6 EIA PROCESS AND METHODOLOGY 6.1 Introductionprojects.gibb.co.za/Portals/3/Wolseley_Ch6_FEIR_EIA Process and... · Hore Tamai National Energy Regulator Hilzinger-Maas S Department

Chapter 6: EIA Process and Methodology

Wolseley Wind Farm EIA March 2013 Final EIA Report

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6 EIA PROCESS AND METHODOLOGY

6.1 Introduction

An Environmental Impact Assessment (EIA) is a legislative tool that is used to assess the potential impacts that may occur due to a proposed development and to ensure that the identified impacts are avoided or mitigated (minimised) where it cannot be altogether avoided. In the South African legal context the environment includes the social, economic and bio-physical aspects and the EIA must assess these equally. The Environmental Impact Assessment (EIA) process for the Wolseley Wind Farm project was undertaken as per the regulations published under Government Notice No. R 543, 544, 545 and 5461 (2010 EIA Regulations) promulgated in terms of Chapter 52 of the National Environmental Management Act 107 of 1998 (NEMA) which came into effect on 2 August 20103. The process consists of three key steps: • Application: submission of an application to the competent authority (in

this case Department of Environmental Affairs and Development Planning)

• Scoping: A process by which the key issues are determined and a plan of study for the impact assessment phase is confirmed. This includes a Public Participation Process.

• Impact Assessment phase: This phase sees the assessment of potential impact with input from specialists. It culminates in a final Environmental Impact Report and an Environmental Management Programme (EMPr). This step again includes a Public Participation Process.

6.2 Application

The competent Authority for this application is the Western Cape Department of Environmental Affairs and Development Planning (DEA&DP). DEA&DP was consulted from the outset of this study and has been engaged throughout the EIA process. The key steps that were undertaken as part of the application phase are presented below: • All landowners on whose property the development was planned were

notified of the commencement of the EIA process. • An application for authorisation in terms of NEMA was submitted to

DEA&DP on 4 April 2012.

1 Government Gazette No. 33306 of 18 June 2010 2 Sections 24(5), 24M and 44 of NEMA 3 Government Gazette No. 33411 of 30 July 2010.



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• DEA&DP acknowledged receipt thereof on 19 April 2012 (Appendix B) and issued EIA reference number 16/3/1/2/B5/16/1002/12.

6.3 Scoping Phase

The objectives of the Scoping phase are to identify the important characteristics of the affected environment; identify and describe the environmental issues and possible impacts of the proposed project; undertake a Public Participation Process which allows open contributions by the public; and provide a Plan of Study for EIA which sets out the tasks and specialist studies to be undertaken as part of the EIA process. The key steps that were undertaken as part of the Scoping phase are presented below:

6.3.1 Consultation with the commenting Authorities (a) Dissemination of information to authorities Background information regarding the proposed project was provided to the other relevant authorities, responsible for the administration of other relevant legislation pertaining to the environment, together with a registration and comment form formally requesting their input into the EIA process. The authorities include (Table 6.1) inter alia: Table 6.1: Authorities consulted

Surname First Name Company / Organisation AUTHORITY - NATIONAL

Dikgang Jacob Department of Transport Scheermeyer Colette South African Heritage Resource Agency (SAHRA) Msengi Bulelwa SANPARKS Isherwood Chris Civil Aviation Authority Stroh Lizell Civil Aviation Authority du Plessis Valerie Department of Water Affairs (DWAF) Hore Tamai National Energy Regulator Hilzinger-Maas S Department of Agriculture Forestry and Fisheries (DAFF) Brink Nelis South African National Roads Agency Limited (SANRAL)

AUTHORITY - PROVINCIAL Ralston Duffey-?

Samantha Alana Cape Nature

Daams Francisco Department of Local Government and Housing: Provincial Disaster Management Centre

Burger Evan Department of Transport and Public Works: Western Cape Khan MAR Department of Water Affairs: Western Cape Lavin Jenna Heritage Western Cape Gwynne-Evans Nigel Department of Economic Development and Tourism: Western Cape van Coller Patrick Breede-Overberg Catchment Management Agency van der Walt Cor Department of Agriculture: Western Cape

Roux Andre Department of Agriculture: Western Cape - Sustainable Resource Management

Barnes Anthony Department of Environmental Affairs and Development Planning AUTHORITY - LOCAL

Taljaard Hennie Witzenberg Local Municipality Bali Quinton Cape Winelands District Municipality



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A full list of key stakeholders consulted during the Environmental Scoping and EIA Phase to date is included in the Interested and Affected Party (I&AP) database included in Appendix D2. Authority consultation continues throughout the EIA process. (b) Authority meetings The following key meetings were held with the authorities during the Scoping phase: • Meeting with DEA&DP on 24 May 2012 to discuss process related

issues; • Meeting with DEA&DP on 30 August 2012 to present the findings of

the FSR; and • A site visit and meeting with DEA&DP and key commenting Authorities

on 10 September 2012.

