 582 2575 • Fax: +27 (0) 41 582 2573 No. 39 Donkin Street, Port Elizabeth

04 September 2019

COMMENTS ON PROPOSED DEVELOPMENT OF SEA-BASED AQUACULTURE DEVELOPMENT ZONE ALGOA BAY, EASTERN CAPE

Please receive our comments on the proposed development of aquaculture in Algoa Bay. Interested & Affected Party: Shaun Fitzhenry, Chairperson, Nelson Mandela Bay Tourism, for and on behalf of its membership. Email: [email protected] Preferred method of contact: email Interest: Representative of various tourism and accommodation product owners who will be impacted directly by the DAFF aquaculture project, and as a tourism product owner.

Summerstrand & Humewood areas – Algoa 1 As the organisation representing most tourism and accommodation product owners in Nelson Mandela Bay, Nelson Mandela Bay Tourism must oppose any form of aquaculture, whether bivalve or finfish, on the Port Elizabeth beachfront. It stands to reason that aquaculture, in any form, will lead directly to a significant drop in numbers of visitors to Nelson Mandela Bay, since the Summerstrand/Humewood beachfront is the metro’s primary attraction – hence the high density of hotels, guesthouses and Bed & Breakfast establishments. An entire tourism economy will be severely impacted by any form of aquaculture off the Summerstrand and Humewood beaches, leading to significant job losses and closure of business. There is no way that aquaculture can replace those jobs. Given the undeniable fact that national, provincial and local government have pushed tourism as the most effective, sustainable way of creating long-term, meaningful employment, it is our considered opinion that the impact of aquaculture has been grossly underestimated, and that it requires a full Scoping and Environmental Impact assessment process rather than a Basic Assessment, as proposed by Anchor research and monitoring. The proposed area of development is in direct view of the Summerstrand and Humewood beaches and the coastal areas that are frequented by holiday makers, sportsmen and women competing in marathons, triathlons and the like, lifesavers, surfers, stand-up paddlers, kayakers, snorkelers, scuba divers, fishermen, sailors or just ordinary people, local and visitors alike, enjoying the natural beauty of our bay. Bivalve aquaculture will destroy this. All forms of leisure activity related to our beach and ocean environment will be negatively impacted by the fish or bivalve cages in the water as well as the movement of people to and from the aquaculture farm. During harvesting a substantial amount of traffic will occur in front of Summerstrand and Humewood, spoiling the natural aesthetic beauty of the sea, and making it unsafe to perform sports in the sea. In addition, the excess food in the area is likely to attract other ocean wildlife, including sharks, to the area, making the practice of water-based sports and activities unsafe and questionable. This will have a direct negative impact on the growth of tourism. Hotel rooms in hotel buildings along the beachfront, which earn premium rates because of their exceptional views, will have these views disturbed by unsightly cages. This will result in a drop in bookings at these hotels, with the increased likelihood of further job losses. There are also very serious concerns about the smell. It has been mentioned that hydrogen sulphide is likely to be produced by decaying food present in the water. When the easterly wind blows, the smell generated by this is very likely to be picked up by Summerstrand inhabitants and tourists. Hydrogen sulphide smells like rotten eggs and can be detected by smell in concentrations as low as 0.30 ppm. This will have a very significant negative impact on Summerstrand and Humewood beachfront and other restaurants, bars and entertainment areas, again leading to possible job losses and business closures. TOURIST INFORMATION OFFICES Donkin Reserve, Belmont Terrace, Central. Tel: +27 (0) 41 585 8884 • Fax: +27 (0) 41 585 2564 The Boardwalk (opp. Hobie Beach), Marine Drive, Summerstrand. Tel: +27 (0) 41 583 2030 • Fax: +27 (0) 41 583 3413 Uitenhage, 73 Graaff Reinet Road, Mosel, Uitenhage. Tel: +27 (0) 41 922 5214 • Fax: +27 (0) 41 922 5765 E-mail: [email protected] Website: www.nmbt.co.za;

An additional factor to be considered is aviation safety. The bivalve farm proposed for Algoa 1 Option 1 is essentially on the Port Elizabeth Airport flight path. Any form of aquaculture will lead to increased marine bird activity in the flightpath, which will lead to heightened aviation safety risks in the form of potential bird strikes. We will raise this issue directly with the Airports Company of South Africa and the South African Civil Aviation Authority. Any form of aquaculture will have a severe negative impact on the aesthetic beauty of the bay (visual and olfactory), as well as impacting visitors and residents in other ways, such as increased danger while participating in watersports because of increased boat traffic and the increased presence of marine predators such as sharks. Because this will definitely have a negative impact on existing tourism as well as the potential growth of tourism, we are definitely OPPOSED to the development of any form of aquaculture off the Summerstrand and Humewood beaches. There is NO benefit, economic or ecological, to such practices, which can outweigh the massive loss to tourism which will be the result of bivalve aquaculture off these key tourist and watersports beaches.

Port Elizabeth Harbour – Algoa 6 The farming of abalone is already taken place here. We do not know what the impact the introduction of a different bivalve to the area will be. We can only support the growing of local species, not foreign species of bivalves. We do not believe that the development will create substantial numbers of employment, and any employment created will be seasonal. Studies will have to be done to determine the suitability of this area for bivalve farming. Due to the low number of jobs that will be created, the debatable economic benefits and the negative impacts on the environment, we only partially support aquaculture here, and then on the proviso that only indigenous species be cultivated.

Port of Ngqura harbour – Algoa 7 The MPA that has been recently promulgated, and which falls under the authority of SANParks, is directly adjacent to the Algoa 7 area. The MPA is of extreme importance to NMB tourism. The protected islands where the endangered penguins and gannets breed are situated near Algoa 7 area. This is where most of the eco-tours take place to view the penguins, whales and dolphins. The endangered humpback dolphin is often observed in and around the harbour wall of the Port of Nqgura. Any release of excess food, excretions, etc. will move into the MPA because of existing water movement patterns and impact negatively on marine biodiversity. Because of the ecological impact, risk to marine biodiversity and negative impact on tourism we do not support development here and believe that the environmental sensitivity of this area again reinforces the need for a full Scoping and Environmental Impact study. It would therefore appear that the only attractive option for NMBT is Option D – the “no-go” option.

Yours sincerely

Shaun Fitzhenry NMBT Chairperson

22 August 2019 LET_MBMaritimeReserve_20190822

Anchor Environmental 8 Steenberg House Silverwood Close Tokai 7945

Att: Dr Ken Hutchings

Dear Sir, RE: EAST CAPE SHOWCASE-- MARITIME RESERVE - NELSON MANDELA BAY

Firstly, would like to congratulate you for taking the initiative on this much needed project to ensure that we utilise our waters to the best advantage for all economic activities within Nelson Mandela Bay.

Unfortunately, most people have not spent the money to analyse what the impact of poverty has on the environment. For this reason we would applaud you for taking the initiative to look for opportunities to create jobs within Nelson Mandela Bay. Scoping Report

The issue around the scoping report has become an extremely sensitive matter for East Cape Showcase (Pty) Ltd as we find that all the environmental specialists are not following due process and DEDEA are not taking any steps to correct the process regarding the scoping process within EIA Process.

East Cape Showcase (Pty) Ltd has a vast stretch of land covering approximately 6000 ha and involving some 30 km of coastline, this project commonly known as Madiba Bay Leisure Park. Our land starts at the high water mark and stretches for 30 km of coastline and approximately 6 km inland.

East Cape Showcase (Pty) Ltd has a 50 year notarial lease registered in the deeds office in Cape Town. (see attached)

Madiba Bay Holdings (Pty) Ltd P.O. Box 20204, Humewood, Port Elizabeth, 6013, Republic of South Africa. Tel. +27 (41) 583 2009 Fax. +27 (41) 583 3910 E-mail: [email protected] Web: www.madibabay.co.za CK Reg. No. 2001/012965/07 Directors: Fezekile Mahlati, Lee Samuels, Johann Dreyer, Tumelo Motsisi

In the deeds office (which is a public domain) you will find the notarised diagram, lease document and a site plan indicating the leased area.

We can confirm that Fairbridges, our attorneys in Cape Town, recently did a deed search and confirmed that all is still in place and that there is a bond registered over such property in favour of ABSA Bank.

Part of the scoping report is to contact all interested and affected parties regarding any development affecting such interested and affected parties. East Cape Showcase (Pty) Ltd has obtained legal opinion that it is the duty of the environmental specialists doing the scoping report to write to all abutting owners of any new development and inform them of such development. This never took place, the scoping process is thus flawed.

In this instance, East Cape Showcase (Pty) Ltd owns the land from the high watermark surrounding the land at Cape Recife and as we understand it the marine reserve is part of the waters on our property at Cape Recife.

As a matter of principle we believe that it would only be correct that the appointed party that has been appointed to do the EIA place on record that they have not followed due process of advising all interested and affected parties with regard to the proposed Maritime Reserve within the Nelson Mandela Bay. This is a matter of principle in that we do not want to allow this process to continue whereby professionals are not following due process in advising abutting owners of properties of proposed developments that abut their land.

We further believe that if due process was followed that the Maritime Reserve for the Nelson Mandela Bay Municipality would have included the coastline of the Madiba Bay Leisure Park development.

It is a known fact that the waters surrounding the Madiba Bay Leisure Park are the most ideal waters for various maritime projects such as perlemoen farming which all are aware occurred naturally and was one of the biggest poaching areas in South Africa where the poachers used to take out approximately R250 million of the perlemoen per annum until they depleted the resources.

The water on the wild side, as it is commonly known, is extremely rich in nutrients as well as having ideal all year round water temperatures thus making it ideal for maritime activities.

Madiba Bay Leisure Park is mainly about education and training of small business franchise cooperatives in all sectors of the economy. The Madiba Bay Leisure Park will not only employ 30,000 people during construction but will create an excess of 2000 small business opportunities where people from the previously disadvantaged communities will own 100% equity in small business franchise cooperatives. Madiba Bay Leisure Park believes that we can take advantage of the rich waters abutting our development by doing on land fish farming as well as ocean-based aquaculture.

It is for this reason that we would request an urgent meeting whereby we would humbly request that the waters surrounding Madiba Bay Leisure Park is included in the maritime reserve and that we enter into discussions with regards to various aquaculture opportunities for research education and job creation.

We would humbly request that you advise us of a date, time and venue when we could fly down to Cape Town to meet with your good selves to discuss this matter further. Madiba Bay Holdings (Pty) Ltd P.O. Box 20204, Humewood, Port Elizabeth, 6013, Republic of South Africa. Tel. +27 (41) 583 2009 Fax. +27 (41) 583 3910 E-mail: [email protected] Web: www.madibabay.co.za CK Reg. No. 2001/012965/07 Directors: Fezekile Mahlati, Lee Samuels, Johann Dreyer, Tumelo Motsisi

Would like to place on record that this letter is not in any way to be taken as a negative response as we are in full support of the initiative of creating a maritime reserve but feel extremely strongly that due process must be followed and that all environmentalists doing scoping reports must be informed of the process of contacting all interested and affected parties in a proper and professional manner.

We look forward to your response and meeting with you to discuss the inclusion of Madiba Bay Leisure Park waters to be part of phase 2 of the proposed Nelson Mandela Bay maritime reserve.

Kind regards,

JOHANN DREYER

DIRECTOR

MADIBA BAY LEISURE PARK

“Walk the Dream”

Madiba Bay Holdings (Pty) Ltd P.O. Box 20204, Humewood, Port Elizabeth, 6013, Republic of South Africa. Tel. +27 (41) 583 2009 Fax. +27 (41) 583 3910 E-mail: [email protected] Web: www.madibabay.co.za CK Reg. No. 2001/012965/07 Directors: Fezekile Mahlati, Lee Samuels, Johann Dreyer, Tumelo Motsisi

Pn.,vince of the EASTERN CAPE

Athol Fugard Terrace/ Castle Hill Central Port Elizabeth 6001, Private Bag X5001 Greenacres 6057 Republic of South Africa Contact person: Dayalan Govender; Tel: 041 5085811 Fax: 041 5085865 Cell: 0716749710; Email: [email protected] www.dedea.gov.za

Vera Massie- Liebau Anchor Environmental Consultants 8 Steenberg House Silverwood Close Tokai 7975

Re: DEDEAT comments on the Algoa Bav ADZ-September 2019

Dear Mam

Please find the comments for your consideration.

1. Fauna: Interactions with Piscivorous Marine Animals (General)

a) The prompt removal of dead fish is an over expectation, as the cages are not under constant observation. b) It must be noted that gulls will pick these offbefore an operator can get to the cages. c) The referenceto Tori lines, having read up on Tori Lines, it was foundthat these don't necessarily work and serves more to prevent by-catch of sea birds in trawling. d) How will one maintain such a register of interactions considering that there is no permanent employee on the cages? e) Harvesting, references blood and entrails, will there be gutting of fish at the site?

2. Sharks and the potential threat to humans "The establishment of the fish farms will create/modify ecological interactions, the concentration of fish within the cages and possible concentration of wild fish outside the cages which will likely be attracted to the feedwill invariably create a food web with apex predators spending more time in the area." a) As mitigation, monitoring is proposed who will do the monitoring as this is a costly exercise? b) Will the longline shark operator be negatively influenced?

3.Cetaceans a) Whilst the risks to cetaceans are considered medium, the impacts on the ca ..-...--..,-f seems to have been ignored. A whale entangled in the cage infrastructurecould in fa disl e cage/sink it. b) The drowned/entangledcetacean will serve as shark bait. The medium risk of entanglement seems to downplay these potential scenarios. Pg. 1 of 7 Leadership Integrity Flexibility Teamwork

c) Impacts on habitat is deemed to be low but the increased residency time of apex predators could increase potential interactions with cetaceans especially juveniles. The report does not consider this aspect. Port Elizabeth is known for drawing in a small group of killer whales. The increase in shark populations would lead to an increase in the presence of these whales.

4. Diseases impacts on wild stocks a) The point that farmed fishare likely to be "infected"by wild stock surely that in itself is a massive risk any investor will have to carry, an entire operation could be decimated by a "wild fish pathogen", the report does not speak to this risk factor. b) The impacts must consider the receiving environment and what the receiving environment could bring to the operation i.e. "wild fishpathogen".

5. Genetic Contamination a) How does one recover escapees? b) The reality is that any fish that escape (10 or 100) could genetically foul the wild population over time.

6. Organic Waste & Chemical a) The impacts of organic waste and chemicals only speaks to the dispersion and the minuscule impacts but fails to consider the concentration of wild fish species around these cages. In essence the chemicals (medicinals as an example) can in fact enter the wild system faster via this conduit of wild fish that will congregate outside the cages for food.

7. Impacts on Recreational Activities, jobs, businesses and routes a) Surely the fact that no information exists on shark distribution patterns this in itself a is a fatal flaw. Liability could be placed on the State if the EA is granted, despite a lack in crucial information pertaining to apex predators. b) Sporting events such as the Iron Man contributes substantially to the NMBM fiscus especially small businesses and the creation of jobs. c) The real risk is the loss of jobs for those employed in hotels, restaurants, shops, transport, cleaning and other businesses that rely on beaches being clean and safe. d) The building of the aqua culture could affect the routes of boats and ships. New routes would have to be taken and possible congestion could take place.

8. Impact on commercial fisheries a) What will be the feedmaterial? b) The report talks to reducing the foot print as a mitigation measure, what will be the final footprint as there are figuresquoted as foot print sizes, 210 (A .g,e d 420 Ha (Algoa 5). c) Will the dispersal of the feed material and faecal matte�...,.,. le impacts on the Chokka fishery especially the habitats and fishingareas? {,

Pg. 2 of 7 Leadership Integrity Flexibility Teamwork

9.ADDOMPA a) The report is stating reducing the production, what will the footprint of the cages be once established even if the production is down scaled. b) As a matter of curiosity as the accumulative impacts of bird guano and nutrient loading been consider on the matter of algal blooms for Algoa 5.

"Untreated wastes resulting mainly from uneaten food and faeces of fish in sea cages are discharged directly into the sea and are a significant source of nutrients. Sediments and benthic invertebrate communities under fish farms usually show chemical, physical and biological changes attributable to nutrient loading." c) Can this not be interpreted as ecological engineering/modification of benthic communities that will have a long-term impact on the various ecological entities that make up the system?

10. Algal Blooms "Nutrient loading, of the water column along with the reduction of dissolved 02 concentrations, as a result of fish cages has been implicated in conditions that stimulate harmful algal blooms, which pose a threat to human health and shellfish mariculture operations. The south coast of South Africa, including Algoa Bay, has been shown to be susceptible to red tides, as demonstrated by the massive bloom of the dinoflagellate Lingulodinium polyedrum during the summer of 2013/14 [covering several hundred kms]. However, this bloom was shown to be a coastal rather than bay phenomenon and the development of such a bloom is unlikely to be influenced in anyway by wastes froma fish farm sited at Algoa". a) How will an algal bloom impact on an operation? b) Whilst it can be argued that the cages will not trigger an algal bloom the potential threatto an operation is not clearly stated. c) Eutrophication is a large concern when it comes to aqua culture.

