DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP 3.4 Applicable listed activities comment, will be amended accordingly. 3.4.1 Activity 14 of Government Notice (“GN”) No. R. 983 of 4 December 2014 may be triggered by the proposed development. Confirmation of whether dangerous goods 3.4.1 No dangerous goods will be will be stored on the proposed site and the volume thereof (if any) must be provided stored on site, and this is why in the EIA Report. this activity has been omitted. 3.4.2 Activity 28 of GN No. R. 984 of 4 December 2014 will be triggered by the 3.4.2. Please note that this proposed development as an Atmospheric Emissions Licence (“AEL”) in terms of the activity will be included as an National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) amendment to the application (“NEM:AQA”) is required. following the submission of the Air Quality Impact Assessment. 3.4.3 A revised Application Form may have to be submitted to the competent authority upon confirmation of the above-mentioned listed activities. 3.4.3 Please see above, thank you for highlighting this. 3.5.1 Agreed. The EIA report will 3.5 Alternatives investigate technology 3.5.1 According to the DSR, two site alternatives were identified and a site selection alternatives for these sites. matrix was undertaken to determine the preferred location of the proposed 3.6.1 This was included in the development. This includes site 1 (Cape Farm No. 1183 and Portion 93 of Cape Farm FSR, Chapter 6. No. 4, Atlantis) and site 2 (Portion 1 of Portion 4 of Cape Farm No, 1183, Atlantis). It is further noted that site 2 is the preferred site alternative based on the environmental 3.6.2. Noted, thank you. Chapter attributes, spatial character and proximity to sensitive human structures. 7 9Plan of Study) highlights the Alternatives for the generation of electricity from a non-renewable resource have ToR’s for all the studies which been identified, but were considered as not feasible for further assessment. The EIA are being conducted, as well as Report must therefore provide an assessment of the technology alternatives to be the three studies already considered for the proposed development. When selecting the preferred conducted. alternative, please be advised that the alternative with the least environmental 3.6.3. Noted, thank you. impacts must be deemed as the most reasonable and feasible alternative. 3.7.1. Correct. 3.7.2. This will be verified and 3.6 Impact assessment updated. 3.6.1 It is noted that a preliminary scoping phase impact assessment was conducted APPENDIX H – ISSUES AND RESPONSES TRAIL pg 63 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP based on existing information and the results of this preliminary assessment will be 3.7.3. Correct. Please note that verified by the relevant specialists during the EIA phase. A list of the potential an Avifaunal Assessment is also impacts associated with the proposed development must be provided in the Final going to be conducted to assess Scoping Report to be submitted to the competent authority. the impacts of the transmission lines. 3.6.2 All the potential impacts associated with the proposed development are to be assessed and/or reported on in the EIA Report. 3.8. An Emergency Response Plan will be included in the Draft 3.6.3 A detailed description of storm water and effluent management must be EIA report, which will be able to included in the EIA Report and the Environmental Management Programme be commented on and amended (“EMPr”) must provide suitable prevention/ mitigation measures for these aspects. accordingly. 3.9. The EAP will obtain this 3.7 Specialist reports confirmation in the EIA phase. 3.7.1 It is understood that the following specialist reports (conducted as part of a 3.10.1 Noted, thank you. previous EIA process) will be used to assess some of the potential impacts identified as part of this EIA application: (i) Botanical Assessment (compiled by Bergwind Botanical Surveys and Tours, dated June/July 2012); (ii) Paleontological Assessment (compiled by G. Avery, dated July 2012); and (iii) Archaeological Input (compiled by ACO Associates, dated 10 July 2012). 3.7.2 The mentioned specialist reports along with updated statements have been included in the DSR. It is important to note that the specialist reports all refer to the development on Portion 1 and Portion 4 of Cape Farm No. 1183, Atlantis. 