6.3.2 Draft Scoping Report (DSR) The findings of the Scoping Phase were documented in the Draft and Final Scoping Reports (DSR and FSR). The reports documented the following: (a) Environmental Impacts Environmental issues and potential positive and negative direct and indirect environmental impacts were identified during the Scoping Phase and were evaluated through desktop studies and a one day site visit. Specialists were engaged to inform this assessment. (b) Public Participation Process Key tasks included: • All comments made by authorities and the public were captured in an

Issues and Response Report (IRR) which was included as an appendix to the scoping report

• The draft Scoping Report (DSR) was submitted to DEA&DP on 24 May 2012 before the 40 day public comment period.

• The DSR was made available for comment to the registered I&APs and commenting Authorities for a 40 day period as required in terms of the 2010 EIA Regulations.

• The final Scoping Report (FSR) was made available for a 21 day public comment period before submitting it to DEA&DP for decision.

(c) Plan of Study for EIA phase A Plan of Study (PoS) was compiled and included in the Scoping Report. It set out the approach to be followed for the EIA as followings: • Tasks to be undertaken as part of the EIA process, including specialist

reports and specialised processes and the methodology for undertaking these studies;

• Indication of the stages at which the competent authority will be consulted; • Particulars of the PPP that will be undertaken during EIA phase;



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• A clear process for impact identification, prediction and evaluation; • Specification of impact identification techniques; • Criteria for evaluating the significance of impacts; • Design of mitigation measures to address impacts; and • Defining types of impacts (direct, indirect or cumulative).

6.3.3 Public Participation Process

A comprehensive Public Participation Process (PPP) was implemented as part of the Scoping phase. The following was undertaken: (a) Identifying and Notifying I&APs The identification and registration of I&APs is an ongoing process during the course of the project. Only registered I&APs were however entitled to comment, in writing, on all written submissions (reports) made to the competent authority by the applicant or the Environmental Assessment Practitioner (EAP) managing an application. I&APs were afforded the opportunity to bring to the attention of the competent authority any issues which that party believes may be of significance to the consideration of the application, provided that comments are submitted within the timeframes that have been approved or set by the competent authority or any extension of a timeframe agreed to by the application or EAP. GIBB developed, maintained and constantly updated an electronic I&AP database of registered I&APs for the EIA (see Appendix D2). During the Scoping phase the I&APs for the project were identified and notified by numerous means including the following: • Existing I&AP databases: these were obtained from the client and

other I&AP databases for other projects within the study area were consulted. Identified Key Stakeholders were then contacted telephonically and / or by fax / email and informed of the project and the EIA process and inviting their participation;

• Letters: A personally addressed letter of invitation was sent to identified landowners

• Newspapers: Placement of newspaper advertisements in two newspapers namely the Cape Argus (27 April 2012) in English, and The Witzenberg Herald (27 April 2012) in Afrikaans. Copies are provided the Scoping Report.;

• Site notice boards: Placement of site notices at the proposed site locations;

• Posters: Placement of site notices in venues in Ceres and Wolseley. The details of these locations are provided in the IRR that was provided with the Scoping Report;

• BIDs: Distribution of Background Information Documents (BIDs) which were prepared in English and Afrikaans detailing the proposed project and explaining the EIA process. The BID was mailed to I&APs on the database and delivered to identified strategic public venues. Copies of the BID were made available to I&APs as and when requested. The BID was also made available on the GIBB projects webpage (http://projects.gibb.co.za/).

• Public Open House Day: A Open House Day was held in the Wolseley Montana Community Hall on 21 June 2012. Invitations were extended to registered I&APs. One-on-one interactions were held with

http://projects.gibb.co.za/



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individuals and representatives of the relevant sectors. These interactions were particularly useful in identifying key issues and other relevant stakeholders.

• Discussions with community leaders and relevant ward councillors; and • Public documents were also made available in public libraries and other

local public venues. (b) Ongoing Consultation and Engagement In addition to the public documents distributed to I&APs, there was ongoing communication between the Applicant, the EIA team and I&APs. Written responses (email, faxes and letters) were provided to numerous I&APs acknowledging issues and providing requested information (dependent on availability). (c) Public Review of the Draft Environmental Scoping Report • The draft Environmental Scoping Report was made available for review

on 25 May 2012, for a period of 40 days. The report was made available at the Wolseley Public Library and Ceres Public Library.

• A letter was sent out to all registered I&APs providing them with an update of the project and availability of the DSR

• Comments received during the review period were included in the Final Scoping Report.

6.3.4 Final Environmental Scoping Report (FSR)

The final stage in the Environmental Scoping Phase entailed the capturing of responses and comments from I&APs on the DSR and making the submission. The following was undertaken: • The DSR was updated with the comments raised during its review; • The Final Scoping Report (FSR) (draft) was compiled and made

available on 6 July 2012 for a 21 day public comment period; and • The Final Scoping Report was submitted for decision on 6 August

2012.

6.3.5 Acceptance of the Scoping Report DEAD&DP accepted the FSR and Plan of Study for EIA on 9 November 2012. The DEA&DP, in their letter of acceptance indicated that the following issues should be considered and addressed in the EIR: • The EIA Report must contain all the information outlined in Regulation

31(2) of the 2010 EIA Regulations. Omission of information may result in the EIA Report being rejected.