11. Anti-foulants "Do not apply antifoulants on site (at sea)", how will the growth of barnacle and algae be managed? as this growth equates to biomass/weight on the structure/cages.

12. Marine Specialist Impact Assessment a) From a species perspective, the initial phase of the project showed that "Yellowtail has significant potential for commercial aquaculture in the country. The fish produced by the pilot project was sold to South Africa's premier retailer, indicating a high level of market potential for yellowtail.", which "premier retailer" was the outlet for sales of the fish? b) It's disappointing, whilst the idea is seeking out to 8le protein. Which retail options will be considered should the EA be gr ted? Can the � prescribe?, or should that not be the recommendation ? That the fir t option is e ' hoprite' and 'Boxers' of the retail world and not premier retailers?

Pg. 3 of7 Leadership Integrity Flexibility Teamwork

"Dusky kob, silver kob and yellowtail were grown over a 30-month period. The project achieved promising yellowtail growth results with some fish reaching 1.5 kilograms in 14 months. The results obtained for both kob species were disappointing, with dusky kob only reaching an average size of 549 grams in 19 months and silver kob reaching an average size of 550 grams in 22 months" c) Why consider using the same failed species when pilot studies show they not worthwhile species?

"The unavailability of yellowtail fingerlings prevented the successful implementation of the continuation phase of the DST Eastern Cape Sea Cage Finfish Farming Pilot Project which was abandoned in 2011." d) What is the status now with regards to fingerlings? e) The use of AIS should only be considered for land-based operations especially considering the risks and should be advocated via this process. f) Fish populations could become smaller through the process of adaption. As they continuously breed, they adapt in size in order to escape. This is the same for fisherman out at sea who overfish, the fish do not reach their full rate of growth and therefore over time the populations become smaller, allowing them to escape nets.

13. Operational Phase Impacts "Incubation and transmission of fish diseases and parasites from captive to wild populations and vice versa." a) If one considers the findings on Salmon, it would infer that the cages would be breeding sites for parasites, any interaction with wild populations would invariably result in transmission.

"Chemical treatment is not without further environmental impacts, whilst build-up of antibiotic and chemical resistance is becoming increasingly problematic (Staniford 2002)." b) Was there a parasite problem found during the I&J pilot project? A baseline study to determine what is the infection rate currently in wild stocks should be a priority for DAFF? c) If this project was land based would the parasitic infection rates be just as high or lower or non-existent?

"Dusky kob are migratory and yellowtail are regarded as nomadic, whilst silver kob within the vicinity (10-100 km) of future sea cages will also likely come into contact with farmed stock (Mann 2000). All three of these species (and any others with nomadic or migratory movement patterns) will therefore be at an increased risk of contracting diseases and or parasites fromstocked fish and spreading them through wild populations. Potential negative effectson wild stocks are particularly concerning as all three of these species are important in the commercial and recreational line · fisheries and furthermore, the stocks of both South African, ob pecies are assessed as collapsed (Grifitths 2000). Dusky kob has recently been usi g IUCN criteria and is considered Vulnerable in South Africa (Sink et al. in prep)." ...... c..---

Pg. 4 of 7 Leadership • Integrity Flexibility Teamwork

d) Is it worth sacrificing the wild stock if the findings are so dire?

14. Mitigation advanced "Maintain strict bio-security measures within hatchery, holding tanks and sea cages." a) How does one achieve such considering the ocean is a dynamic habitat?

"Ensure all fry undergoes a health examination prior to stocking in sea cages." b) It is understood that parasitic infection will happen via wild stock interacting with cage stocks.

"Regularly inspect stock for disease and/parasites as part of a formalised stock health monitoring programme and take necessary action to eliminate pathogens through the use of therapeutic chemicals". c) How regular?

"This will require focussed research effort into the identification, pathology and treatment of diseases and parasites infectingfarmed species, both within culture wild stocks." d) The parasitic/disease transmission impact seems like a fatal flaw, with both wild stocks and caged stocks in jeopardy. e) Should this not be a Pilot Project like the I&J project and the research that needs to be done is undertaken on the pilot project, thereby removing/reducing the Risk?

"Maintain comprehensive records of all pathogens and parasites detected as well as logs detailing the efficacy of treatments applied. These records should be made publically available to facilitate rapid responses by other operators to future outbreaks." f) The question is would one operator who operates efficientlywant to share informationwith a competitor?

"Pollution of coastal waters due to the discharge of organic wastes." "Implement a phased approach, starting with <1000 ti ADZ and do not exceed recommended stocking options as per Wright et al. (2019)." g) This mitigation measure is the best option but should be advanced as a "pilot project" to test the waters (pun intended).

"Escape of genetically distinct fish that compete and interbreed with wild stocks that are often already depleted." "Independent monitoring of brood stock rotation, breeding programmes and cultured stock genetic diversity may, however, be required to ensure that mitigation is effective"

h) Who pays forsuch? i) Is it possible to affect a DNA monitoring system considering the reproductive sterile fingerlings will/could become a reality in the fu

"Develop and implement recovery procedures sho j) How does an operator recover escaped fish? Pg. 5 of 7 Leadership Integrity • Flexibility Teamwork

"Implement annual genetic monitoring between indigenous wild caught indigenous and farmed fish to monitor for any significant differences" This is supported.

"Chemical pollution of marine food chains ( & potential risk to human health) due to the use of therapeutic chemicals in the treatment of cultured stock and antifouling treatment of infrastructure." k) The potential threat to human health is a concern considering that a large number of subsistence fisher people live in the Bay.

"The effectsof chemical pollution arising fromfish cages on Algoa 1 and Algoa 7 are anticipated to be local, that is confined to Algoa Bay." I) Local impacts on benthic fauna has this been assessed as the benthic fauna communities could be modified?

"Physical hazard to cetaceans and other marine species that may become entangled in ropes and nets." m) Any entangled ( drowned or drowning) cetacean will serve as an attractant to apex predators.

"Piscivorous marine animals (including mammals, sharks, bony fish and birds) attempt to remove fish fromthe cages and may become tangled in nets, damage nets leading to escapes and stress or harmthe cultured stock. Piscivorous marine animals may also be attracted to the cages that act as Fish Attractant Devices (FADs) and in so doing natural foraging behaviours and food webs may be altered. Internationally fish farmers tend to kill problem predators or use acoustic deterrents (Stickney and McVey 2002)." n) The change in foraging behaviour and alteration in food webs are a critical environmental variable that is bound to have far reaching impacts, not just environmental but also socio­ economical and the report does not address this alteration of food webs in that sense.

"Install and maintain suitable predator nets (sufficientstrength, visibility and mesh size, above and below water line." o) Predator nets especially below water line will result in none selective capturing. p) Will it keep out shoal predatory fish, like shad out?

"Store feedso piscivores cannot access it and implement efficient feedingstrategy." q) Will the feed be on site?

"Develop a protocol for dealing with problem pisci ...... ,...... ,._.,.� ction with experts and officials (DAFF, DEA etc)." r) Who will do this?

Pg. 6 of 7 Leadership Integrity Flexibility Teamwork J

15. Bivalve mariculture "However, despite at least a decade of oyster mariculture in the v1c1mty of Algoa 6, wild populations of the Pacific oyster C. gigas has not yet been detected in Algoa Bay and associated estuaries suggesting that conditions are not ideal for the establishment of this species in the wild in this area." a) Please clarify this statement, if the environmental conditions are not suitable for the specie to invade then how will they "thrive" as a mariculture species in the Bay? b) Our very own prawn farms that are now a dilapidated ruin are clear examples of what could go wrong if we do not understand the whole ecosystem.

16. Mitigation: "Ensure a high level of biosecurity management and planning is in place to limit the introduction of new invasive species and to be able to respond quickly and effectivelyshould biosecurity risks be identified." a) Reference to Bio security in an open ocean-based facility seems very unlikely, please clarify how this will work.

"Routine surveillance on and around marine farm structures, associated vessels and infrastructure must be undertaken forindications of non-native species" b) Who does the monitoring and at whose cost, it must be borne in mind that operators may not be too keen on funding such surveillance as that should be the responsibility of the EA holder (if granted)? c) The mitigation measures to manage invasive species coming in via spat and whilst harvesting is supported and must form part of an OEMPr.

"Direct effects on the seabed fromshellfish farms could, under certain conditions, arise through shading fromfarm structures, potentially reducing the amount of light reaching the seafloor, with implications for the growth, productivity, survival and depth distribution of ecologically important primary producers (Everett et al. 1995; Crawford 2003; Huxham et al. 2006)". d) Surely the shading factor is a crucial environmental variable for benthic creatures that needs to be mitigated?

"Shellfishfarm infrastructure could alter hydrodynamics and reduce flow rates and alter current velocities at the farm level." e) Again, not sure why an environmental variable such as hydrodynamics is not mitigated?

ents provided will assist in the assessment.

Dayalan (Jeff) Govender Regional Environmental Manager: Sarah Baartman District/Nelson Mandela Bay Region Date

Pg. 7 of 7

Algoa Bay Aquaculture Development Zone

Our Ref:

Enquiries: Briege Williams Date: Tuesday August 06, 2019 Tel: 021 462 4502 Page No: 1 Email: [email protected] CaseID: 13103

Interim Comment In terms of Section 38 of the National Heritage Resources Act (Act 25 of 1999) Attention: Department of Agriculture Forestry and Fisheries

The Department of Agriculture, Forestry and Fisheries (DAFF), as the lead agent for aquaculture management and development in South Africa, intends to establish and manage a sea-based Aquaculture Development Zone (ADZ) in Algoa Bay in the Eastern Cape.

The South African Heritage Resources Agency (SAHRA) would like to thank you for submitting the Draft Basic Assessment Report for the Algoa Bay Aquaculture Development Zone.

Because of the significant maritime history of Algoa Bay, SAHRA previously advised that a Maritime Archaeological Impact Assessment (AIA) report would be requested as part of the application process. The AIA was produced as part of the Pre-application BAR which SAHRA commented on in April 2019. Since then the size of Algoa 1 has been reduced and the DAFF preferred alternative has changed. These changes have not affected the heritage assessment or the recommendations set out in the AIA.

The proposed work is based in three areas, namely Algoa 1, 6 and 7. The areas Algoa 1 and 7 have been identified as having a relatively low number of historical shipwrecks occurring in their vicinity. However, the area that constitutes Algoa 6 has a high concentration of recorded wreckings, mainly because it encompasses the area of the original landing place for the bay.

The comments that SAHRA issued for the Pre-application BAR remain unchanged and support the mitigation measures set out below.

The maritime AIA has considered the historical significance of all three areas and makes the following recommendations based on the heritage potential in each area.

• Any geophysical data generated to support the development of aquaculture in this area must be archaeologically reviewed for the presence of historical shipwrecks or related material and to ground truth proposed mooring locations. Datasets that are particularly useful in this regard are magnetometer, side scan

Algoa Bay Aquaculture Development Zone

Our Ref:

Enquiries: Briege Williams Date: Tuesday August 06, 2019 Tel: 021 462 4502 Page No: 2 Email: [email protected] CaseID: 13103 sonar and multibeam bathymetric data. It is recommended that the archaeologist is consulted before data are collected to ensure that the survey specifications and data outputs are suitable for archaeological review;

• Any video footage collected support to development of aquaculture in the three areas should ideally also be reviewed by the archaeologist for evidence of shipwreck material on the seabed;

• If geophysical data are not collected, the proposed positions of all moorings must be ground truthed by suitably qualified divers;

• Should the reviews and ground truthing set out above identify wreck material at or near the location of any proposed mooring, micro-siting of the mooring and the possible implementation of an exclusion zone around the archaeological feature should be sufficient to mitigate the risks to the site.

• Should any archaeological material, be accidentally encountered during the course of developing aquaculture operations in any of the proposed areas, work must cease in that area until the project archaeologist and SAHRA have been notified, the find has been assessed by the archaeologist, and agreement has been reached on how to deal with it.

SAHRA reiterates that all efforts must be made to avoid damage and/or disturbance to any cultural heritage material. Should you have any further queries, please contact the designated official using the case number quoted above in the case header.

Yours faithfully

______Briege Williams Heritage Officer

Algoa Bay Aquaculture Development Zone

Our Ref:

Enquiries: Briege Williams Date: Tuesday August 06, 2019 Tel: 021 462 4502 Page No: 3 Email: [email protected] CaseID: 13103

South African Heritage Resources Agency

______Lesa la Grange Acting Manager: Maritime and Underwater Cultural Heritage South African Heritage Resources Agency

ADMIN: Direct URL to case: http://www.sahra.org.za/node/514209

Terms & Conditions:

1. This approval does not exonerate the applicant from obtaining local authority approval or any other necessary approval for proposed work. 2. If any heritage resources, including graves or human remains, are encountered they must be reported to SAHRA immediately. 3. SAHRA reserves the right to request additional information as required.

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Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

57 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

APPENDIX F6: MINUTES OF MEETINGS HELD

58 research & monitoring research & monitoring

ALGOA SEA BASED AQUACULTURE DEVELOPMENT ZONE BASIC ASSESSMENT PROCESS

Date: Wednesday, 6 March 2019. Time: 14:30 – 16:00 Venue: Eastern Cape Department: Economic Development, Environmental Affairs and Tourism 14 Athol Fugard Terrace, Port Elizabeth Central, Port Elizabeth, 6001

Chairperson: Dr Ken Hutchings – Anchor Research & Monitoring (Pty) Ltd

FINAL MINUTES: AUTHORITIES MEETING

1. Welcome & Introductions: Dr Kenneth Hutchings (KH) opened the meeting at 14:35, introduced himself and Anchor Research & Monitoring and welcomed all attendees to the authorities meeting. He explained that Anchor was appointed by the Department of Agriculture Forestry and Fisheries (DAFF) as the Environmental Practitioner (EAP) to assist DAFF with the application for Environmental Authorisation (EA) for the proposed sea-based Aquaculture Development Zone (ADZ) in Algoa Bay.

2. Present & Apologies: KH requested all attendees to introduce themselves. The attendees are listed in the table below:

Name Affiliation Kenneth Hutchings Anchor Research & Monitoring (Pty) Ltd Songezo Mtsokoba Anchor Research & Monitoring (Pty) Ltd Vera Massie Anchor Research & Monitoring (Pty) Ltd Michelle Pretorius Department of Agriculture, Forestry and Fisheries Maxhoba Jezile Department of Agriculture, Forestry and Fisheries Zimasa Jika Department of Agriculture, Forestry and Fisheries Dayalan Jeff Govender DEDEA (Eastern Cape) Andries Struwig DEDEA (Eastern Cape) Xolani Nikelo DEDEA (Eastern Cape) Thembinkosi Tyali DEDEA (Eastern Cape) Neliswa J Piliso DEDEA (Eastern Cape) Gcobisa Mdoda DEDEA (Eastern Cape) Vusi Mthombeni DEDEA (Eastern Cape) Ndileka Nozo DEDEA (Eastern Cape) Lindelwa Twala DEDEA (Eastern Cape) Siyabonga Dlulisa DEA: Integrated Coastal Management Algoa Bay Sea-Based Aquaculture Development Zone – Authorities Meeting 6 March 2019 Final Minutes

Isaac Nokele Nelson Mandela Bay Municipality - Urban Agriculture: EDTA Jill Miller Nelson Mandela Bay Municipality - Public Health H May Mandela Metropolitan Municipality: Directorate Sports, Recreation, Arts and Culture G Murrell Mandela Metropolitan Municipality: Directorate Environmental Management Mandilakhe Mdodana Transnet National Ports Authority - Port of Nqura Zanda Mkhulisi Transnet National Ports Authority - Port of Port Elizabeth Zinhle Small TNPA Brynn Adamson TNPA Cloverly Lawrence SANParks Rob Milne SANParks

Apologies: Leon Els - DEDEA (Eastern Cape)

3. Finalisation of the agenda The Agenda was accepted by all attendees and no amendments were made.

4. Presentation (attached to the minutes) 4.1 Objectives of the meeting: KH provided a brief overview of the project and presented the objectives of the meeting.

4.2 Basic Assessment Process: VM provided an overview of the project timeline. She explained that to date, the pre-application Basic Assessment Report (BAR) has been completed (but not finalised) and that the purpose of this meeting was to present the findings and discuss the results of the studies conducted to date. She emphasised that the pre-application public participation (PP) phase had not yet commenced, but that the first round of PP would be initiated within two weeks of the public meeting. The application and Draft BAR are planned to be submitted by end of May 2019, with the Final BAR submission scheduled for end of August 2019.