3.7.3 It is further understood that the following specialist assessments will be undertaken as part of the EIA reporting phase, being an Air Quality Impact Assessment; Noise Impact Assessment; and a Risk Assessment. 3.8 Plan of Study for EIA APPENDIX H – ISSUES AND RESPONSES TRAIL pg 64 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP 3.8.1 The Plan of Study for EIA must include the compilation of an Emergency Response Plan (as per the City of Cape Town’s requirements) since the proposed site is located within the 16km Urgent Protective Zone of the Koeberg nuclear power plant. 3.9 Confirmation of services 3.9.1 Confirmation that the local authority has sufficient, spare unallocated capacity to provide water, sewage disposal, refuse removal and electricity services must be included in the EIA Report. 3.10 General 3.10.1 The DSR incorrectly refers to this Department’s Guideline on Need and Desirability, 2010. The correct reference is the Guideline on Need and Desirability dated March 2013, which forms part of the EIA Guideline and Information Document Series (March 2013). 4. Directorate: Waste Management – Gary Arendse ([email protected]; Tel: (021) 483 3872): 4.1 Section 4.2.1 of the DSR must be amended to include the applicability of the National 4.1 This is noted, thank you. Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) and its subordinate Please note no hazardous and/or legislation to the proposed development. Your attention is drawn to GN No. No. 926 of 29 general waste will be stored on November 2013: National Norms and Standards for the Storage of Waste. Please be advised site and this legislation does not that the storage of hazardous and general waste in excess of 80m³ and 100m³ respectively, apply. excluding the storage of waste in lagoons or the temporary storage of such waste, would 4.2 The Draft EMPr will contain require the applicant to comply with said norms and standards. detailed information regarding the disposal and management of APPENDIX H – ISSUES AND RESPONSES TRAIL pg 65 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP waste. 4.2 The EIA Report must provide detailed information on the volume of waste to be 4.3. Noted, this will be included. generated and how waste from the proposed CCGT plant and associated infrastructure during the construction and operational phase will be managed. The waste management hierarchy (reduction, re-use and recycling of waste) must be implemented to ensure that the disposal of waste should only be as a last resort. Any resulting waste generated during the construction/commissioning and operation of the proposed development which cannot be re-used or recycled, must be disposed of at a licensed waste disposal facility. 4.3 The EMPr to be included with the EIA Report must address the prevention and management of potential leaks and spillages of hazardous substances. Any hazardous substances and fuel must be kept in storage areas that are bunded and with a capacity to contain 110% of the volume of any hazardous substances and fuel. Spill kits must be available on-site for clean-up of potential spills. 5. Directorate: Air Quality Management – Peter Harmse ([email protected]; Tel: (021) 483 8343): 5.1 Noise and dust management: 5.1.1 This is noted and these 5.1.1 The Air Quality Impact Assessment to be undertaken during the EIA phase must impacts will be taken into take cognisance of the National Dust Control Regulations (GN No. R. 827) of 1 consideration. November 2013, promulgated in terms of NEM:AQA. These regulations prohibit a person from conducting any activity in such a way as to give rise to dust in such 5.1.2 The Draft EIA report will quantities and concentrations that the dust or dust fall may have a detrimental include this regulation, as well as effect on the environment, including health. the Draft EMPr. 5.1.2 It is noted that a Noise Impact Assessment will be conducted during the EIA 5.2.1. Odour may be briefly phase. Please be advised that Section 8.7.2 of the Plan of Study for EIA must be discussed in the DEIR, however, amended to indicate that noise generated from the installation and operation of the this is not deemed a significant APPENDIX H – ISSUES AND RESPONSES TRAIL pg 66 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT for the proposed Atlantis Gas-to-Power facility on Portion 1 of Portion 4 of Cape Farm 1183, Western Cape DATE OF COMMENT, FORMAT OF RESPONSE FROM NO COMMENT COMMENT, NAME OF EAP/APPLICANT/SPECIALIST ORGANIZATION/I&AP CCGT facility (gas turbines/gas engines, electric generators, dry cooling systems, impact in the Scoping Phase.