• The DEIR must first be submitted to DEA&DP where after it must be made available to I&APs, including all the relevant State Departments that administer laws relating to a matter affecting the environment, for comment for a period of 40 days.

• Comment should be obtained from the Department of Environmental Affairs.



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6.4 Detailed Impact Assessment Phase

6.4.1 Introduction

The purpose of the Impact Assessment Phase of an EIA is as follows (DEA, 2005): • Address issues that have been raised during the Scoping Phase; • Assess alternatives to the proposed activity in a comparative manner; • Assess all identified impacts and determine the significance of each

impact; and • Formulate mitigation measures in order to minimise negative impacts

and optimise the effects of positive impacts. Numerous acceptable approaches and methodologies exist by which the above purpose can be achieved. The legislation in South Africa, including the guideline documents published in support thereof, does not provide a specific methodology for the assessment of impacts. Rather, an assessment framework is provided within which Environmental Assessment Practitioners (EAPs) are expected to structure a project-specific assessment methodology. This assessment framework recognises that there are different methodologies available for assessing the impact of a development but that the specific methodology selected must provide for the following (DEA, 2005): • A clear process for impact identification, prediction and evaluation; • The specification of impact identification techniques; • Criteria for evaluating the significance of impacts; • The design of mitigation measures to address impacts; • Defining types of impacts (direct, indirect or cumulative); and • Specification of uncertainties. This section serves to describe the manner in which GIBB, as the appointed EAP, intends to undertake the detailed Impact Assessment Phase of the EIA process. To ensure consistency in the assessment, all the specialists were required to make use of the same assessment methodology.

6.4.2 Impact Assessment Methodology The process of assessing the potential impacts of the project encompassed the following four activities: • Identification and assessment of potential impacts; • Prediction of the nature, magnitude, extent and duration of potentially

significant impacts; • Identification of mitigation measures that could be implemented to

reduce the severity or significance of the impacts of the activity; and • Evaluation of the significance of the impact after the mitigation

measures have been implemented, i.e. the significance of the residual impact.



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In accordance with GNR 543, promulgated in terms of section 24 of NEMA, specialists were required to assess the significance of potential impacts in terms of the following criteria: • Cumulative impacts; • Nature of the impact; • Extent of the impact; • Intensity of the impact; • Duration of the impact; • Probability of the impact occurring; • Impact non-reversibility; • Impact on irreplaceable resources; and • Confidence level. Table 6.5 provides a summary of the criteria and the rating scales, which are used in this regard. The assignment of a rating4 was undertaken based on past experience of the EIA team, the professional judgement of the specialists as well as through desktop research. Once the potential impacts were assessed in terms of the above criteria a consequence rating was applied as per the convention in Table 6.6. The overall significance of the impacts was defined based on the result of a combination of the consequence rating and the probability rating, as set out in Table 6.7. Mitigation measures were then identified and considered for each impact and the assessment repeated in order to determine the significance of the residual impacts (the impact remaining after the mitigation measure has been implemented). The results of the assessment of the significance of the residual impacts were then linked to decision-making by authorities in the following manner: • Low – did not have an influence on the decision to proceed with the

proposed project, provided that recommended mitigation measures are implemented;

• Medium – should influence the decision to proceed with the proposed project, provided that recommended mitigation measures are implemented; and

• High – would strongly influence the decision to proceed with the proposed project regardless of the implementation of recommended mitigation measures.

4 Cumulative impacts, impact non-reversibility, and impact on irreplaceable resources will together inform the impact

intensity rating



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Table 6.5: Impact Assessment Criteria and Rating Scales

Criteria Rating Scales Notes

Nature

Positive This is an evaluation of the type of effect the construction, operation and management of the proposed development would have on the affected environment. Would it be positive, negative or neutral?

Negative

Neutral

Extent This refers to the spatial scale at which the impact will occur.

Low Site-specific, affects only the development footprint

Medium Local (limited to the site and its immediate surroundings, including the surrounding towns and settlements within a 10 km radius);

High Regional (beyond a 10 km radius) to national

Duration

Low Short-term: 0-5 years, typically impacts that are quickly reversible within the construction phase of the project

Medium Medium-term, 6-10 years, reversible over time

High Long-term, 10-60 years, and continue for the operational life span of the development

Intensity This is a relative evaluation within the context of all the activities and the other impacts within the framework of the project. Does the activity destroy the impacted environment, alter its functioning, or render it slightly altered? The specialist studies must attempt to quantify the magnitude of the impacts and outline the rationale used.

Low Where the impact affects the environment in such a way that natural, cultural and social functions and processes are minimally affected

Medium Where the affected environment is altered but natural, cultural and social functions and processes continue albeit in a modified way; and valued, important, sensitive or vulnerable systems or communities are negatively affected

High Where natural, cultural or social functions and processes are altered to the extent that the impact will temporarily or permanently cease; and valued, important, sensitive or vulnerable systems or communities are substantially affected.