4.3 Project description and impact assessment: KH commenced with the presentation, which has been attached to these minutes. KH covered the following content: • Project background (i.e. history) • Project description • Potential finfish and bivalve species • Identification potential ADZ sites • Alternative options (including No-go Option) (see below)

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Option Algoa 1 Algoa 6 Algoa 7 (Summerstrand) (PE harbour) (Coega) A Finfish & Bivalve Bivalve Finfish B Bivalve Bivalve Finfish C X Bivalve Finfish D X X X

• Studies incorporated into the Impact Assessment of 2019 • Impact Assessment method • Marine impact assessment (negative) VM then continued with the presentation covering the following content: • Visual aesthetic impacts (negative) • Socio-economic impacts (positive and negative) • Maritime and Underwater Cultural Heritage • Summary of positive significance ratings • Summary of negative significance ratings • No go option (Alternative Option D) • Conclusions: o DAFF intends to apply for Option A, involving finfish culture at Summerstrand and Ngqura sites and bivalve culture at Summerstrand and PE Harbour sites. o DAFF proposes to implement a phased approach. o Phased approach and adaptive management would be implemented in accordance with the Environmental Management Programme (EMPr). o Implementation of phased approach and adaptive management would be overseen and coordinated by a management structure similar to the one implemented for the Saldanha Bay ADZ. o Based on current impact assessment Option C has the smallest environmental footprint. o EAP likely to recommend Option B or C. o DEA to make a decision based on information presented. Questions on the process and details of the presentation and study approach were not taken during the presentation.

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3. Questions and answers session:

Jeff Govender from DEDEA: • Is there any intention to include land-based fish processing facilities? • Vera Massie (VM) responded that land-based support structures are not included in this assessment process. This application process focuses on the declaration of the sea-based ADZ.

Andries Struwig from DEDEA: • Commented on the processing facility issue. He highlighted that fish processing facilities are vital for the operation of a finfish farm and recommended that DAFF ensures that existing facilities can absorb the initial production volumes. This should be reflected in the Basic Assessment Report. • The SEA section in the report should mention where else in South Africa ADZ have been declared. DAFF confirmed that the only existing sea based ADZ is located in Saldanha Bay. o DAFF responded that a land-based site has been established at Qolora in KwaZulu Natal. • Transfer of responsibility from DAFF to individual operators must be done immediately and must be very strict to ensure that DAFF can comply with the Environmental Authorisation. Provincial DEA has had negative experiences with transfer of responsibility to individual developers. Additional notes: DAFF would be the holder of the EA and would enforce the EA conditions through the issuing of a Marine Aquaculture Right and annual permits. • Issues raised at the ELC meeting held in November 2018 were repeated to enquire whether they had been addressed in the assessment. Most importantly he stated that sewage spills of unknown origin are occurring frequently. This should be considered when declaring an aquaculture site at Algoa 6 (PE Harbour). • Questions whether it is enough to show the impacts of the generic structures, rather than what will actually be implemented by the individual operators. • Some of the indigenous species are on the SASSI list and are prohibited from being sold. How will DAFF ensure that selling farmed SASSI listed species will not encourage illegal sales of wild caught listed specimens (for e.g. the spotted grunter). Ms Zimasa Jika responded that DAFF has experience in regulating the marketing of undersized abalone and even recreational list aquaculture species, noting that product traceability is essential. • Requested clarification on a statement in the presentation regarding the need to establish suitability of cage farming for some species. Is this correct? o Additional notes: Finfish culture is new in South Africa and some of the species in the application have never been farmed in the area and none have been farmed on commercial scale. This is one of the reasons why a pilot phase is recommended (the other reason is to establish whether environmental impacts are likely to be acceptable at full commercial scale). • Disagrees with the fact that the Mediterranean mussel could be farmed if it is already present along this coastline. He argued that for this reason it should not be authorised.

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o Additional notes: It must be noted that mussels are not actively seeded onto ropes, which means that no additional propagules are introduced into the marine environment. The ropes will be left to be colonised by naturally occurring offshore mussel larvae pools (part of the mussel life history is spent offshore). Larvae pools are carried inshore by (1) upwelling-related circulation, (2) internal tidal waves and bores, (3) the local diurnal (or diel) sea breeze, and (4) waves and ocean swell (Pfaff 20151). • The assessment focuses on how the development impacts on the receiving environment, but does not seem to address concerns about how the existing environment may impact on the proposed development. These include (1) ship to ship bunkering. Currently two operators, but more licenses will be granted; (2) sewage spills; (3) dredge spoil. o VM responded that a chapter on the risks to the development has been included in the Basic Assessment Report, which includes the components described in the comment. The report highlights that DAFF is well aware of these risks. She elaborated that establishing feasibility of the development lies outside the scope of the application for environmental authorisation and that DAFF, understanding the potential risks to the proposed ADZ, will submit an application for environmental authorisation. • Requested clarification on the proposed phased approached where at first 1000 t would be farmed within the ADZ and then expanded to commercial scale at a later stage. o KH responded that any farm established in the ADZ would be for commercial purposes, however, expansion to carrying capacity could only commence once it has been shown that the environmental impacts associated with the first phase (i.e. 1000 t) are acceptable. Environmental monitoring (baseline and follow-up) would be critical in understanding the impacts associated with the aquaculture farm. Issuing an authorisation that carte blanche allows production up to an estimated carrying capacity is not considered to be an environmentally precautionary approach. • What is the carrying capacity? o KH responded that the carrying capacity is currently estimated by the hydrodynamic modelling output (study conducted at the end of 2018 by Anchor, to be made available with the other documents), which estimates an amount of fish that can be farmed without causing environmental degradation. In reality, the predicted carrying capacity may be higher or lower than the model predictions. For this reason, environmental monitoring would be critical in implementing an ongoing adaptive management approach. • SANParks should be part of the AMC. DAFF and Anchor agreed to include this in the Environmental Management Programme (EMPr). • Landbased aquaculture should be favoured, an ADZ has already been declared for this purpose. o KH explained that DAFF intends to develop both land-based and sea-based aquaculture. He also pointed out the challenges faced by land-based aquaculture, particularly for finfish farming. It is very expensive to pump water and maintain conditions suitable for

1 Pfaff MC, Branch GM, Fisher JL, Hoffman V, Ellis AG and Largier JL. 2015. Delivery of marine larvae to shore requires multiple sequential transport mechanisms. Ecology, 96(5) 2015, pp. 1399–1410.

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the aquaculture organisms. Land-based aquaculture systems are not included as an alternative in this application for environmental authorisation.

Godfried Murrel from the Metropolitan Municipality: • Highlighted the importance of considering previous objections related to Algoa 1 (Summerstrand). He agrees that by excluding finfish at Algoa 1 many of the original concerns are mitigated. He warned that there will be an outcry again, especially regarding Algoa 1 (Summerstrand). o KH confirmed that Anchor and DAFF are acutely aware of the lack of public support (at least partially, the public meeting showed that there is support for this development from communities that are interested in job creation) and that it is for this reason that DAFF is putting forward three alternative options, of which B excludes finfish farming at Algoa 1 and C excludes Algoa 1 altogether. DAFF is driven by the mandate to develop aquaculture and will apply for Option A. The EAP will, however, likely recommend that Option B or C are authorised due to the potentially high, negative socio-economic impacts of option A. • He informed the attendees that the Municipality is currently being sued for shutting down export of bivalve produce farmed at Algoa 6 (PE Harbour). This is due to the poor water quality in the area.

Rob Milne from SANParks • A number of negative impacts have been mentioned, including interference with wild breeding stock, diseases, genetics, algae blooms and attraction of predators. • SANParks main concern is that Algoa 7 (Ngqura) is situated within the recently approved Addo MPA. An MPA is worth millions due to the fact that the MPA will supply stock to the fishing industry. Impacts on the MPA may translate into reduced benefits to the fishing industry in the long term. • Expressed concern about ship bunkering and repeated that in addition to the two operators more licenses are about to be approved. • Expressed concern about swell conditions near Ngqura harbour and that this could pose a risk to the proposed finfish cages. • Main concern is regarding the impacts on the Addo MPA. • KH explained that the BAR was taking these impacts and risks into consideration.

Cloverley Lawrence from SANParks: • Requested whether the impact of finfish cages on penguins and gannets (in general birds) residing on the islands nearby was considered. • Water quality was not mentioned in the impact assessment. • Algoa 7 is situated near a shark nursery area. • Finfish cages could attract more sharks and how will this impact on recreational users in the Bay.

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• Reminded everyone that Algoa Bay is of interest to a number of user groups and that everyone has to work together in harmony to ensure that all mandates can be fulfilled as best as possible. As soon as one mandate supersedes the others it becomes very difficult for all other entities to meet their objectives.

DEDEA: • Where is the fish stock going to come from? o KH responded that finfish brood stock would be caught in the wild and would be kept at a land-based hatchery where mature individuals spawn under controlled conditions and fry are produced for cage culture. Oyster spat is currently imported, although local hatcheries are currently being developed. Any local hatcheries would be land-based. • How will the monitoring of mitigation measures going to be done? o KH responded that a management structure is proposed, similar to the one implemented for the Saldanha Bay ADZ. This would involve the Aquaculture Development Zone Management Committee (AMC) and the Consultative Forum (CF) as detailed in the presentation.

Vusi Mthombeni from DEDEA (Ecologist) • Concerned about upwelling events and associated Harmful Algal Blooms (HAB) and temperature fluctuations of more than 10 °C within one day. Sea conditions are rough and feasibility is questionable. He would recommend land-based farming over sea-based farming from a feasibility perspective. • His impression is that the aquaculture sector is very reluctant to invest in sea-based aquaculture in Algoa Bay due to feasibility and conflict with other users. • KH responded that his concerns were primarily on a strategic level (i.e. Strategic Environmental Assessment) and related to the feasibility of the proposed development. An SEA was conducted in 2009 and Algoa Bay was identified as a potential site and was comparatively favourable in relation to the rest of South Africa’s coastline. He reiterated that these factors had been taken into consideration and that DAFF was well aware of the challenges and risks. He also emphasised that large companies are currently attempting sea-based finfish cage farming due to the challenges that are faced in culturing finfish on land.

Jeff Govender from DEDEA: • Requested whether he could email his questions on this project and whether Anchor could respond in writing. • KH agreed that this would be a great approach to capture any remaining questions related to this meeting. The questions and response from Anchor would then be circulated together with the meeting minutes. He requested that comments should be submitted within two weeks of this meeting to not delay the finalisation of the minutes.

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• JG also requested whether it would be possible to refer to Algoa 1, 6 and 7 by stating the location, i.e. Summerstrand, PE Harbour and Ngqura. Stakeholders would be able to follow the discussion more easily. • KH agreed that this was a good idea and that this would be done for the presentation to the public.

Ms Zimasa Jika from DAFF: • DAFF has looked at fish processing facilities in this area. These facilities are readily available and the capacity could be quickly created and would not pose a problem to the proposed ADZ. Wild caught and farmed fish can be processed in the same facilities. • Pollution issues are covered according to the legislation and the environmental legislation is implementing the ‘polluter pays principle’. • DAFF has substantial experience in selling fish species that are listed on SASSI, including undersized specimens. For example dusky kob was sold in a lot of supermarkets. Products have to be labelled as farmed products and have to be traceable, which is achieved by inserting specialised hooks with barcoding that shows where the fish originated. It should also be noted that spotted grunter has been farmed in South Africa and will be sold on South African markets next month.

Captain Brynn from Transnet • Finding suitable sites was a challenge. • It is important to take cognisance of incidents that have occurred around existing farms in Algoa Bay. e.g. collisions and pollution. • VM noted that Captain Brynn had arrived after the different sites had been discussed and clarified that the site selection process had already been completed. She suggested to have a more detailed conversation after the meeting.

The method of circulation of the reports was discussed at the meeting. Government departments are generally unable to access documents via Dropbox. While DAFF is able to send and receive documents via WeTransfer, DEDEA confirmed that this does not seem to be an option yet. VM clarified that it was not possible to send a hard copy to every government Department (The cost of this would be: R3 600 per Department including printing and courier costs). National DEA will be the only Government institution to receive hard copies. Anchor will make every financially feasible effort to ensure that the BAR is received by Government Institutions.

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4. Closure: KH closed the meeting at 16:12.

APPROVAL OF THE MINUTES BY THE CHAIRPERSON

Dr Kenneth Hutchings

SIGNATURE DATE: 16 March 2019

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ALGOA SEA BASED AQUACULTURE DEVELOPMENT ZONE BASIC ASSESSMENT PROCESS

Date: Wednesday, 6 March 2019. Time: 18:00 – 20:30 Venue: City Hall, Main Hall Reception Area, Govan Mbeki Ave, Port Elizabeth Central, Port Elizabeth, 6001

FINAL MINUTES: PUBLIC MEETING

1. Welcome & Introductions: Dr Kenneth Hutchings (KH) introduced himself and Anchor Research & Monitoring and welcomed all attendees to the public meeting. He explained that Anchor was appointed by the Department of Agriculture Forestry and Fisheries (DAFF) as the Environmental Practitioner (EAP) to assist DAFF with the application for Environmental Authorisation (EA) for the proposed sea-based Aquaculture Development Zone (ADZ) in Algoa Bay.

2. Matters to be Discussed (Presentation attached to the minutes) 2.1 Objectives of the meeting: KH provided a brief overview of the project and presented the objectives of the meeting. He explained that as the environmental consultants, Anchor also represents the aquaculture and marine specialist for this project.

He elaborated that Vera Massie (VM) would address matters related to the Basic Assessment process, and components of the impact assessment other than the marine impacts (i.e. visual, socio-economic and heritage resources impact assessments). He clarified that the maritime Heritage Impact Assessment was conducted by ACO Associates, which are qualified heritage resources specialists.

2.2 Basic Assessment Process: VM provided an overview of the project timeline. She explained that to date, the pre-application Basic Assessment Report (BAR) has been completed (but not finalised) and that the purpose of this meeting was to present the findings and discuss the results of the studies conducted to date as well as to solicit information from the public regarding their concerns with the project. She emphasised that the pre- application public participation (PP) phase had not yet commenced, but that the first round of PP would be initiated within two weeks of the public meeting. The application and Draft BAR are planned to be submitted by end of May 2019, with the Final BAR submission scheduled for end of August 2019. VM then provided detail on the public participation process, emphasising that there would be two 30 day commenting periods for this project. She also explained what the minimum statutory participation requirements entail and additional measures that have been and would be implemented to ensure comprehensive consultation of the public. Algoa Bay Sea-Based Aquaculture Development Zone – Public Meeting 6 March 2019 Final Minutes

KH commenced with the presentation, which has been attached to minutes. KH covered the following content: • Project background (i.e. history) • Project description • Potential finfish and bivalve species • Identification potential ADZ sites • Alternative options (including No-go Option) (see below)

Option Algoa 1 Algoa 6 Algoa 7 (Summerstrand) (PE harbour) (Coega) A Finfish & Bivalve Bivalve Finfish B Bivalve Bivalve Finfish C X Bivalve Finfish D X X X

• Studies incorporated into the Impact Assessment of 2019 • Impact Assessment method • Marine impact assessment (negative) VM then continued with the presentation covering the following content: • Visual aesthetic impacts (negative) • Socio-economic impacts (positive and negative) • Maritime and Underwater Cultural Heritage • Summary of positive significance ratings • Summary of negative significance ratings • No go option (Alternative Option D) • Conclusions: o DAFF intends to apply for Option A, involving finfish culture at Summerstrand and Ngqura sites and bivalve culture at Summerstrand and PE Harbour sites. o DAFF intends to implement a phased approach. o Phased approach and adaptive management would be implemented by means of the Environmental Management Programme (EMPr). o Implementation of phased approach and adaptive management overseen and coordinated by management structure similar to the one implemented for the Saldanha Bay ADZ. o Based on current impact assessment Option C has the smallest environmental footprint. o EAP likely to recommend Option B or C. o DEA to make a decision based on information presented. Questions on the process and details of the presentation and study approach were not taken during the presentation.

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3. Questions and answers session: Note that the minutes of the meeting do not capture each comment, but rather summarise the aspects discussed at the meeting and the response provided by anchor or DAFF on the topic, if applicable. Any questions or comments that Anchor did not address in the meeting or additional information have been answered in these minutes and have been recorded in italics.

3.1 Comments provided in favour of the proposed development were provided by the Khoisan fishing community as well as previously disadvantaged community members of Port Elizabeth: • Importance of ensuring that the local community would benefit from this development if it was approved. • Recommendations on how the local community could benefit: o Manufacture fish cages in Port Elizabeth o Train and utilise divers from the local communities o Feed manufacturing could be done locally o The Khoisan fishing community representative suggested that the fish cages could possibly be constructed in such a way that the waste can be extracted from the cages and used on land-based aquaponics aquaculture facilities. • It was emphasised that the sea should be accessible to and benefit everyone. Tourism, conservation and recreation should not be the only aspect taken into account. • It was emphasised that the aquaculture sector is still untransformed and that small and medium enterprises should benefit.