Degree of Reversibility This considers the ability of the impacted environment to return to its pre-impacted state once the cause of the impact has been removed.

Low Impacted natural, cultural or social functions and processes will return to their pre-impacted state within the short-term.

Medium Impacted natural, cultural or social functions and processes will return to their pre-impacted state within the medium to long term.

High Impacted natural, cultural or social functions and processes will never return to their pre-impacted state.

Potential for impact on irreplaceable resources This refers to the potential for an environmental resource to be replaced, should it be impacted. A resource could possibly be replaced by natural processes (e.g. by natural colonisation from surrounding areas), through artificial means (e.g. by reseeding disturbed areas or replanting rescued species) or by providing a substitute resource, in certain cases. In natural systems, providing substitute resources is usually not possible, but in social systems substitutes are often possible (e.g. by constructing new social facilities for those that are lost). Should it not be possible to replace a resource, the resource is essentially irreplaceable e.g. red data species that are restricted to a particular site or habitat of very limited extent.

Low No irreplaceable resources will be impacted.

Medium Resources that will be impacted can be replaced, with effort.

High There is no potential for replacing a particular vulnerable resource that will be impacted.

Consequence The consequence of the potential impacts is a summation of above criteria, namely the extent, duration, intensity and impact on irreplaceable resources.

Low

A combination of any of the following • Intensity, duration, extent and impact on irreplaceable

resources are all rated low • Intensity, duration and extent are rated low but impact on

irreplaceable resources is rated medium to high • Intensity is low and up to two of the other criteria are rated

medium



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• Intensity is medium and all three other criteria are rated low

Medium

• Intensity is medium and one other criteria is rated high, with the remainder being rated low

• Intensity is low and at least two other criteria are rated medium or higher

• Intensity is rated medium and at least two of the other criteria are rated medium or higher

• Intensity is high and at least two other criteria are medium or higher

• Intensity is rated low, but irreplaceability and duration are rated high

High • Intensity and impact on irreplaceable resources are rated high,

with any combination of extent and duration • Intensity is rated high, with all of the other criteria being rated

medium or higher Probability The probability of the impact actually occurring, based on professional experience of the specialist with environments of a similar nature to the site and/or with similar projects. It is important to distinguish between probability of the impact occurring and probability that the activity causing a potential impact will occur. Probability is defined as the probability of the impact occurring, not as the probability of the activities that may result in the impact. The fact that an activity will occur does not necessarily imply that an impact will occur. For instance, the fact that a road will be built does not necessarily imply that it will impact on a wetland. If the road is properly routed to avoid the wetland, the impact may not occur at all, or the probability of the impact will be low, even though it is certain that the activity will occur.

Low Improbable. It is highly unlikely or less than 50 % likely that an impact will occur.

Medium Distinct possibility. It is between 50 and 70 % certain that the impact will occur.

High Most likely. It is more than 75 % certain that the impact will occur or it is definite that the impact will occur.

Significance Impact significance is defined to be a combination of the consequence (as described below) and probability of the impact occurring. The relationship between consequence and probability highlights that the risk (or impact significance) must be evaluated in terms of the seriousness (consequence) of the impact, weighted by the probability of the impact actually occurring. The following analogy provides an illustration of the relationship between consequence and probability. The use of a vehicle may result in an accident (an impact) with multiple fatalities, not only for the driver of the vehicle, but also for passengers and other road users. There are certain mitigation measures (e.g. the use of seatbelts, adhering to speed limits, airbags, anti-lock braking, etc.) that may reduce the consequence or probability or both. The probability of the impact is low enough that millions of vehicle users are prepared to accept the risk of driving a vehicle on a daily basis. Similarly, the consequence of an aircraft crashing is very high, but the risk is low enough that thousands of passengers happily accept this risk to travel by air on a daily basis. In simple terms, if the consequence and probability of an impact is high, then the impact will have a high significance. The significance

Low • Low consequence and low probability • Low consequence and medium probability • Low consequence and high probability

Low to medium

• Low consequence and high probability • Medium consequence and low probability

Medium • Medium consequence and low probability • Medium consequence and medium probability • Medium consequence and high probability • High consequence and low probability

Medium to high • High consequence and medium probability



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defines the level to which the impact will influence the proposed development and/or environment. It determines whether mitigation measures need to be identified and implemented and whether the impact is important for decision-making.

High • High consequence and high probability

Degree of confidence in predictions Specialists are required to provide an indication of the degree of confidence (low, medium or high) that there is in the predictions made for each impact, based on the available information and their level of knowledge and expertise. Degree of confidence is not taken into account in the determination of consequence or probability.