3.2 Comments against the proposed development were provided by residents who have an interest in conservation, recreational activities and the tourism economy of Port Elizabeth: • It was tabled that the majority of people are not against the development per se, but that the location of Algoa 1 is the problem, being located in the aquatic sports capital of South Africa. This site should not be considered. • It was argued that due to the large capital investment, corporate companies would be more likely to benefit and not small and medium enterprises. • This is an expensive experiment, there is too little known whether this proposed project will be realised with actual benefit to the people (emphasis on local people). The potential negative impacts could be high and if the project is not realised after trials, it may be too late for Algoa Bay. The appropriate option may be the No-Go option (Alternative Option D) or maybe Option C – Finfish at Ngqura and Bivalve at PE Harbour). Cumulative impacts in Algoa Bay are constantly increasing (reference to shipping and industry). o DAFF responded that South Africa is one of the most unequal societies in the world and that DAFF is also in the business of creating jobs and opportunities and to boost the South African economy. DAFF acknowledged the comment that there is only “one Algoa Bay” and responded that it must be considered that there are very few sites along the coast that are suitable for aquaculture.

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3.3 Comments regarding the public participation process: • The meeting should be held at a location more accessible to previously disadvantaged community members of Port Elizabeth, who have an interest in the jobs and skills that could arise from this project. o Anchor responded that a more appropriate venue will be explored for the next meeting. • WESSA appealed to everyone to recognise that South Africa is one of the most unequal societies in the world and that spatial segregation implemented during Apartheid is still evident in Port Elizabeth. This participation process could easily turn into a racially charged debate between Summerstrand and Motherwell residents. This really should be avoided, and it should be recognised that Hobie Beach is utilised by many communities living in Port Elizabeth. The process should be constructive rather than combative.

3.4 Comments regarding impact assessment: • The Airport Company South Africa (ACSA) is concerned about the fact that the ADZ is located within the flight path of the PE Airport. Fish cages attract birds and fish processing even more so. This would pose a serious threat to airplanes passing over the ADZ. Furthermore, this concern was raised during the appeal phase of the previous EIA process and does not seem to have been addressed in the pre-application BAR. o DAFF and Anchor responded that this issue will be included in the BAR to be published within the next two weeks. (Additional notes: Only piscivorous, low-flying sea birds will be attracted to large concentrations of fish and food in sea cages at Algoa 1 and 7 and include sea gulls, gannets, cormorants and terns. High-flying migratory flocks of birds such as geese, ducks, and starlings will not be attracted to the cages. The risk of collision with seabirds is therefore improbable even without mitigation measures. Essential mitigation measures to prevent seabirds from gaining access to the cages are proposed in the marine specialist assessment. The additional risk posed by the finfish cages is considered to be relatively small as the cages are unlikely to alter flight path height of the bird flocks.) o Anchor further clarified that fish processing is not permitted at sea and that this would occur at fish processing factories on land. Furthermore, cages would be covered with predator nets to prevent birds from gaining access. With the implementation of appropriate mitigation measures (i.e. predator nets), the absence of a food reward means that seabirds are unlikely to be attracted to the cages. • A quantitative approach was not taken to assess socio-economic impacts (including concerns that total capital investment and number of jobs created were not quantified), which is problematic when weighing up positive (desirability) and negative socio-economic impacts against each other. o KH responded that estimates for job creation have been provided in the BAR (also see additional comment provided in the question section of the minutes), which were sourced from the socio-economic specialist study that was conducted for Algoa 1 (Summerstrand) and 5 (Addo MPA) in 2016 by the Rhodes University (comparative

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assessment 2016). KH further elaborated that a realistic quantitative cost and benefit study is not possible to do at this stage. This is due to the lack of existing established sea-based finfish culture facilities within SA. Additional note: Due to the lack of quantitative evidence, impacts are rated with low confidence, which must be considered when weighing up positive and negative impacts against each other (i.e. need and desirability versus negative impacts). o KH also highlighted that feasibility studies for farming of finfish in South Africa have been conducted by consultants appointed by DAFF (Feasibility Study of Marine Finfish (Dusky kob and Atlantic salmon) Aquaculture in South Africa, 2017). o KH explained that the quantitative determination of whether the ADZ is indeed the most desirable development for Port Elizabeth is well outside the scope of the application for Environmental Authorisation. It has been decided on a national level (i.e. Operation Phakisa – Ocean’s Economy) that aquaculture is to be promoted in South Africa. There are limited opportunities along South Africa’s coastline to implement sea-based aquaculture. Algoa Bay has been identified as a suitable site. Additional note: The Basic Assessment Report must cover the “Need and Desirability” of the proposed development, as this is a factor that is taken into consideration by the DEA when issuing a decision on the application. Essentially the means have to justify the ends. However, it is not possible to quantify this due to the lack of South African examples of sea-based finfish aquaculture. The most detailed information that can be included in the motivation is the potential number of jobs and opportunity that could be created as a result of this development (as included in the BAR). Finally, although provincial and municipal development plans must be considered when describing the “Need and Desirability“ of a project to ensure that it is in line with the development goals of the area, it is not a requirement to prove to the DEA that this development is “the most desirable” option when compared to any number of unknown, potential development alternatives for Port Elizabeth. • Adding up impact ratings from different impact categories means that each impact is given an equal weighting. This is not realistic. o No response was provided during the meeting. o Additional note: This method which attributes an equal weight to all identified impacts is certainly not perfect, but Anchor found this to be the only way to succinctly present the total impact that the alternative options (A, B and C) are likely to have. It should be noted that each person has a different view on which impact types are most important. Socio-economic impacts will be most important to people who will be most affected economically. Impacts on marine ecology and birds on the other hand will constitute the more important impact to a conservationist (this is perfectly illustrated in that Algoa 7 is more favourable in terms of socio-economic impacts, while Algoa 1 would have a substantially lower impact on the marine ecology of Algoa Bay). The development of weighting criteria for identified impacts would therefore be an entirely subjective exercise. Different people are likely to propose entirely different weightings. This issue and question in essence describes the challenges faced by the EAP and the

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decision-making authority when considering all impacts in making a recommendation/decision. • Site 6 and 7 are not going through a full EIA process, which would mean that the impacts on those sites would be assessed in much less detail as part of the Basic Assessment process (no scoping phase). KH responded that: o The public participation process is the same, if not longer when compared to the initial EIA process (i.e. 60 days to comment, two public meetings) o The same data was collected for the new finfish site Algoa 7 (Ngqura), i.e. bathymetry, sediment, macrofauna, and water quality. Existing research data for Algoa 6 was incorporated into the Benthic Study. Additionally, while the previous EIA process did not include dispersion modelling for calculating carrying capacity estimates, this BAR does include a specialist study covering both finfish sites. o Additional note 1: The socio-economic specialist studies (2013 and 2016) conducted for Algoa 5 (Addo) would not have to be repeated for Algoa 7 (Ngqura) by a specialist due to the fact that the impacts are very similar and could be assessed by the EAP. The detail in which Site 6 and 7 were assessed is certainly comparable to what had been done as part of the previous EIA process for Algoa 1 (Summerstrand) and Algoa 5 (Addo). o Additional note 2: An additional specialist study was compiled as part of the BAR to assess Heritage Impacts, which had not been done as part of the previous EIA process. • Algoa 7 (Ngqura) is situated near St Georges Beach which is a popular bathing beach. The risks to this beach posed by finfish farming should be assessed in the impact assessment, especially considering that a shark attack had occurred on this beach before. o KH responded that the impact on recreational activities at Algoa 7 had been considered, but that care would be taken to re-assess the impact ratings. • A description of the waste originating from finfish cages should be included in the impact assessment. Especially the type of waste found in the upper metre of the water column that would be rapidly dispersed towards the shore by the prevailing wind and whether this would pose a health risk to beach users. o KH responded that this could certainly be included in the BAR. However, he emphasised that waste from finfish cages constitutes an ecological concern more so than a health concern. o Additional note: Human health concerns in the marine environment are generally related to microorganisms such as bacteria, viruses and parasites. Contaminated water can be ingested during contact sports and result in gastrointestinal illnesses. Escherichia coli and Enterococci are generally used as indicators for the presence of these harmful microorganisms. It is important to note that finfish farms are not a source of bacteria, viruses and parasites that could harm humans. Harmful microorganisms are excreted by warm-blooded animals (e.g. cow, pig, ostrich, humans) and are washed into the sea via rivers, outfall pipelines or stormwater drains.

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• Wind should be taken into account in Port Elizabeth. Wind influences currents and upwelling. The person commenting was concerned that the impact of wind would be swept under the carpet. o KH responded that wind as the primary driving force behind currents, swell, and upwelling conditions are certainly taken into account in this assessment and is not being swept under the carpet. With regards to the infrastructure itself, the individual operators need to make sure that their structures can withstand the local conditions. o Additional note: Wind as the driving force itself cannot be assessed as an impact. However, wind was considered in the following example, which is included in the marine specialist study: “Potential impact OP-ME3: Genetic impacts on wild fish stocks”. Damaged cages allow finfish to escape and interbreed with the local population of the same species. This can impact on the genetic makeup of the local fish population. Cages can be damaged by deep ocean swell (deep powerful swell resulting from weather systems approaching Algoa Bay) or wind swell (localised swell resulting from strong winds). In both cases, “wind” is not the impact, but is the driving force behind the observed impact of genetic contamination. Furthermore, “Potential impact OP-ME2: Organic pollution from finfish sea cages” in the marine assessment also considers wind. Organic pollution arising from finfish cages is dispersed by currents, which in inshore regions are primarily wind driven. o The impact assessment needs to focus on the impacts of the development on the receiving environment and not vice versa. This is the reason why risk to the aquaculture farm is not assessed in impact tables (e.g. impact of swell on cage structure). However, these issues have certainly been considered when discussing the feasibility of the proposed development (a feasibility assessment precedes an Environmental Impact Assessment).

3.5 Questions raised by attendees and answers: • What is the objective of the project? o Anchor response: Economic growth in the marine aquaculture sector, which is one of the mandates of DAFF. • Why is abalone not considered for this project? o Anchor did not provide a clear answer to this question at the meeting and a response has been included in these minutes: Abalone are currently successfully either ranched (near natural conditions) or farmed on land (strictly controlled environmental conditions). Some companies have experimented with growing abalone in offshore baskets (like oysters) but this does not appear to be a viable culture method. Furthermore, protecting a sea-based abalone farm against abalone poachers would likely pose a serious challenge. • Option C is the alternative with the lowest environmental footprint. Is Option A therefore off the table? o Anchor explains that DAFF will apply for Option A, which is the most economically beneficial option. However, the Department of Environmental Affairs is the decision

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making authority and will take into consideration the need and desirability of the project, as well as the negative impacts when issuing a decision on whether Environmental Authorisation should be granted for Option A, B or C or not at all (i.e. Option D). • Even if DAFF ensures that environmental concerns are addressed during the phased approach, what mechanisms are in place to ensure that operators adhere to legal requirements? o DAFF responded that individual operators will be contractually bound to DAFF and will be required to apply for a Mariculture Right and annual permits (the right forms the basis of the annually renewed permits and is valid for 15 years). o Anchor also added that the Aquaculture Development Zone Management Committee and Consultative Forums will also oversee the adherence to legislative requirements. • Who is the landlord for individual operators? o DAFF/KH responded that the landlord would be Transnet National Port Authority for the sites that lie within the boundaries of the Port. VM suggested to confirm this with Transnet and include a map in the report to show this clearly. Additional comment: A lease agreement would be signed by both parties as per the National o The Sea-Shore Amendment Act 1993 (No. 190 of 1993) prohibits Ports Act (Act No 12 of 2005), any relevant regulations and guidelines promulgated thereof. Furthermore, the erection of buildings and structures and the laying of pipes below the high-water mark on the sea shore or in the sea without a lease in terms of the Act. In 2014, the Seashore Act was repealed with regards to the functions and powers of the Minister, but not with regards to the functions and powers of Provincial Departments. Coastal Lease Agreements are issued by the provinces (different institutions and processes). Recognising that this provincial level system has to be repealed by a consolidated national system in terms of ICMA, the provinces were assigned the responsibility to repeal the applicable sections of the Seashore Act once a replacement system is in place and effective. None of the provinces have repealed the Seashore Act and hence, coastal lease agreements are still issued via existing administrative processes. • Are the EAP’s recommendations considered in the decision-making process? o Anchor responded that the Competent Authority (i.e. National Department of Environmental Affairs) will consider all documents at hand, including the recommendations by the EAP in issuing the decision. • Will the old environmental authorisation simply be resurrected? There is the impression that the ADZ has already been approved. o Anchor responded that DAFF withdrew the previous application altogether and decided to submit an entirely new application to DEA. Anchor emphasised that the current application will also be submitted in terms of the 2017 Regulations, which requires a Basic Assessment process. This means that the application is started from scratch. However, previous outcomes and appeals will form part of the new decision issued by the DEA. • Is the Environmental Management Programme (EMPr) instead of an EIA not a way to bulldoze the process through?

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o Anchor responded that the EMPr is certainly not a way to bulldoze the process through. The EMPr is a component of the Basic Assessment Report (BAR) and is required in all Environmental Impact Assessments. The EMPr essentially outlines how a development must be managed and constitutes the key document in ensuring that mitigation measures are implemented as required in the Environmental Authorisation. It also constitutes a tool to implement the desired adaptive management approach, which is very important in ensuring that environmental thresholds are not exceeded. However, the impact assessment process (including public participation) remains the most important process in assisting the DEA in making a decision whether a development should be granted Environmental Authorisation or not. • How were the sites selected and why Algoa Bay? o KH explained that a National Strategic Environmental Assessment was conducted in 2009, which selected Algoa Bay as a potential site for finfish culture. He explained that there are very few sites along South Africa’s coastline that are suitable for sea-based aquaculture. He also emphasised that over the last 10 years, seven sites have been considered within Algoa Bay and that DAFF is going to apply for the three sites discussed today. This process is no longer about considering new sites. • Why not land-based aquaculture? o KH responded that DAFF intends to promote land-based AND sea-based aquaculture, not one or the other. Land-based aquaculture is therefore not an alternative activity in this application. Additional notes: the DAFF has already identified other land based ADZ sites around the country and is moving forward with these sites, the current application considers sea-based sites. • How many jobs will actually be created? How many of the jobs created will be provide opportunities for local people? For what period of time will there be jobs? The potential benefits must be clearly defined. o KH responded that it is very difficult to exactly quantify how many jobs will be created by such a development as this is a BA for declaration of an area of sea space where certain types of mariculture may take place in the future. In other words, this is about gazetting zonation, and the details of potential developments (actual operating models of potential future farmers) are not known in detail at this stage. The assessment is by necessity generic. This is due to the fact that number of jobs created is dependent amongst other factors, the species farmed, the scale of the development and the operating procedures of future farmers. o Additional note: Excerpt from the BAR: “Direct employment in the production component of an offshore finfish farm in Algoa Bay is expected to roughly 50 employees for a 1000t/annum scale operation (1 employee per 20 ton) and 80 employees for a 3000t/annum commercial unit (1 employee per 37.5 tons) (Britz et al. 2016)”. To quantify exactly how many local jobs will be created is not possible at this stage. The impact assessment lists the prioritising of local job opportunities and skill development as a benefit-enhancing measure.

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• Surface water movement as a result of strong winds was not previously taken into consideration. Does the dispersion modelling study conducted in 2018 consider wind? (This question was followed by a statement that this should be considered in the impact assessment as finfish waste could wash up on Summerstrand beach): o KH responded that the study did not consider wind driven near-surface currents for the dispersion of the waste originating in the cages (although measured currents at the depth in the water column equivalent to the cage bottom were utilized in modelling). Most of the waste produced in a finfish cage sinks to the bottom as faeces and excess food (Additional: note: minimised by strict feeding methods, feed is a major expense for an operator and will not be wasted). He acknowledged that some wastes such as oils or fats may float on the water surface but emphasised that an additional modelling study would not be conducted at this stage of the project. Modelling at this point is a theoretical exercise and additional modelling would unlikely change the rating of the impact assessment with regards to the waste discharge into the marine environment. Anchor strongly emphasised the importance of monitoring and adaptive management for this type of development. o Additional note: Our modelling consultant confirms that wind induced currents within the first metre of the water column is usually not considered when modelling dispersion of waste from finfish cages. • What is the plan to grow the Small and Medium Enterprises in the aquaculture sector? o KH responded that although the supporting of SMMEs is considered in the impact assessment as a mitigation measure, the development of a plan of how to achieve this lies outside of our tasks as environmental consultants. • Will the applicant/operator have to inform DAFF what will be fed to the finfish? The concern is around the feeding of smaller fish, which could contribute towards the depletion of the ocean as more small fish must be fed to larger fish. o KH responded that the Marine Aquaculture Right and permits would specify requirements regarding the feed that is to be used. Feeding wild caught fish is mainly used in tuna ranching but is unlikely to be approved in South Africa. Finfish cage farming focuses on optimising pelleted feed with the view to minimise the Food Conversion Ratio (kilograms of feed required to produce 1 kg of farmed fish) and the cost to feed the farmed fish. Pelleted feed is currently used in most fish farming internationally and in the experimental cages in Saldanha Bay. • WESSA requested to put the following three question on record: o Is DAFF pre-empting marine spatial planning with this development? There is a unit at the Nelson Mandela University which currently looks at the spatial planning of Algoa Bay. Additional note: Given that the spatial planning component of the Algoa ADZ was initiated as early as 2009 in the SEA phase, it certainly pre-dates (but not necessarily pre-empts) the recently established NMMU academic unit. The DAFF is a key Department in the Marine Spatial Planning process and is ensuring that fisheries and aquaculture is considered in this process.

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o Algoa 6 (PE Harbour) lies above a ship graveyard. Has this been covered in the impact assessment? • VM responded that this had been addressed in the maritime heritage resources study conducted by ACO Associates. o Would the finfish cages impact on sand movement along the coast? The beaches at Summerstrand are supplied from Cape Recife area. • KH confirmed that a hydrodynamic sediment modelling study was not conducted as part of this impact assessment. He responded that based on his knowledge, the two mechanisms by which sand is supplied to beaches are primarily aeolian (i.e. sand transported by wind from the land into the sea) and by means of long-shore currents in the nearshore (<10m depth) (Additional note: Rivers also supply the coastal environment with sediment). Long-shore drift is caused by currents flowing parallel to the shore, redistributing sediments along the coast. Algoa 1 (Summerstrand) is an offshore site and is situated well outside of the long-shore drift zone. Furthermore, cages and their moorings are unlikely to hinder sediment movement, unlike solid structures [such as jetties, groynes or reclamation of land]. o Is the south-west corner of Algoa 1 (Summerstrand) excluded due to the positioning of the Bell Buoy? • KH responded that the shape was due to one of the exclusionary criteria that were applied by a GIS mapping exercise during the SEA phase. This question of whether this had anything to do with the bellboy could not be answered confidently during the meeting and a map has been included to demonstrate that the Bell Buoy is not the reason for the shape of southwest Algoa 1.

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3.6 Other comments: • A stakeholder in favour of the development addressed DAFF and requested that more information about aquaculture in general would be brought to people in the PE area. Plans should be put in place to develop skills, provide SMMEs an opportunity to enter business and to provide jobs. He emphasised that people are impatient and want this development to go ahead. o DAFF responded that the declaration of the ADZ is the very first step in promoting sea- based aquaculture in this area. DAFF understands that the aquaculture sector requires transformation, capacity building and skills development. Such efforts, however, go well beyond the first step, which is to apply for Environmental Authorisation and, if a positive decision is issued, the declaration of the ADZ. • Have the following risks to the development been taken into consideration: Red tide, Bunkering, Land-based discharges, Offshore bunkering, Sewage spills (flooding of Baakens River) o VM responded that the focus of the environmental impact assessment must be on the impacts caused by the proposed development on the environment and not vice versa. Therefore such impacts are not covered in the impact assessment per se. However, a chapter on the risks to the development has been included in the Basic Assessment Report, which includes the components described in the comment. The report highlights that DAFF is well aware of these risks.

4. Closure: VM informed all attendees that the presentation and minutes of this meeting would be made available to all attendees as soon as possible. VM reminded the attendees that the public participation period would commence within two weeks of the meeting and that the reports would be made available for a commenting period of 30 days. She encouraged all attendees to provide written comment once the reports were made available and within the commenting period provided. KH closed the meeting at 20:30.

APPROVAL OF THE MINUTES BY THE CHAIRPERSON

Dr Kenneth Hutchings

SIGNATURE DATE 14 March 2019

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ALGOA SEA BASED AQUACULTURE DEVELOPMENT ZONE BASIC ASSESSMENT PROCESS

Date: Wednesday, 31 July 2019. Time: 18:00 – 20:30 Venue: City Hall, Main Hall Reception Area, Govan Mbeki Ave, Port Elizabeth Central, Port Elizabeth, 6001

FINAL MINUTES: PUBLIC MEETING

1. Welcome & Introductions: Dr Kenneth Hutchings (KH) introduced himself, Anchor Research & Monitoring and the Department of Agriculture, Forestry and Fisheries (DAFF), and welcomed all attendees to the public meeting. He explained that Anchor was appointed by the Department of Agriculture Forestry and Fisheries (DAFF) as the Environmental Practitioner (EAP) to assist DAFF with the application for Environmental Authorisation (EA) for the proposed sea-based Aquaculture Development Zone (ADZ) in Algoa Bay.

2. Matters to be Discussed (Presentation attached to the minutes) 2.1 Objectives of the meeting: KH explained that the purpose of this meeting was to present the outcomes of the pre-application public participation process and how comments provided by stakeholders were considered in the Draft BAR. He also explained that as the environmental consultants, Anchor also represents the aquaculture and marine specialist for this project. He elaborated that Vera Massie (VM) would address matters related to the Basic Assessment process, and components of the impact assessment other than the marine impacts (i.e. visual, socio-economic and heritage resources impact assessments).

2.2 Basic Assessment Process: KH provided an overview of the project timeline. He explained that the non-statutory pre-application phase had been concluded and that comments submitted during the commenting period had been considered in completing the Draft Basic Assessment Report (BAR). He informed all stakeholders that DAFF had submitted the application for Environmental Authorisation on 22 July 2019 and that I&AP could submit their comments until 28 August 2019.

He further elaborated that DAFF had 90 days to complete the Final BAR, which will be submitted for decision-making by 21 October 2019. The Competent Authority (National Department of Environmental Affairs) has 107 days to make the decision (Additional Note: that the period from 15 December until 5 January is excluded from any time frames pertaining to environmental authorisations). A decision is therefore to be issued by the 27 February 2020. Stakeholders were also made aware of the appeal process.

Algoa Bay Sea-Based Aquaculture Development Zone – Public Meeting 31 July 2019 Final Minutes

KH and VM commenced with the presentation, which has been attached to minutes. KH and VM covered the following content: • Very brief project background (i.e. history) (KH) • ADZ definition (KH) • Project overview (KH) • Alternative options (including No-go Option) (see table below) (KH) • Public participation process and outcomes (VM) • Changes to the BAR (KH and VM) • Summary of Alternative Option preferred by DAFF (VM) • Recommendations by the EAP • BA process timeline and appeal procedure

VM emphasised that it is important to note that, based on the revised significance of negative economic impacts linked to finfish farming at Algoa 1 Option 1 from ‘medium’ to ‘high’ after implementation of mitigation measures, DAFF has revised its priorities in respect of mariculture in Algoa Bay and has nominated Option B as the preferred Alternative Option. Alternative Option B involves: Mussel and oyster farming at Algoa 1 Option 1 (Summerstrand site) Mussel and oyster farming at Algoa 6 (PE Harbour site); and Finfish farming at Algoa 7 (Ngqura Harbour site)

Option Algoa 1 Algoa 6 Algoa 7 (Summerstrand) (PE harbour) (Coega) A Finfish & Bivalve Bivalve Finfish B (DAFF preferred) Bivalve Bivalve Finfish C X Bivalve Finfish D X X X

Questions on the process and details of the presentation and study approach were not taken during the presentation. VM informed all attendees whether copies of the Draft BAR can be accessed.

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3. Questions and answers session: Note that the minutes of the meeting do not capture each comment, but rather summarises the issues discussed at the meeting; and the response provided by Anchor or DAFF on the topic, if applicable. Any questions or comments that Anchor did not address in the meeting or additional information have been answered in these minutes and have been recorded in italics.

3.1 The decision by DAFF to remove finfish culture at Algoa 1 from their application was well received by most attendees.

3.2 Comments provided in favour of the proposed development were provided by the Khoisan fishing community as well as previously disadvantaged community members of Port Elizabeth: • Importance of ensuring that the local community would benefit from this development if it was approved. • Recommendations on how the local community could benefit: o Manufacture fish cages in Port Elizabeth o Train and utilise divers from the local communities o Feed manufacturing could be done locally o The Khoisan fishing community representative suggested that the fish cages could possibly be constructed in such a way that the waste can be extracted from the cages and used on land-based aquaponics aquaculture facilities. • It was emphasised that the sea should be accessible to and benefit everyone. Tourism, conservation and recreation should not be the only aspect taken into account. • It was emphasised that the aquaculture sector is still untransformed and that small and medium enterprises should benefit. A commercial diver attended the meeting and hopes were expressed that he could find employment should environmental authorisation be granted. • Aquaculture employs a lot of people and it was felt by some attendees that the focus was only on the negative aspects of the proposed development. It was pointed out that technologies are evolving to mitigate some of the negative impacts. The first priority should be food security in this country, which has an unemployment rate of 38% and people are going hungry (it is not a matter of saving recreational activities). It was emphasised that the sea belongs to everyone and activities should benefit everyone and people who are struggling are being excluded. It should be noted that every activity that we do has a negative impact. It should also be questioned who benefits from Iron Man, it is not the local communities who are benefiting from Iron Man.

3.3 Comments against the proposed development were provided by residents who have an interest in conservation, recreational activities and the tourism economy of Port Elizabeth: • We are failing to manage our wild food resources and it is worrisome that a finfish farm is proposed to be situated adjacent to the Addo Marine Protected Area (MPA). The concern is that more fish would be caught in the waters surrounding St Croix Island to feed to the farmed fish, thus reducing the penguins immediate food supply and forcing them to swim ever greater distances in search of food. This will have a high impact on our wild fish stocks.

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o Anchor responded that it is true that globally, in many cases we have been mismanaging our wild fish stocks. Most fish stocks are no longer sustainable and aquaculture provides roughly 50% of the seafood that we eat today. This trend is mirroring what happened on land, where we hunted many large mammals to extinction in the wild, we started cultivating and domesticating animals and we are now deriving most of our meat from farm production. With regards to feeding wild caught fish, cultured finfish are for a variety of logistical reasons usually fed formulated pellets. These pellets typically include protein from relatively low-value shoaling species such as sardines and anchovies or derived from offcuts during fish processing. Due to the increasing demand for fish meal, there are ongoing efforts to source alternative protein sources for aquaculture feed although for example, using soy is not necessarily the optimal environmental solution either. In SA only holders of small pelagic fishing rights are permitted to purse seine sardines and anchovies. Numerous restrictions govern their activities and right holders are prohibited from fishing inside the restricted zone of the MPA. Pellet feed for finfish is made from fishmeal produced from anchovies and sardine off-cuts. However, individual aquaculture operators will be required to purchase fish meal from existing right holders (fishing right applications are a separate process and are not included in the ADZ application). To ensure a sustainable fishery, DAFF determines the Total Allowable Catch (TAC) for each species. The TAC will therefore not increase to meet an increased demand in the aquaculture sector. Due to the proclamation of the MPA, which includes the St Croix Island group, feeding grounds of penguins and other seabirds will be protected in from over exploitation in future. • It was emphasised that the food produced would not benefit Port Elizabeth and surrounding communities. This food would be exported in the manner that squid is exported. o Anchor responded that the squid industry employs approximately 1700 people in the Port Elizabeth area and the catches have a significant foreign exchange value. The employment created in this area is contributing to the well-being of many families. Even if the squid is not consumed the activity generates economic benefits. o DAFF added that in terms of bivalve culture in South Africa, most of the yield is sold on the local market as it is cheaper to supply the local market than export overseas. Exporting is only possible financially once the farm reaches a certain economy of scale. (note that this is not applicable to abalone).

3.4 Comments regarding the public participation process: • Alternative methods for commenting should be provided as some individuals, especially in previously disadvantaged communities who in some cases do not have access to internet. • The meeting should be held at a location more accessible to previously disadvantaged community members of Port Elizabeth, who have an interest in the jobs and skills that could arise from this project. The public participation process should not be confined to this area. o Anchor responded that this was raised in the previous public participation process and that a meeting was planned for the 1 August 2019 at the Motherwell Community Hall. It

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was emphasised that it was not feasible to visit all areas to involve all communities and that the focus should be on the communities that will be directly impacted by the environmental impacts of the proposed development. Motherwell is the closest community to the Ngqura Harbour site and the meeting will therefore be held there. It was also emphasised that announcements were made on Nkqubela Radio to alert people of the public participation process. Additional note: one of the stakeholders who attended the meeting at the Motherwell Community Hall on 1 August 2019 spoke to the Motherwell Library where the hard copy and CDs of the BAR were made available to investigate whether the library would be willing to collect hard copy written comments for submission. Unfortunately, this request was denied. • Johann Dreyer claimed that he should have been contacted earlier as he leases a large stretch of land along the coastline (30 km) in the Cape Recife area. He claimed that he had plans to create large numbers of jobs (30 000) by utilising this land, one of which activities would be aquaculture. He requested that his land be included in the impact assessment process for future aquaculture facilities. This land constitutes an area where wild abalone was a significant resource in this area and queried why abalone was not covered in this application. o Anchor apologised that he had only heard about this project during the application- phase of this project, however, most importantly that he had an opportunity to provide comment during the legal application-phase public participation phase. It was emphasised that Anchor has met the legal requirements for the stakeholder consultation process (reference to Stakeholder Consultation Report in Appendix F was made) o DAFF emphasised that this project is sea-based and does not include land-based facilities. Abalone farming is included in the environmental authorisation that was issued for the Qolora Aquaculture Development Zone in the Amathole District in the Eastern Cape. Furthermore, DAFF would not conduct environmental processes for private businesses owning or controlling land. However, DAFF is currently conducting a high level strategic environmental assessment which covers marine and freshwater zones across the country.

3.5 Comments regarding impact assessment: • Comment on the marine specialist study was provided. The comment highlighted the importance of recognising the outcome of this study which concluded that there was a high risk of disease transfer from farmed to wild populations. • Concern regarding Algoa 1 was raised. It was questioned that any aquaculture in this area could have an economic impact as a knock on effect of visual impacts and perceived increased risk of shark encounters. It was emphasised that this area is the most valuable land per square metre in the Port Elizabeth area. Option C was seen as the preferable option by this stakeholder and most attendees expressed agreement with this opinion. • Concern was expressed that aquaculture may have a significant negative impact on the tourism industry. The BnB Association is concerned that a quantitative approach was not taken to assess socio-economic impacts (including job creation versus losses). It was emphasised that

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perception rules the tourism industry (an example of how the Ebola virus has impacted tourism in South Africa was given). o Anchor responded that every development seeks to maximise economic benefits and minimise consequences. Attendees were referred to the socio-economic impact assessment which provides an estimate of the potential impact based on the best available information. Qualitative personal perception will be the key factor that will determine to what extent the economic impact will be realised and it is believed that eliminating finfish farming from Algoa 1 will largely mitigate negative economic impacts. o DAFF added that the tourism industry also benefits from aquaculture. For example tourists like to eat seafood in areas such as Port Elizabeth and often interested in understanding where the food comes from. Aquaculture should not be seen as the opposite to tourism and they certainly interlink. DAFF did, however, acknowledge the fears of the tourism sector. o Anchor also emphasised that the revised description of the socio-economic character of Port Elizabeth added a wealth of new information on the water sport events that take place in the city. Maps demonstrate that the proposed aquaculture area does not overlap with any of the sport event routes and activities. The Jendamark Bell Buoy Challenge’s most outer extent of the route is situated approximately 500 m from the proposed boundary of the aquaculture site. It is not expected that the events will be cancelled with bivalve farming at Algoa 1. • The EAPs should consider adding another alternative option which considers bivalve farming at all three sites and should consider the rehabilitation of the Swartkops Estuary instead as an alternative. A restored estuary would provide nursery areas and benefit wild fish stocks for harvesting. o Anchor explained that although estimated job opportunities were much lower than what has been estimated for bivalve farming in Algoa Bay, this estimate is based on best available information which comes from international sources where fish cage farming is established e.g. Norway. In South Africa we tend to employ a lot more people and tend to not automate processes to the extent that this occurs in developed countries. It is therefore anticipated that the number of jobs is currently underestimated. The finfish farming sector is still in its infancy and we therefore within the South African context, a reliable estimate is difficult to derive. Furthermore, after shrimp, finfish is considered a high value product and has economic growth potential. o Anchor responded that rehabilitation of the estuary could not be added to the scope of this project, as the mandate for estuary rehabilitation is held by the Department of Environmental Affairs and not the Department of Agriculture, Forestry and Fisheries. DAFF also indicated that there is currently a re-habitation project underway for the Estuary of which DAFF is involved in. • Concern was raised that the negative economic impact was assessed on a local scale while the positive economic impact as assessed on regional scale. It was stated that both positive and negative impacts should be assessed at the same geographic scale. This inconsistency gives some interested and affected parties the impression that there is a bias in the assessment.

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o Anchor responded that we based our impact assessment on the assessment by Bloom 2013 assessment, who argued that the negative impact should be assessed at a local scale. With regards to the positive economic impact for bivalve farming, a regional scale is proposed as currently much of the economic activity related to bivalve farming is happening in Saldanha Bay, Western Cape. This may translate into a more localised economic impact over time as the infrastructure and business support expands to Port Elizabeth. Anchor asked for further input on the reasons why the local negative impact should be extended to regional scale. The stakeholder was encouraged to provide input on the economic assessment in writing and that Anchor would consider the input in the compilation of the Final BAR. Anchor assured that as EAPs we don’t have a vested interest in this development and are basing our assessment on the available information. • As discussed at the previous meeting and comments submitted during the pre-application process, wind should be taken into account in Port Elizabeth. Wind influences currents and upwelling. The person commenting maintained that waste from finfish farms could wash up on the beaches.