Low

Medium

High

An explanation of the impact criteria is provided in Table 6.5 above. Only the above-mentioned criteria were taken into account in the assessment of impact significance. In addition, the degree of confidence in the prediction of impacts, the nature of applicable mitigation measures and legal requirements applicable to the impacts were described by the specialists. Mitigation measures are designed to reduce the consequence or probability of an impact, or to reduce both consequence and probability. The significance of impacts has been assessed both with mitigation and without mitigation. Table 6.6: Convention for Assigning a Consequence Rating

Consequence Rating

Intensity, Extent and Duration Rating

HIGH Consequence

• High intensity at a regional level and endure in the long term • High intensity at a national level and endure in the medium term • Medium intensity at a national level and endure in the long term • High intensity at a regional level and endure in the medium term • High intensity at a national level and endure in the short term • Medium intensity at a national level and endure in the medium term • Low intensity at a national level and endure in the long term • High intensity at a local level and endure in the long term • Medium intensity at a regional level and endure in the long term

MEDIUM Consequence

• High intensity at a local level and endure in the medium term • Medium intensity at a regional level and endure in the medium term • High intensity at a regional level and endure in the short term • Medium intensity at a national level and endure in the short term • Medium intensity at a local level and endure in the medium term • Medium intensity at a local level and endure in the long term • Low intensity at a national level and endure in the medium term • Low intensity at a regional level and endure in the long term

LOW Consequence

• Low intensity at a regional level and endure in the medium term • Low intensity at a national level and endure in the short term • High intensity at a local level and endure in the short term • Medium intensity at a regional level and endure in the short term • Low intensity at a local level and endure in the long term • Low intensity at a local level and endure in the medium term • Low intensity at a regional level and endure in the short term • Low to medium intensity at a local level and endure in the short term



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Table 6.7: Convention for Assigning a Significance Rating

Significance Rating Consequence x Probability

HIGH Significance

• High x Definite • High x Highly Probable • High x Probable • High x Improbable • Medium x Definite

MEDIUM Significance

• Medium x Highly Probable • Medium x Probable

LOW Significance

• Medium x Improbable • Low x Definite • Low x Highly Probable • Low x Probable • Low x Improbable

6.4.3 Consideration of Alternatives It is a requirement to consider project alternatives in any EIA. This has been addressed in Chapter 4 in which the following are considered: • The “do nothing” or ‘no-go’ alternative: The ‘do-nothing’ alternative is

the option of not establishing a wind farm on the proposed site; • Layout and design alternatives (site specific) including micro-sighting

(positioning) for the turbines.

6.4.4 Assessment of Potential Impacts Based on the findings of the Scoping Phase, the issues presented in Table 6.8 below were identified as requiring further investigation within the Impact Assessment Phase. The specialists involved in the EIA are also reflected in Table 6.8. These specialist studies considered the site proposed for the development of the wind farm and associated infrastructure, as well as all of the project alternatives. The ToR for the specialist studies is provided in Section 6.4 below. Table 6.8: Summary of issues which require further investigation in the Impact

Assessment Phase

Specialist Study

Potential Impact Specialist Name

Ecology Assessment

• Loss / fragmentation of natural vegetation; • Loss / fragmentation of populations of plant species of conservation concern; • Loss of habitat for animal species of conservation concern; • Loss of bats through collisions with turbine blades; • Loss of individuals of protected trees; • Loss of wetlands / impairment of wetland function; • Establishment and spread of declared weeds and alien invader plants; and • Change in ecological processes maintaining vegetation (fire).

Simon Todd of Simon Todd Consulting

Avifauna Assessment

• Collision mortality on the wind turbines; • Collision with the proposed power line; • Displacement due to disturbance; and • Displacement caused by habitat transformation.

Chris van Rooyen of Chris van Rooyen Consulting

Social Assessment

Impacts on Local Communities and Individuals: • Potential impact on rural sense of place (this will be closely linked to the visual

Tony Barbour of Tony Barbour Environmental Consultants



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Specialist Study


impacts); • Potential negative impact on tourism, both locally and regionally (this will be

closely linked to the visual impacts from routes currently serving a scenic/ touristic function);

• Impact on property prices (Wolseley town and adjacent/ near-adjacent rural areas where the scenic resource may be considered of significant value with regard to rural lifestyle land use);

• Influx of job seekers into the area during the construction phase. The influx of job seekers may result in an increase in sexually transmitted diseases, including HIV/AIDS; increase in prostitution; increase in alcohol and drug related incidents; increase in crime; and creation of tension and conflict in the community.

• Creation of employment and business opportunities during the construction phase;

• Creation of employment and business creation opportunities during the operational phase;

• Creation of potential training and skills development opportunities for local communities and businesses;

• Potential up and down-stream economic opportunities for the local, regional and national economy;

• Potential positive impact on tourism, in that the proposed WEF may attract visitors to the area;

• Provision of clean, renewable energy source for the national grid. • Potential positive impacts resulting from required socio-economic contribution

and local ownership through local development trust. Impacts on farmers on and adjacent to the proposed site: • Potential threat to farm safety due to increased number of people in the area and

construction workers; • Potential stock losses (during the construction and operational phase); • Potential damage to water and other farm infrastructure (during the construction

and operational phase); • Potential damage to roads by heavy equipment and increased traffic volumes