3.6 Comments regarding feasibility of the proposed project: • Finfish farming at Algoa 7: The results of the 2016 feasibility study were summarised and it was highlighted that feasibility of finfish farming in Algoa Bay was low to very low in Algoa Bay due to temperature changes (upwelling events) and wave exposure. Fish in cages cannot escape environmental conditions and expensive technology would be required to withstand significant wave heights that have been observed in Algoa Bay. The stakeholder offered to provide significant wave height data for Algoa 7 to ensure that potential investors are aware of the conditions at this site. o Anchor responded that the comment is correct and no secret has been made of the fact that this area experiences high wave energy. Operators are likely to investigate in detail whether the infrastructure would be able to withstand environmental conditions as losing stock due to damaged cages would severely impact the business itself. There are international engineering solutions and DAFF as well as operators would seek to match/adapt engineering solutions to the environmental conditions. • Bivalve farming at Algoa 6: the existing farm is frequently experiencing high pathogen levels in the water. Algoa 6 is currently not suitable for large-scale bivalve farming due to these challenges and this needs to be improved and improvement demonstrated by means of water quality measurements. o DAFF responded that the deterioration of water quality at Algoa 6 is related to a sewage pipeline and that this outfall is being legally investigated. DAFF emphasised that this should not be used as an example of general conditions at Algoa 6 but did not deny the need to improve water quality at this site in order to support the proposed scale of bivalve farming.

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o DAFF also added that good water quality is particularly important during the last stages of growing out bivalves and therefore Algoa 1 has been put forward as a grow out site, as this reduces the risk of poor water quality. Additional note: Bivalves purge pathogens harmful to humans within a certain period (oysters within two weeks, mussels within one month). Currently oysters are quarantined in holding tanks on land prior to sale on the market. Algoa 1 could allow farmers to grow out their bivalves in cleaner waters, reducing the bioaccumulation of heavy metals and negating the expensive quarantine period. It should be noted that Algoa 6 is more protected and therefore more suitable for early stage cultivation. o Additional note: The BAR considers feasibility in the impact assessment. The probability of the positive impact being realised is dependent on the probability of the business succeeding. Without mitigation measures (i.e. improving water quality) this probability is currently rated as ‘possible’, which means that without fixing the water quality issue at Algoa 6, the positive economic impact is rated as ‘medium’. After mitigation, the probability of this impact being realised is rated as ‘definite’, which results in a positive impact significance of ‘high’ for bivalve culture at Algoa 6 (probability of the impact being realised can be rated as ‘impossible’, ‘possible’, ‘probable’, and ‘definite’. Refer to the impact rating methodology for more information). • It was mentioned that the recent research in Algoa Bay has shown that fingerlings (young fish) are being impacted by the rising acidity of our oceans due to climate change. This should be considered for the feasibility of the project. o Anchor responded that although we are aware of the challenges faced by climate change this was an interesting point as Anchor was unaware that local research had been conducted.

3.7 Questions raised by attendees and answers: • Penguins are still being rehabilitated as a result of the recent offshore ship to ship bunkering accident leading to an oil spill near Ngqura Harbour. How will this affect finfish farms nearby? o Anchor responded that any impact on wild biota would have an even higher negative impact on finfish that cannot escape. This risk would need to be managed, but should not mean that aquaculture cannot occur in this area. o DAFF responded to say that aquaculture requires clean seawater. DAFF also responded that they cannot comment on another department’s mandate for managing the aftermath of the oil spill (i.e. Department of Environmental Affairs). o Offshore bunkering operations resulted in a 200-400 L fuel spill on 6 July 2019 near the Port of Ngqura (classified as a Tier 1 spill) and to date SANParks removed at least 80 penguins from Bird Island and St Croix Island and are currently being rehabilitated (Algoa Bay Hopespot Facebook Page). • Port Elizabeth experiences strong winds and high seas, waves have been seen breaking at Bell Buoy. Who will clean up structures washed up on the popular tourism beaches? o Anchor responded that farmers must have an emergency procedure in place, which includes requirements to clean up any debris that washes up on the beach immediately.

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Farmers will be aware of this risk as it is well known that Algoa Bay experiences rough sea conditions. This is also requirement in the Environmental Management Programme (ADZ and individual operator level EMPr). • Is there any chance that DEA may still authorise finfish farming at Algoa 1 (Summerstrand Site)? Page 15 of the BAR states that “should finfish farming be pursued at Algoa 1 Option 1”. o Anchor responded that DAFF submitted an application for Option B, which excludes finfish farming from Algoa 1. The Competent Authority is unlikely to issue an option that has a higher environmental impact than the option applied for. The wording in the BAR will be amended to remove ambiguity. • Animal husbandry is a major issue associated with finfish farming. Fish are cramped in cages, infested with parasites and diseases and often are injured due to the lack of space available. It is understood that rules of conduct will be established for farmers. How will these rules of conduct be policed? Successfully enforcing rules of conducts is an issue in South Africa. o Anchor responded that it is in the best interest of the farmer to minimise diseases and the impact on the receiving environment as the quality of their products rely on good environmental practice. o DAFF added that international standards put further pressure by ensuring that only good quality products will be accepted by countries purchasing farmed seafood from South Africa. Farms have to be audited regularly and international standards must be met for a successful business. • Why is Algoa 1 included in the ADZ at all? o Site selection has been based on several Strategic Assessments (national and Algoa Bay specific) conducted since 2009. Algoa Bay was identified as one of the few sites where sea-based aquaculture is possible along the very exposed shoreline of South Africa. The strategic assessment involved the application of various spatial exclusionary criteria relating to feasibility, including, but not limited to, exposure to wave energy, water depth, and distance from harbour. Furthermore, environmental impact aspects are also considered, including user conflict (shipping lanes) and known heritage resources. There are indeed very few oceanographically suitable sites due to the very exposed coastline of South Africa. This is likely why Algoa 1 remains of interest to DAFF for the development of aquaculture. • One stakeholder felt that they had been lied to and that the Nelson Mandela University gave a presentation in 2014 and claiming that finfish farming would only create seven jobs and finfish would be processed on Chinese ships and that there would be no benefit to South Africa or the local community. It was claimed the information that is presented is confusing as the number of jobs that could be created has changed dramatically since the last EIA process. What is the truth? o Anchor responded that they are not familiar with this presentation and where this information was obtained from. Anchor emphasised that a balanced and independent impact assessment process was followed. Anchor emphasised that emotions regarding this proposed development were running high and urged attendees to assess any information about this project as objectively as possible.

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• Considering that the products farmed in aquaculture facilities are aimed at the high income bracket and tourists, how will this project contribute to food security in South Africa? o Anchor agrees that food security would not constitute a direct benefit by this project. Following the pre-application process the ‘Need and Desirability’ Section was updated, however, not consistently, which mislead the stakeholders. This has been corrected in the Draft BAR. However, indirectly, jobs will provide income and therefore increase food security. • Why is DAFF not considering bivalve farming at all sites? DAFF is imposing a solution to unemployment and lack of economic growth in this area rather than taking advantage of the environmental conditions. o DAFF explained that the aim is to diversify the sector and develop aquaculture for as many species as possible. Sea-based finfish farms improve the economy of scale as the running costs are lower. Marine finfish culture is currently not at all developed in South Africa due to environmental and technological challenges. As technologies are rapidly developing, DAFF is taking a forward-looking approach in facilitating the development of the aquaculture sector in South Africa. Market resilience is higher with increasing variety of species. • Recent research has shown that bivalves in Algoa Bay have assimilated toxins higher than levels safe for consumption. Considering poor water quality in areas of the bay, how will water quality be monitored and has feasibility been considered in terms of toxins in bivalve flesh and safety for human consumption? The research showing these results was offered. o DAFF explained that there is a difference between toxins measured in wild versus farmed bivalves. Wild bivalves have more time to assimilate toxins when compared to farmed products. Further, international food standards apply to aquaculture products and levels cannot exceed safe consumption levels if the product is to be sold for human consumption. Tests are conducted regularly and rigorously and if required farms are shut down for a period until the levels of pathogens and toxins have fallen below the safety standard. This matter must be verified as such statements in a public forum without the evidence at hand can have serious consequences for the existing farm at Algoa 6. • The proximity of the largest remaining penguin colony in South Africa of this endangered species is very close to Algoa 7. Have increased predator activity and the impact on penguins been assessed? A risk assessment should be conducted to establish potential impacts. o The proximity of the endangered African Penguin was considered in the impact ratings. The proximity to an important conservation area (MPA) is the reason why some of the marine ecological impacts are considered ‘high’ and ‘medium’ after the implementation of mitigation measures for Algoa 7. • Environmental impacts are often more easily managed on land. Why is land-based aquaculture not included as an alternative? o DAFF intends to promote land-based and sea-based aquaculture, not one or the other, to provide potential investors with diverse opportunities within an enabling environment that allows for sustainable growth of the aquaculture sector. Land-based aquaculture is therefore not an alternative activity in this application. Land-based finfish

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culture is currently very expensive when compared to sea-based finfish farming. However, options are currently being pursued to also creating an enabling environment for land-based finfish farming in the future. o Additional note: Each aquaculture type has its own challenges as well as varying negative impacts and degrees to which mitigation measures are realistically implementable. For example, land-based facilities must be supplied with clean seawater and various systems are available (flow-through, partial re-circulation and full recirculation). Overall implementation of a land-based system is very expensive (both pumping costs causing high electricity demand, and infrastructure costs). In contrast, cage culture makes use of the assimilative capacity of the receiving environment and if managed carefully (e.g. site selection for appropriate waste dispersion, not exceeding carrying capacity (in kg fish) of the site) can have a lower impact on coastal water quality and ecosystems than a land- based facility that discharges finfish effluent close to the shore where dispersion and dilution may be poor. On the other hand, diseases are much more easily controlled and contained in land-based facilities, where treatments can be applied more effectively and effluent can be sterilised prior to discharge, thereby reducing the impact on native fish populations. The absolute prevention of impacts is impossible, and it is therefore important to consider the types of mitigation measures that are available and how effective they are. Environmental monitoring (baseline and impact monitoring) are also key in detecting unacceptable impacts and mitigating their effects. Please refer to the Environmental Management Programme (EMPr) in Appendix F for more information.

3.6 Other comments by stakeholders, DAFF and Anchor: • The terminology to describe conflict between humans and marine predators should be changed from ‘shark attack’ to ‘shark encounter’. The BAR should be amended to be in line with the efforts of conservation agencies to change the common misperception of sharks as malicious creatures. • The real name for Hobie Beach is ‘Shark Rock Beach’ and should be used. o Anchor response: Anchor will continue to use ‘Hobie Beach’ for the purpose of the Basic Assessment process as this is the name that everyone is familiar with and changing this name could confuse the public. • DAFF emphasised that the proposed project is an Aquaculture Development Zone (ADZ), not a fish farm. Should environmental authorisation be granted by the Competent Authority, investors wishing to establish a sea-based mariculture facility within the zone will not need to apply for environmental authorisation, provided that the conditions of the authorisation are met by the proposed farm. This reduces cost to the individual farmer. • DAFF emphasised that one of their mandate is job creation and sustainable economic development. DAFF is pursuing Aquaculture Development Zones across the country that are suitable along the coastline. • It was emphasised that the land described by Johann Dreyer (large piece of land) is in fact state land and should have been included in the environmental process. This project could be a

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blessing in disguise at it could replace the ADZ and eliminate all the issues associated with the proposed project. o Anchor clarified that the reason why the sea space adjacent to this stretch of coastline was excluded during the earlier SEA for finfish farming is due to the exposed nature of this area which lies outside of the bay. o However, thereafter it was clarified that Johann Dreyer had spoken about abalone ranching. DAFF responded that an abalone ranching right would not be included within an ADZ. It was explained that a separate process would be required for the application of an abalone ranching right. • A commercial diver from Eastern Cape expressed frustration over the fact that he cannot go and dive for ranched abalone. Aside from that he has also been struggling to find work. o DAFF explained that ranched abalone belongs to the entity that seeded the abalone. Unfortunately, this abalone is not available to other people. There have been several complaints to DAFF regarding this issue. • Concern was expressed that we are exploiting the ocean unsustainably. All attendees were made aware of the protest swim and walk that had taken place on 13 July 2019 against finfish farming at Algoa 1. The memorandum that had been prepared could not be handed over to DAFF or the EAP at the time and was handed over at the end of the meeting.

4. Closure: Kenneth Hutchings informed all attendees that the presentation and minutes of this meeting would be made available to all attendees as soon as possible. He thanked everyone for attending the meeting and for the input provided. He also reminded all attendees that written comment could be provided by the 28 July 2019. KH closed the meeting at 21:00.

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APPROVAL OF THE MINUTES BY THE CHAIRPERSON

Dr Kenneth Hutchings

SIGNATURE DATE 17 September 2019

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ALGOA SEA BASED AQUACULTURE DEVELOPMENT ZONE BASIC ASSESSMENT PROCESS

Date: Thursday, 1 August 2019. Time: 18:00 – 20:30 Venue: Motherwell NU2 Community Hall, Chief Poto Street, Motherwell, 6211

FINAL MINUTES: PUBLIC MEETING

1. Welcome & Introductions: Dr Kenneth Hutchings (KH) introduced himself, Anchor Research & Monitoring and the Department of Agriculture, Forestry and Fisheries (DAFF), and welcomed all attendees to the public meeting. He explained that Anchor was appointed by the Department of Agriculture Forestry and Fisheries (DAFF) as the Environmental Practitioner (EAP) to assist DAFF with the application for Environmental Authorisation (EA) for the proposed sea-based Aquaculture Development Zone (ADZ) in Algoa Bay.

2. Matters to be Discussed (Presentation attached to the minutes) 2.1 Objectives of the meeting: KH explained that the purpose of this meeting was to present the outcomes of the pre-application public participation process and how comments provided by stakeholders were considered in the Draft BAR. He also explained that as the environmental consultants, Anchor also represents the aquaculture and marine specialist for this project. He elaborated that Vera Massie (VM) would address matters related to the Basic Assessment process, and components of the impact assessment other than the marine impacts (i.e. visual, socio-economic and heritage resources impact assessments).

2.2 Basic Assessment Process: KH provided an overview of the project timeline. He explained that the non-statutory pre-application phase had been concluded and that comments submitted during the commenting period had been considered in completing the Draft Basic Assessment Report (BAR). He informed all stakeholders that DAFF had submitted the application for Environmental Authorisation on 22 July 2019 and that I&AP could submit their comments until 28 August 2019.

He further elaborated that DAFF had 90 days to complete the Final BAR, which will be submitted for decision-making by 21 October 2019. The Competent Authority (National Department of Environmental Affairs) has 107 days to make the decision (Additional Note: that the period from 15 December until 5 January is excluded from any time frames pertaining to environmental authorisations). A decision is therefore to be issued by the 27 February 2020. Stakeholders were also made aware of the appeal process.

Algoa Bay Sea-Based Aquaculture Development Zone – Public Meeting 1 August 2019 Final Minutes

KH and VM commenced with the presentation, which has been attached to minutes. KH and VM covered the following content: • Very brief project background (i.e. history) (KH) • ADZ definition (KH) • Project overview (KH) • Alternative options (including No-go Option) (see table below) (KH) • Public participation process and outcomes (VM) • Changes to the BAR (KH and VM) • Summary of Alternative Option preferred by DAFF (VM) • Recommendations by the EAP • BA process timeline and appeal procedure

VM emphasised that it is important to note that, based on the revised significance of negative economic impacts linked to finfish farming at Algoa 1 Option 1 from ‘medium’ to ‘high’ after implementation of mitigation measures, DAFF has revised its priorities in respect of mariculture in Algoa Bay and has nominated Option B as the preferred Alternative Option. Alternative Option B involves: Mussel and oyster farming at Algoa 1 Option 1 (Summerstrand site) Mussel and oyster farming at Algoa 6 (PE Harbour site); and Finfish farming at Algoa 7 (Ngqura Harbour site)

Option Algoa 1 Algoa 6 Algoa 7 (Summerstrand) (PE harbour) (Coega) A Finfish & Bivalve Bivalve Finfish B (DAFF preferred) Bivalve Bivalve Finfish C X Bivalve Finfish D X X X

Questions on the process and details of the presentation and study approach were not taken during the presentation. VM informed all attendees where copies of the Draft BAR can be accessed.

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3. Questions and answers session: The minutes below summarise the comments made by individual stakeholders and responses provided by Anchor or DAFF on the topic, if applicable. Any questions or comments that Anchor did not address in the meeting (or additional information that is relevant to the comment) have been answered in these minutes and are recorded in italics.