(during the construction and operational phase); and • Potential impact on farming operations and loss of productive land (during the

construction and operational phase). • Financial remuneration paid to farmers on whose properties turbines would be

located. Heritage Assessment

• Impacts on Palaeontology • Impacts on Pre-Colonial and Colonial Archaeology • Impacts on the Built Environment • Impacts on the Cultural Landscape

Dr. Lita Webley and Dave H of ACO Associates cc

Noise Assessment

Impact of noise generated during construction: • Grading and building of new roads; • Preparation of the footprint, earthworks and construction of the base of the wind

turbine; • Construction of the wind turbines; and • Construction traffic. Impact of noise generated during operation: • Wind turbines: - Normal operation of the wind turbines - Mechanical noise - Normal wear and tear, poor component design and lack of preventative

maintenance - Aerodynamic noise • Substation • Traffic Impact of noise generated during decommissioning

Barend van der Merwe of DBAcoustics

Visual Assessment

• The visual impact of the wind turbines on Houwhoek Pass. • The optimal placing of the wind turbines and the number of wind turbines to

mitigate the visual impact. • The positioning of the roads and transmission lines so that their visual impact is

minimised. • The visual impact on the local towns and farms.

Alan Cave of Bapela Cave Klapwijk



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Specialist Study


• The increase in visual impact of the turbines due to the potential requirements for red and white colouring for aeronautical purposes.

• The impact along the R46 from the fact that the wind turbines will be visible against the skyline from viewpoints to the north and south of the proposed site.

• The impact on scenic routes due to the proximity and visibility of the site from these routes.

Agricultural Impact Assessment

• Assessment of the agricultural potential of the properties, as determined by the availability and condition of the resources and relative access to markets.

• Agricultural use during and after wind farm operation. • Description of potential impacts of the proposed WEF on agricultural resources,

activities and potential farm income (information to be extracted from report by Hugo van Zyl).

• General description of mitigation measures and possible benefits. • Management and monitoring guidelines.

Francois Knight of Agri Informatics

Bat Sensitivity Assessment

• Monitoring of habitat types and predictions on the species and activities of bats that may reside in different parts of the proposed wind energy site.

• Important roosts and geographical features that will attract bats (for foraging and/or roosting).

• Compilation of a bat species probability of occurrence table as well as site specific habitat applicable to each species.

• The foreseen impacts will each be given a significance rating, distinguishing between construction and operational phases. Additionally cumulative nature of impacts will also be considered where applicable.

• The proposed alternatives will be compared and recommendations given. • Mitigation measures and recommendations will be given for each expected.

Werner Marais of Animalia Consulting

Wetland delineation

• Overlay of proposed development footprint/s on the map of freshwater ecosystems and wetlands, to examine the extent of encroachment into these areas;

• Provision of broad guidelines for the protection of the mapped freshwater ecosystems and wetlands, which would be of relevance to the proposed project; and

• Recommendation of specific Freshwater Ecosystem studies that should be completed for the impact assessment phase of the proposed project.

Dean Ollis of Freshwater Consulting

Economic Impact Assessment

• Provide a profile of the existing economic context within which the project would be established.

• Identify significant economic impacts for assessment. • Assess significant economic impacts to the extent judged appropriate and

recommend appropriate management and mitigation measures.

Dr. Hugo van Zyl of Independent Economic Researchers

6.4.5 Description of assumptions made, uncertainties or gaps in knowledge Avifauna The basic assumption made in this study is that the sources of information used are reliable. However, it must be noted that there are certain limitations: • Observations at vantage points will be biased towards those species that are

more visible (i.e. larger species), and flights that are closer to the observer. • The spatial distribution of priority species that were recorded during transect

counts and as incidental sightings may be biased towards the transects and roads in the study area and should therefore not be viewed as being representative of the actual spatial distribution of the birds.

• The analyses of the data in this report should be viewed as descriptive and preliminary pending an in depth statistical analyses of the final (four seasons) dataset.



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• No comprehensive studies, and published, peer-reviewed scientific papers, are available on the impacts wind farms have on birds in South Africa. Heavy reliance had to be placed on professional judgment.

• Given the lack of research on the topic in South Africa, the precautionary principle was applied throughout.

Bats

• Distribution maps of South African bat species still require further refinement. The literature based table of species probability of occurrence may include a higher number of bat species than actually present.

• The migratory paths of bats are largely unknown, thus limiting the ability to determine if the wind farm will have a large scale effect on migratory species. This limitation however will be overcome with long-term bat monitoring.

• The satellite imagery partly used to develop the sensitivity map may be slightly imprecise due to land changes occurring since the imagery was taken. Satellite imagery from Google Earth for 2012 was utilized to minimize this limitation.

• A significant limitation was that the field work was carried out during a winter cold front. Bat detection will be significantly lowered during periods of cold and consistent rainfall. The high rainfall also limited the extent to which the site could be traversed for bat detection. This slightly compromises the assessment of the extent of habitat use by bats. However the assessment, in terms of bat species encountered and expected on site and the sensitivity map generated remains largely credible.

Ecology Most of these areas are well documented by fine-scale vegetation maps and the CBA maps for the area. As the sensitivity of these areas has already been well documented, these areas were not investigated in detail during the study, except where transformation had taken place since the mapping had occurred, in which case the current land use and status of these areas was verified in the field. In contrast to these high sensitivity areas, the site also contains a large proportion of transformed habitats which retain little of their original biodiversity or ecological function. Development within these areas is not likely to pose significant ecological risk and could proceed with little impact on the terrestrial environment.

Broadly speaking, the site consists of transformed areas which are largely of low sensitivity and areas of intact vegetation which are largely of very high sensitivity. Therefore given the contrasting nature of the site, a habitat level assessment was used as the primary approach for field assessment. This involved the validation of the CBA map for the area, which was outdated in several areas on account of recent transformation that has taken place. An attempt to derive a full species list for the entire site was not made, as the primary goal was to avoid impact to areas of intact vegetation. Nevertheless in the final layout not all areas of natural vegetation could be avoided and a small number of turbines fall within areas of natural or semi-natural vegetation. In such cases, these locations were specifically assessed in the field, and a full species list for the affected area was recorded.



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In addition, the site and the layout were also discussed with Rupert Koopman the botanist from CapeNature who is familiar with the area and distribution of species of conservation concern at the site. This aided in refining the sensitivity map as well as ensuring that all known areas of potential concern were captured in the sensitivity map. The final sensitivity map of the site therefore represents the best current knowledge of biodiversity pattern within the study area and is thoroughly ground truthed with all sensitive features present mapped at a high level of detail and spatial accuracy. Aquatics and wetlands The quality of the aerial photographic imagery used for this study was not ideal in that images were captured in summer, when wetlands are least visible given the winter-rainfall climate of the area. The relatively poor resolution of the imagery that was available made it difficult to discern the presence of wetlands with a high degree of confidence, although this was ameliorated to some degree by systematic scanning of the site using Google Earth satellite imagery, and later by field-based ground-truthing.

When the fieldwork for this study was undertaken, the final layout plan for the proposed WEF had not yet been generated and an earlier iteration of the site development plan was used. As such, there are portions of the site where turbines and/or roads have been proposed in the final layout plan, as assessed in this report, that were not specifically visited when the fieldwork was undertaken. Assumptions have thus been made about the presence, extent and ecological condition of wetlands in these areas on the basis of field information gathered from nearby areas. Agriculture No specific assumptions that could significantly alter the findings of the study were made.

Visual • The largest/ tallest of the possible turbine sizes and their layout provided was

used as this is the worst case scenario; • There will be no workers or staff housing constructed for the duration of the

infrastructure installation or the erection of the turbines; • There will be no mast erected for the transmission of data that will be higher than

the nacelle of the wind turbine; • All soil excavated from the turbine foundations will be disposed of in a manner

that will not constitute a visual intrusion within the site area or beyond. However if this should be so the assessment of this new landform is not part of this visual impact assessment study;

• The construction of new roads and temporary sheds required for the construction, erection and storage of equipment will not be addressed in depth in the study; and

• Two red lights on the nacelle, which is an international standard, will be used to identify wind energy towers at night.

The following gaps in knowledge have been identified:



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• The location of future residential housing development areas, other than the new

residential development De Vierde Liefde that is in progress. This is located in a short shallow valley that is orientated East-North-East to West-South-West east of Kanonkop in the foot slope of the Waaihoekberge.

Noise • The noise calculations were based on wind speeds of 5.0 m/s, 7.7 m/s and 15 m/s with

trees and vertical structures in the vicinity of the measuring point. • The noise levels of a Vestas wind turbine (Coega) was used with a wind speed of 2.5

m/s to 3.0 m/s to determine the noise levels at different distances from the turbine. These noise levels were compared with noise levels of studies done at the University of Massachusetts and the Australian Wind energy Association. These noise levels were found to be in line with the noise levels of the modern type wind turbines which are used in wind farms.

• The prevailing noise level at the different distances from the wind turbine is illustrated in Figure 7. This was for a turbine of 50 m in height and the wind turbine measured was 80 m high. There will therefore be a further noise reduction of 3.0 dBA because of the Inverse Square Law applicable where sound will decrease with 6.0 dB per doubling of the distance from the source (Tontechnik – Rochner)i.

Figure 6-1: Noise levels at a distance from turbine (Rodgers, 2006)

Heritage • It is assumed that during fieldwork most significant above ground heritage

resources were identified. • However, due to the size of the study area, it is considered unlikely that field

surveys will have identified all the heritage resources in the area. It is possible that unidentified formal and informal graveyards may occur within the boundaries of the proposed facility. Similarly, it is anticipated that historical archaeological sites may exist in proximity to old farmsteads although none were identified during the fieldwork.



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• Oral histories relating to heritage resources and the historic use of the landscape may be available. Due to time constraints, no interviews were conducted with farm workers.

Economics • All technical, financial (i.e. viability estimates, business plans and costs) and

other information provided by the applicant, other official sources and other specialists involved in the EIA is assumed to be correct unless there is a clear reason to suspect incorrect information.