Xolani Teyise – Department of Agriculture Forestry and Fisheries What kind of fish are proposed for this project? KH responded that this was an application for the farming of indigenous finfish species and a list of potential indigenous species can be found in the report. Trials have been successfully completed in Algoa Bay for yellow tail and dusky kob.

Gary Koekemoer – Wildlife and Environment Society of South Africa (WESSA) 1. Expressed concern regarding potential increased risk of fatal shark encounters at St Georges Strand as a result of finfish farming at Algoa 7. A fatal shark encounter occurred at St Georges Strand in the 1970s. He claimed that research is showing clear evidence that finfish cages attract sharks and gave the example of Reunion Island. He expressed concern that finfish cages would constitute a new food source and would lure sharks closer to St Georges beach. He questioned Anchor whether a shark expert has provided input on the real risk of fatal shark encounters as a result of a finfish farm 4 km from a popular bathing site.

KH response: Anchor consulted Dr Alison Kock during the initial 2013 EIA, who is a prominent Great White Shark expert in the country. Fatal shark encounters are rare and stochastic events and hence very difficult to predict and Dr Alison Kock was unable to provide definitive answers. Following a series of fatal shark encounters in False Bay the public claimed that the culprit of these fatal incidents was the shark cage diving industry, as operators lure sharks to the cages with food. Research projects were initiated to investigate residence times of sharks around shark cage diving boats (residence time indicating habituation) when food was used to lure the sharks closer to the cages but were not rewarded with food. It was concluded that without a predictable reward, sharks showed no signs of habituation. Anchor would welcome input from Dr Malcolm Smale (Bayworld) a local expert regarding how he thinks finfish farming at Algoa 7 would influence the risk of a fatal shark encounter at St Georges Beach (as recommended by GK).

2. The conditions of the appeal (previous EIA process 2010-2014), specifically the socio-economic study that would compare jobs lost versus jobs gained and revenue lost versus revenue gained have not been met, yet a new process was initiated. He questioned the validity of the current application process.

DAFF responded that the studies had been completed as per the request of the Minister for the sites under consideration during the first application process.

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3.He proposed that bivalve farming appears to be a much better option as the assessment shows that more jobs can be created when compared to finfish farming. However, he also claimed that the number of jobs presented in the assessment was incorrect.

KH response: The number of jobs were extrapolated from the existing farm Zwembesi Farms (Pty) Ltd who provided the total numbers of jobs that will be created once their farm reaches full-scale production. He referred stakeholders to the basic impact assessment report where this was explained in more detail.

DAFF added that it is important to consider who currently benefits from the events and tourism in the Port Elizabeth area and if jobs were gained in the aquaculture industry who would benefit. It is not simply a matter of comparing the number of jobs that could be gained or lost.

3. Previous aquaculture farms have failed in the past and it is important to understand what the real potential of this proposed project is. He commented that if DAFF had completed the study that quantified the number of jobs that could be lost as a result of the proposed development, it would have been possible to identify in which demographic group jobs may be lost.

4. WESSA is concerned that a notice of suspension/cessation/withdrawal of the original ADZ application initiated in 2011 was not issued by DEA and distributed among stakeholders. It is WESSA’s understanding that as per NEMA’s EIA Regulations 2014, a similar application cannot be submitted twice unless the appeal was concluded. WESSA is of the opinion that the appeal period was not concluded and is questioning the validity of this application process.

KH responded that the previous EIA was conducted by CapeEPrac and that Anchor was the subcontracted marine specialist on the project and that DAFF or CapeEPrac should respond to this concern.

DAFF informed the attendees that the application was not retracted by DAFF but instead, the authorisation was not upheld, and a new application had been requested by the Competent Authority.

Tuletu Nombona – Metro Youth Chamber Expressed concerned about the lack of participation of the community especially when considering the proximity of the finfish farm to Motherwell community. It was suggested that perhaps communication methods could be improved by providing a questionnaire or allowing people to leave their comments at the library. It was suggested that the Ward Councillors could be contacted and provided with summary information as many young people obtain information at the Councillor’s offices. She was also interested to know if there was a register at the library where the document and CDs are displayed, as this was one way to find out who is interested in the project. She also elaborated that she is concerned that the community must make their voices heard to support the approval of this project.

KH responded that it could be queried with the librarian if a register of people who are interested in the project could be kept.

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Siya Ntsumpa – WESSA He agreed with the need for information to be accessible, especially for the local communities. He also commented that 1 300 pages were too much information. He supported herbivorous finfish farming and was concerned about the fact that carnivorous finfish consume smaller fish which leads to pollution. He also expressed concern regarding pathogen control at finfish farms. He commented that the impacts had not been discussed in the presentation and only the benefits had been mentioned. He also clarified that WESSA was not against creating employment.

KH responded that it is understandable that 1 300 pages is a lot of information to go through by stakeholders. He explained that on the one hand comprehensive information must be submitted to the Competent Authority for informed decision-making and on the other hand this information must be made accessible to the public. The very details that were mentioned in the comment must be included in the reports. He explained that the Background Information Document serves as a concise summary of the proposed project and EIA process. VM added that Chapter 1 and 2 of the BAR provide the most important information on the project and constitutes a much smaller volume of information that should be more accessible to stakeholders than the full report plus all the appendices. Stakeholders interested in more detail can consult relevant specialist reports or sections of the BAR for more information.

Mxoleli Nkuhlu – No affiliation provided The focus should not only be on job creation, but rather on how this development can contribute to economic opportunities that result in jobs. He queried who the role players would be if the proposed project was implemented. He expressed concern that the demographics should be considered more carefully when evaluating the socio-economic impact of the project.

KH responded that as this is an EIA process for declaration of an ADZ (i.e. zonation of sea space) rather than a specific aquaculture development, it is currently not known who the operators would be if the project was approved.

Siya Somntu – Insight Media He criticized that the only perspective taken in this process is to create jobs, rather than focusing on how to enable previously disadvantaged people to create jobs for themselves. The Environmental Impact Assessment process tends to look at previously disadvantaged people as a work force, rather than entrepreneurs. The Basic Assessment Report shows that the concerns of the comments submitted were considered carefully and the applicant changed their application to reduce the impact identified. He concluded that he is in support of the proposed development and that he hopes that if the ADZ is approved, previously disadvantaged people will be given preferential opportunity to invest in the ADZ.

VM encouraged Siya Somntu to submit recommendations on the benefit enhancing measures for the socio-economic impact assessment. The stakeholder was encouraged to specifically submit recommendations from an entrepreneurial perspective.

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Siyabonga Makinana – Metro Youth Chamber He expressed disappointment that the negative impacts are always emphasised, and the positive impacts are not discussed enough. He also expressed disappointment that the EAP was not communicating with the local communities outside of Port Elizabeth metro, which was demonstrated by the poor attendance at this meeting. He agreed with Tuletu Nombona that councillors should be contacted and that Metro Youth Chamber to consolidate comments from community members and to submit those as part of the process.

KH recognised that there is always room for improvement in conducting a public participation process and that Anchor would take these suggestions on board going forward. He also encouraged the Metro Youth Chamber to mobilise people and to assist in obtaining comments from the broader community.

Xola Ngcawgca – Black Fishers Association His organisation is registered under the Marine Living Resources Act and he attended the meeting to represent the organisation. He explained that his organisation is in support of the project. He expressed concern that the aquaculture sector is still very untransformed, and that this must be changed. Small- scale fishermen in his organisation are still waiting for their permit and would like to get involved if the ADZ was approved. He would like to see small-scale fisheries participating fully in the economy. He spoke about the rights of small-scale fishermen and how small-scale fishermen have been struggling. He also explained that aquaculture is a skill and that people who would like to participate must go back to school and learn about aquaculture.

Sabelo Nkuhlu – MXN – Resident of Nelson Mandela Bay 1. He expressed concern that the impact on the economy were assessed based on public perception regarding the increased risk of fatal shark encounters rather than on empirical evidence. He pointed out that the option involving the farming of finfish at the Summerstrand site was dropped based on the revised impact assessment, which was based on perception. He reiterated that empirical evidence is critical in facilitating the government in making a sound decision. He agreed with WESSA and suggested that the real risk of a fatal shark encounter should be investigated.

Anchor response: Unfortunately, obtaining empirical evidence on the probability of shark encounters is practically impossible, they are extremely rare and apparently random events that defy statistical probability modelling. Furthermore, perception often drives human decision-making more than empirical evidence. In many cases factual evidence is not accepted by the public when perception of the opposite scenario has already been entrenched. In taking a precautionary approach and in the absence of irrefutable (& impossible to obtain) scientific evidence, the EAP had to take into account public perception of the risk of shark encounters in rating the potential negative economic impact on Port Elizabeth.

2. He also pointed out that what constitutes a negative visual impact for some does not necessarily constitute a visual impact for others. It depends who the beneficiary of the project is.

Anchor response: This comment will be considered in the revised BAR.

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3. Aquaculture can contribute to sustainable development and can contribute towards a healthy lifestyle of people.

4. The knock-on effects of boosting aquaculture in South Africa are potentially larger than what is predicted, especially when considering the scale of aquaculture product processing that will be required. Aquaculture is currently a significant contributor to employment and is a key component of the 2030 National Development Plan. The President also mentioned aquaculture in his State of the Nation Address in 2019.

5. He recognised that this project cannot go ahead unless the Minister of Environmental Affairs grants Environmental Authorisation.

6. He supported the approach taken by DAFF to declare a zone for aquaculture. Zonation is important for economic development and is in line with international practice. He explained that this approach allows the economy to diversify and that it can facilitate broader economic development by providing service delivery in economic hubs. Such economic development can make a significant difference in people’s lives.

4. Closure: Kenneth Hutchings informed all attendees that the presentation and minutes of this meeting would be made available to all attendees as soon as possible. He thanked everyone for attending the meeting and for the input provided. He also reminded all attendees that written comment could be provided by the 28 August 2019. KH closed the meeting at 20:45.

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APPROVAL OF THE MINUTES BY THE CHAIRPERSON

Dr Kenneth Hutchings

SIGNATURE DATE 03 October 2019

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Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

59 research & monitoring Final BAR for DAFF Sea-Based ADZ in Algoa Bay Appendix F: Stakeholder Consultation

APPENDIX F7: ATTENDANCE REGISTERS AND PRESENTATIONS

A- Public meeting held in Port Elizabeth on 6 March 2019.

B- Public meeting held in Motherwell on 1 August 2019.

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Pre-application consultation

Authorities Meeting

6 March 2019

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Public Meeting

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Agenda No. Agenda Item Responsibility 1. Welcome & Introductions Anchor 2. Present & Apologies Anchor 3. Presentation a) Project background Basic Assessment Process b) Basic Assessment process and stakeholder consultation c) Project description Algoa Bay Sea‐Based d) Identification of potential ADZ sites e) Precincts under consideration and alternatives Aquaculture Development Zone f) Impacts associated with the proposed development g) Time line of the project and stakeholder involvement 4. Question and Answer session All attendees 5. Closure Anchor Kenneth Hutchings, Vera Massie & Songezo Mtsokoba Presentation for the pre‐application process public meeting 6 March 2019

Algoa Bay Sea‐based ADZ Basic Assessment Process 1 Algoa Bay Sea‐based ADZ Basic Assessment Process 2

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Objectives of this meeting BA Process Timeline Pre‐application Phase (Not statutory) • Anchor was appointed as the Environmental Assessment • Pre‐application meeting with Competent Authority Inception • Pre‐application BAR Practitioner (EAP) to assist the DAFF with the application for Phase Environmental Authorisation • Engage with I&APs early in the process – meetings, commenting period 30 days • Process: Basic Assessment Process • Competent Authority: National DEA Application Phase (Statutory) • Draft BAR and submit application • Objectives of this meeting: • Engage with I&APs – meetings, commenting period 30 days 1. To inform the public about the Basic Assessment • Final BAR submitted to Competent Authority (90 days process and public participation from submission of application) 2. To introduce the proposed project to the public 3. To present and discuss the pre‐application Basic Assessment Report Decision‐making period = 107 days

Algoa Bay Sea‐based ADZ Basic Assessment Process 3 Algoa Bay Sea‐based ADZ Basic Assessment Process 4

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Algoa Bay sea‐based ADZ Basic Assessment Process 1 11/10/2019

BA Process Timeline continued… Participation Process: What does it entail? NEMA EIA Regulations Chapter Appeal process (NEMA National Appeal Regulations) 6 prescribe minimum requirements: Applicant: • Written consent of • Inform I&APs of the decision within 14 days landowner • Can appeal within 20 days of receiving the decision • Notice board • Written notice (registered I&APs: letters) • Can appeal within 20 days of receiving the notification • Transnet of the decision • Adjacent land owners/occupiers/person Take note of the appeal procedure as per regulations in control • Municipal councillor/s • Municipality • Relevant Organs of State

Algoa Bay Sea‐based ADZ Basic Assessment Process 5 Algoa Bay Sea‐based ADZ Basic Assessment Process 6

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Participation Process: What does it entail? Participation Process: What does it entail? NEMA EIA Regulations Chapter 6 prescribe minimum requirements: Additional efforts: • Additional 30 days to provide • Advertisement ‐ 5 December comment 2018 in the PE Express • 16 Radio announcements in • Compile and maintain isiXhosa on Nkqubela FM during stakeholder database drive time for both processes (1‐6 • Make documents available March 2019, ~June 2019) • 30 day statutory commenting • Two public meetings (6 March 2019 period and application phase) (email communication) • Additional posters at shops, pharmacies and libraries

X2

Algoa Bay Sea‐based ADZ Basic Assessment Process 7 Algoa Bay Sea‐based ADZ Basic Assessment Process 8

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Algoa Bay sea‐based ADZ Basic Assessment Process 2 11/10/2019

Public Participation Process: Project Background Improvements for the next round Environmental National SEA Additional efforts: S&EIR Authorisation for finfish • Initiate radio announcements further in advance. 9 July 2014 for 2009 2010‐2014 • Challenge: Algoa 1 • Meeting should be accessible to all communities in the Minister suspended area authorisation to 28 Substantive 2016 studies • Should be after working hours but allow for additional Appeals also allow for safe commute home studies

Socio‐ Marine Economic economic feasibility

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Project Background Project Description

• 2018/2019: DAFF has identified two new sites to be included • ADZs provide ‘investment ready’ platforms in the EIA process and intends to submit a new application • Operation Phakisa project – Ocean’s Economy for Environmental Authorisation in terms of the 2017 NEMA • Aquaculture definition: EIA Regulations. The propagation, improvement, trade or rearing of aquatic organisms (plant and animal) in controlled or selected aquatic environments (fresh, sea or brackish waters, on land or at sea) • Marine aquaculture or mariculture definition: Farming of marine organisms such as finfish, shellfish (e.g.. abalone, mussels), crustaceans (e.g. prawns) and seaweed

EXCLUDES RANCHING

HUMAN INTERVENTION

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Algoa Bay sea‐based ADZ Basic Assessment Process 3 11/10/2019

Project Description Project Description • DAFF intends to declare an ADZ for farming finfish and bivalves (e.g. mussels and oysters) • Finfish are farmed in cages

(Source: Shutterstock)

Algoa Bay Sea‐based ADZ Basic Assessment Process 13 Algoa Bay Sea‐based ADZ Basic Assessment Process 14

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Potential finfish species to be considered Potential finfish species to be considered Indigenous species only: • Environmental conditions mostly suitable. • Yellowtail • Suitability for cage farming must be established through • Dusky kob research. • Silver kob • Carrying capacity modelling for finfish culture completed by • Yellowfin tuna Anchor for indigenous Yellowtail and Meagre (similar to kob). • No alien finfish species in this BA process. • Sole • Should alien species be farmed at a later stage, operators • Geelbek must ensure compliance with National NEMBA Alien Invasive • Spotted grunter Species Regulations. • White steenbras • White stumpnose • Red roman

Algoa Bay Sea‐based ADZ Basic Assessment Process 15 Algoa Bay Sea‐based ADZ Basic Assessment Process 16

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Algoa Bay sea‐based ADZ Basic Assessment Process 4 11/10/2019

Project Description Project Description • Oysters are farmed on long‐lines • Mussels are farmed on long‐lines or rafts

(Source: https://www.ptreyeslight.com/article/marin‐ oyster‐companys‐revised‐permit‐harbinger‐future. Photo credit: David Briggs)

Algoa Bay Sea‐based ADZ Basic Assessment Process 17 Algoa Bay Sea‐based ADZ Basic Assessment Process 18

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Potential bivalve species to be considered Identification of potential ADZ sites • Indigenous shellfish species – Cape Rock Oyster – Black mussel – Brown mussel • Alien shellfish species – Pacific oyster – Mediterranean /green mussel

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Algoa Bay sea‐based ADZ Basic Assessment Process 5 11/10/2019

Identification of potential ADZ sites cont… Identification of potential ADZ sites cont…

• Algoa 2,3,4 and 6: Eliminated during the 2013 EIA. Findings of comparative study 2016 Reasons: Algoa 1: • 2 and 3 – Environmentally favourable but within area • Low economic feasibility of very high risk for shipping traffic • Socio‐economic impacts are significant (tourism and • 4 – Environmentally not favourable (too exposed) recreation indicator ranked as ‘very low feasibility’) • Otherwise moderately feasible for other socio‐economic • 6 – Insufficient depth for waste dispersion for finfish indicators • Algoa 1 and 5: Assessed as part of the S&EIR process • Ecologically feasible with appropriate mitigation measures 2013/14, EA granted for preferred alternative Algoa 5: • Alternative 1 (preferred): Algoa 1 • Very low economic feasibility • Alternative 2: Algoa 5 (not authorised) • Socio‐economic feasibility ‘moderately feasible’ for most indicators • Ecologically feasible with appropriate mitigation measures

Algoa Bay Sea‐based ADZ Basic Assessment Process 21 Algoa Bay Sea‐based ADZ Basic Assessment Process 22

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Precincts under consideration Alternative Options

• Combinations of precincts as alternative options are being considered – varying scale of development.

Option Algoa 1 Algoa 6 Algoa 7 (Summerstrand) (PE harbour) (Coega) AFinfish & Bivalve Bivalve Finfish B Bivalve Bivalve Finfish C X Bivalve Finfish DX X X

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Algoa Bay sea‐based ADZ Basic Assessment Process 6 11/10/2019

2019 Impact Assessment Impact Assessment Method Studies incorporated In two steps: • Marine specialist study 2019 (Algoa 1, 6 & 7) 1. Each precinct is assessed individually • Dispersion modelling and habitat mapping 2019 (Algoa 1, 6 & 7) a. Each impact type • Maritime and Underwater Cultural Heritage Impact Assessment 2019 (Algoa 1, 6 & 7) (ACO Associates) b. Where applicable finfish and bivalve impacts are • Comparative Assessments (Rhodes University 2016) (Algoa 1) assessed separately – Socio‐economic Report 2. Alternative options assessment: – Ecological Report Sum impacts (+ve and –ve separately) for each alternative – Feasibility study option A, B, C, D • Marine specialist study 2013 (Algoa 1) • Visual specialist study 2013 (Algoa 1) • Socio‐economic specialist study 2013 (Algoa 1)

Algoa Bay Sea‐based ADZ Basic Assessment Process 25 Algoa Bay Sea‐based ADZ Basic Assessment Process 26

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Impact Assessment: Marine (negative) Visual aesthetic impacts • Disturbance of subtidal habitat • Introduction of alien organisms into the wild Negative impact on seascape character during • Disease and parasite transmission to wild stocks • Organic waste discharge impacting on water quality and benthic environment • Genetic contamination of wild stocks Example: • Pollution from chemical therapeutants and antifoulants Identification of visual receptors • Accidental entanglement of cetaceans and alterations in habitat use for Algoa 1 • Piscivorous marine animal interactions • Impacts on Addo MPA • Effects on fish populations and habitat use

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Algoa Bay sea‐based ADZ Basic Assessment Process 7 11/10/2019

Socio‐economic impacts Socio‐economic impacts

• Investment in the local, regional and national economy (+ve) Impacts assessed continued: • Increased employment, income and skills development for • Impacts on existing mariculture activities (+ve) Algoa Bay (+ve) • Impact on local fisheries (‐ve) • Economic impact on specialist tourism and recreational Pressure on existing land‐based infrastructure (‐ve) businesses (i.e. loss of jobs and income) (‐ve) • • Impact on coastal real estate due to aesthetic nature of • Impacts on water sport recreational activities (‐ve) views and sense of place (‐ve) • Impacts on SCUBA diving activities (‐ve) • Impact on local community development (+ve) • Risk of collision between vessels and aquaculture farms (‐ve) • Impact of income leakage on local economic • Impact on vessel navigation routes (‐ve) development of the area (‐ve) • Impact on small businesses, individual and informal sector development (+ve)

Algoa Bay Sea‐based ADZ Basic Assessment Process 29 Algoa Bay Sea‐based ADZ Basic Assessment Process 30

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Maritime and Underwater Cultural Heritage Summary of significance ratings – Positive Number of positive significance ratings for each impact • Submerged prehistory category after implementation of benefit enhancing • Maritime archaeology ‐ shipwrecks measures for alternative options A, B and C

14 18 ratings 18 ratings 13 ratings 12 10 8 Low 6 Medium 4 High 2 0 ABC

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Algoa Bay sea‐based ADZ Basic Assessment Process 8 11/10/2019

Summary of significance ratings: Summary of significance ratings –Negative Negative impacts after mitigation Number of negative significance ratings for each impact category after implementation of mitigation measures for alternative options A, B and C • No ‘very high’ ratings • ‘High’ rating ‐ marine ecological impact (disease and parasite 18 44 ratings 42 ratings 30 ratings transmission to wild stocks) 16 14 • ‘Medium’ ratings: socio‐economic and marine ecological 12 Insignificant impacts. 10 Very low • ‘Insignificant’ ratings: Maritime & Underwater Heritage 8 Low 6 Medium 4 High 2 0 ABC

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No‐Go option (Alternative Option D) Conclusions DAFF intends to apply for Option A: Algoa 1: Finfish & Bivalve • Environmental status quo is maintained: Algoa 6: Bivalve • No additional job opportunities and skills development in the aquaculture sector Algoa 7: Finfish • No negative impacts on visual aesthetics, maritime Phased approach heritage resources, or the socio‐economic and marine ecological environment

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Phased approach and EMPr Conclusions • Phased approach ‐ only expand to commercial scale if pre‐determined environmental quality standards are met (biophysically and socio‐ Based on current impact assessment: economically) Option C –Bivalve at Algoa 6 and Finfish at Algoa 7 has • Implementation of Environmental Management Programme (EMPr) smallest environmental footprint. critical +ve socio‐economic: partly realised • Overseen/coordinated by ADZ Management Committee (AMC) • DAFF ‐ve socio‐economic: minimised • DEA: Oceans and Coasts ‐ve visual: minimised • DEDEAT ‐ve marine ecological: reduced • Municipality ‐ve heritage resources: reduced • Transnet National Port Authority • Consultative Forum (CF) to review environmental monitoring data and EAP likely to recommend Option B or C ‐ Lower negative advise on management measures impacts, while positive impacts are still realised.

DEA to make decision

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Timeline of the project and stakeholder involvement Timeline of the project • NOW: First commenting round opens within the next two weeks and stakeholder • Pre‐applica. on BAR will be revised → Draft BAR • Submit application and Draft BAR to competent authority involvement ~ end of May 2019 • Application‐phase public participation: ~ June 2019 • BAR will be revised → Final BAR • Final BAR submitted to Competent Authority: ~ end August 2019 • Decision‐making = 107 days ~ end January 2020 • Appeal phase ~ February 2020

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Report availability and contact details Reports will be made available within the next two weeks and can be obtained here: Anchor website: https://anchorenvironmental.co.za/node/344

Telephonic requests: Office Phone: 021 701 3420 Direct Cell: 081 576 3870

Email requests: [email protected] Thank you

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Application consultation

Public Meeting

31 July 2019

Application consultation

Public Meeting

1 August 2019

11/10/2019

Agenda No. Agenda Item Responsibility 1. Welcome & Introductions Anchor 2. Present & Apologies Anchor 3. Presentation Anchor Basic Assessment Process a) Brief background Algoa Bay Sea‐Based b) Timeline of the project and stakeholder involvement Aquaculture Development Zone c) Summary of pre‐application phase stakeholder consultation process d) Pre‐applica. on BAR → Dra BAR: What changed? e) DAFF: Preferred Alternative Kenneth Hutchings and Vera Massie f) EAP recommendations Presentation for the application‐phase 4. Question and Answer session All attendees public participation process public meeting 5. Closure Anchor 31 July and 1 August 2019

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Objectives of this meeting BA Process Timeline Pre‐application Phase (Not statutory) • Anchor was appointed as the Environmental Assessment • Pre‐application meeting with Competent Authority Inception • Pre‐application BAR Practitioner (EAP) to assist the DAFF with the application for Phase Environmental Authorisation for an Aquaculture • Engage with I&APs early in the process – meetings, commenting period 30 days Development Zone in Algoa Bay. • Process: Basic Assessment Process • Competent Authority: National DEA Application Phase (Statutory) • Draft BAR and submit application –22 July 2019 • Engage with I&APs –commenting period 30 days Objectives of this meeting: To present the outcomes of the • Commenting period: 23 July –28 August 2019 • Submit Final BAR to Competent Authority within 90 pre‐application public participation process and how days from submission of application = 21 October 2019 comments provided by stakeholders were considered in the Draft BAR. Decision‐making period = 107 days The decision will be issued by 27 February 2019

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BA Process Timeline continued… Application

Appeal process (NEMA National Appeal Regulations) • 2018‐2020: DAFF submitted a new application for Environmental Authorisation in terms of the 2017 NEMA EIA Applicant: Regulations on 22 July 2019 for declaration of an • Inform I&APs of the decision within 14 days Aquaculture Development Zone (ADZ) in Algoa Bay. • Can appeal within 20 days of receiving the decision

I&APs: • Can appeal within 20 days of receiving the notification of the decision

Take note of the appeal procedure as per regulations

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Proposed Aquaculture Development Zone ADZ Definition

• Aquaculture Development Zone: an area declared for dedicated aquaculture use (in terms of section 21 of the Aquaculture Development Bill). • Application for Zonation. • ADZ declaration may specify types of aquaculture. • Details of potential, future operators within the ADZ not known at this stage. • Impact assessment is therefore “high level” and based on expected operations.

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Brief Project Overview Brief Project Overview Marine aquaculture or mariculture: Farming of marine • Mussels and oysters: on long‐lines organisms such as finfish, shellfish (e.g. oysters, mussels), crustaceans (e.g. prawns) and seaweed

https://www.princeedwardisland.ca/en/information/agriculture‐ and‐fisheries/mussels

Mussel long-lines: Marine Biological Research Centre

• Mussels naturally settle on ropes • Oysters are grown in baskets (various technologies available)

Oyster baskets on long-lines

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Brief Project Overview Alternative Options • Finfish: in cages • Combinations of precincts as alternative options were considered in the impact assessment – varying scale of development. Option Algoa 1 Algoa 6 Algoa 7

(Source: Shutterstock) (Summerstrand) (PE harbour) (Coega) AFinfish & Bivalve Bivalve Finfish B (DAFF Bivalve Bivalve Finfish preferred) CX Bivalve Finfish DX X X

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Proposed Aquaculture Development Zone Who provided comment? • 708 registered stakeholders (current status) • Private citizens • Government • Hospitality industry (accommodation, restaurants) • Tourism sector • Commercial and small‐scale fisheries • Aquaculture sector • Environmental consultancies • Conservation and research sector • Water sport industry (including diving industry) • Rate payer and home owner associations • 180 comments during pre‐application process

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Concerns raised by stakeholders Concerns raised by stakeholders Category No. of Reference to culture stakeholders type and precinct

Negative economic impacts 81 Finfish culture at Algoa 1 Shark risk to recreational users 72 Finfish culture at Algoa 1 Impacts on marine ecology 62 Finfish culture Water quality for recreation 54 Finfish culture at Algoa 1 Negative impact on recreation 45 Finfish culture at Algoa 1 Visual and aesthetics 28 Finfish culture at Algoa 1 Site selection 26 Finfish culture at Algoa 1 Economic feasibility of ADZ 25 Finfish culture Finfish culture Algoa 1 and Not enough information provided 18 7 Positive economic impact and new 5Entire ADZ job opportunities Qualitative interpretation of 179 comments submitted during the pre‐application phase for the Basic Assessment process for the proposed sea‐based Aquaculture Development Zone in Algoa Bay. Note the above data was obtained by interpreting the comments provided (i.e. this information was not the obtained from a survey) and does not necessarily represent the sentiment of all people in Port Elizabeth or beyond.

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Concerns raised by stakeholders Changes to the Basic Assessment Report No. of Reference to culture type • Algoa 1 has been reduced to Option 1 Category stakeholders and precinct Implementation queries 12 Entire ADZ Land‐based ADZ as an alternative 12 Entire ADZ Impact on beaches 11 Finfish culture at Algoa 1 Marine Spatial Planning not done 9 Entire ADZ Need and desirability 9 Entire ADZ Impacts on fishing industry 9 Entire ADZ Shortcomings of the stakeholder 8 consultation process Entire ADZ Impact on real estate 5 Finfish culture at Algoa 1 Vessel navigation 4 Algoa 1 Both culture types at Algoa Impact on air quality 3 1&6 Impact on aircraft navigation 3 Entire ADZ Violation of environmental rights 2 Entire ADZ Potential impact on Waterfront 2 Finfish culture at Algoa 1 Corruption 1 Entire ADZ

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Changes to the Basic Assessment Report Changes to the Basic Assessment Report • The Addo MPA was promulgated on 23 May 2019. Algoa 7 was excised from the • No reef was detected during the 2010‐14 EIA process MPA. • Bathymetry of the entire extent of Algoa 1 was mapped using a single‐ beam echosounder and benthic samples confirmed sandy bottom in accordance with the SANBI Benthic Habitat Map

Bathymetry map for the original extent of Algoa 1 (2013)

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Changes to the Basic Assessment Report Changes to the Basic Assessment Report • The impact on dive operators was revised from ‘very low’ to ‘low’ after • Pro Dive identified a low profile reef near the centre of Algoa 1 at an mitigation for finfish culture at this site. The impact of bivalve culture at this site approximate depth of 25‐29 m remains ‘very low’. • 200 m radius marine ecological buffer was applied around the reef. • Access to the dive site should be maintained

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Changes to the Basic Assessment Report Changes to the Basic Assessment Report • Major changes were made to the description of affected user groups • Negative economic impact of finfish culture at Algoa 1: • Caused by potential marine ecological and visual impacts, and the perception of increased risk of shark attack on water sport participants. • Pre‐application BAR assessed negative economic impact as Nelson Mandela Bay Tourism medium significance. • Comments provided by stakeholders indicated that the Michelle Barnett Dr JF McLellan perceived higher risk of shark attacks alone could potentially have a profound impact on the local economy during the pilot phase, and may be irreversible. • Negative economic impacts linked to finfish culture at Algoa 1 was therefore raised to high.

Pro Dive Michelle Barnett

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Alternative Option B: Impact Summary Conclusions Algoa 1 Algoa 6 Algoa 7 DAFF has noted these stakeholder concerns and has nominated Option B as the (Summerstrand) (PE Harbour) (Ngqura Harbour) preferred Alternative Option: Bivalve Bivalve Finfish • Mussel and oyster farming at Algoa 1 Option 1 (Summerstrand site) Positive economic impact High High Medium • Mussel and oyster farming at Algoa 6 (PE Harbour site); and Employment opportunity High: 780** High: 1 600** Medium: 160 • Finfish farming at Algoa 7 (Ngqura Harbour site) estimates (direct and indirect permanent jobs) Marine ecological impacts Low (6/8) High (1/7) Very low (2/8) Medium (3/7) Low (3/7) Visual aesthetics Low Very low Very low Negative socio‐economic Low (4/9) Medium (2/9) impacts Very low (4/9) Low (4/9) Insignificant (1/9) Very low (2/9) Insignificant (1/9) Heritage resources Insignificant (applicable to construction phase)

*assuming a mussel to oyster ratio 70:30 *Note that this calculation excludes temporary jobs. The impact statement in the Draft BAR includes temporary jobs, which amounts to 900 and 2 300 job opportunities at Algoa 1 and Algoa 6 respectively. Refer to Draft BAR for rational behind estimates.

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Recommendations of the EAP BA Process Timeline • Alternative Option B constitutes the best practicable environmental option: • Job creation: Option B > Option C Application Phase (Statutory) • User conflicts: Option B < Option A • Draft BAR and submit application –22 July 2019 • Commenting period: 23 July –28 August 2019 • The EAP therefore supports the application for Environmental • Submit Final BAR to Competent Authority within 90 days from Authorisation for Alternative Option B submission of application = 21 October 2019 • Conditions: • Phased implementation in conjunction with rigorous environmental monitoring. • Implementation of ADZ overseen by a management committee. • Recently identified reef at Algoa 1 must be excluded from the ADZ and access for dive operators must be maintained. Decision‐making period = 107 days The decision will be issued by 27 February 2019

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BA Process Timeline continued… Stakeholder involvement Commenting period closes Appeal process (NEMA National Appeal Regulations) on 28 August 2019 Applicant: The report is available on our website: • Inform I&APs of the decision within 14 days https://anchorenvironmental.co.za/node/344 • Can appeal within 20 days of receiving the decision Hard copies and CDs: I&APs: Newton Park Library: Hurd St, Newton Park, Port Elizabeth, 6045 Motherwell Library: Corner Umlu and Ngqokweni St, Motherwell, Port Elizabeth, • Can appeal within 20 days of receiving the notification 6211 of the decision Telephonic requests: Office Phone: 021 701 3420 Take note of the appeal procedure as per regulations Direct Cell: 081 576 3870

Email requests: [email protected]

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Thank you

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research & monitoring