• The quantification of economic impacts in order to inform the assessment of the significance of impacts was not possible, nor considered necessary, for all impacts. Where possible, quantification focused on impacts considered to be most important in the overall assessment. Assessments of impact significance made without quantification (and based on a consideration of the likely magnitudes of impacts and/or expert judgements) are, however, considered adequate unless specified otherwise.

• The assessment borrows from information gathered by the author as part of the compilation of the economic specialist studies for EIAs of other renewable energy projects in the region and elsewhere. This is done only where relevant and in order to avoid unnecessary duplication of effort.

Social • It is assumed that the strategic importance of promoting renewable energy,

including wind energy, is supported by the national and provincial energy policies.

• It is assumed that the development site identified by SAGIT represents a technically suitable site for the establishment of a WEF.

• Legislation and policies reflect societal norms and values. The legislative and policy context therefore plays an important role in identifying and assessing the potential social impacts associated with a proposed development. In this regard a key component of the SIA process is to assess the proposed development in terms of its fit with key planning and policy documents.

The following limitation was identified:

• The demographic data used in the study is largely based on Census 2001 and

StatsSA’s Community Survey 2007, or projections based on them. The information from Census 2011 was not available at the time of preparing the report. While this data does provide useful information on the demographic profile of the affected area, the actual data is dated and should be treated with care.

6.4.6 Draft Environmental Impact Report

In accordance with Regulation 31 of the 2010 EIA Regulations, the contents of the Draft Environmental Impact Report (DEIR) should include the following: • Details and expertise of the EAP to undertake an EIA (Chapter 2); • Detailed description of the proposed activity (Chapter 3); • Detailed description of the property on which the activity is to be

undertaken and the location of the activity on the property (Chapter 1);



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• A description of the environment that may be affected by the activity and the manner in which the physical, biological, social, economic and cultural aspects of the environment may be affected by the proposed activity (Chapter 7);

• Details of the PPP conducted during the detailed assessment phase of the EIA process (Chapter 6 and Appendix D);

• A description of the need and desirability of the proposed activity and identified potential alternatives to the proposed activity, including advantages and disadvantages that the proposed activity or alternatives may have on the environment and the community that may be affected by the activity (Chapter 3);

• An indication of the methodology used in determining the significance of potential environmental impacts (Chapter 6);

• A description and comparative assessment of all alternatives identified during the environmental impact assessment process (Chapter 4);

• A summary of the findings and recommendations of any specialist report or report on specialised process (Chapter 18);

• A description of all environmental issues that were identified during the environmental impact assessment process, an assessment of the significance of each issue and an indication of the extent to which the issues could be addressed by the adoption of mitigation measures (Chapter 8 – 18);

• An assessment of each identified potentially significant impact in terms of cumulative impacts, the nature of the impact, the extent and duration of the impact, the probability of the impact occurring, the degree to which the impact can be reversed, the degree to which the impact may cause irreplaceable loss of resources and the degree to which the impact can be mitigated (Chapter 8 – 18);

• A description of any assumptions, uncertainties and gaps in knowledge (Chapter 6);

• An opinion as to whether the activity should or should not be authorised, and if the opinion was that it should be authorised, any conditions that should be made in respect of that authorisation (Chapter 18);

• An environmental impact statement which contains a summary of the key findings of the environmental impact assessment, a comparative assessment of the positive and negative implications of the proposed activity and identified alternatives (Chapter 18);

• A draft Environmental Management Plan (EMP) (Appendix F); • Copies of any specialist reports and reports on specialised processes

(Appendices E1-11); and • Any specific information that may be required by the competent

authority.

6.4.7 Draft Environmental Management Plan (EMP) During the compilation of the DEIA Report, a draft EMP was compiled in accordance with the NEMA EIA Regulations. The draft EMP provided the actions for the management of identified environmental impacts emanating from the proposed project and a detailed outline of the implementation programme to minimise and/ or eliminate the anticipated negative environmental impacts. The draft EMP also provided strategies to be used to address the roles and responsibilities of environmental management



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personnel on site, and a framework for environmental compliance and monitoring. The EMP includes the following: • Details and expertise of the person who prepared the EMP; • Information on any proposed management or mitigation measures that

would be taken to address the environmental impacts that are identified in the Environmental Impact Report (EIR), including environmental impacts or objectives in respect of planning and design, pre-construction and construction activities, operation or undertaking of the activities, rehabilitation of the environment and closure where relevant;

• A detailed description of the aspects of the activity that are covered by the draft EMP;

• An identification of the persons who will be responsible for the implementation of the measures;

• Time periods within which the measures contemplated in the draft EMP must be implemented; and

• Proposed mechanisms for monitoring compliance with the EMP and reporting thereon.

6.4.8 Public Participation Process (PPP)

(a) Notifying and engaging I&APs As done for the Scoping Phase, registered I&APs will be engaged through a number of means in the EIA phase, including the following: • Newspapers: Placement of newspaper advertisements in two

newspapers namely the Cape Argus (30 November 2012) and The Witzenberg Herald (30 November 2012) in English, and Die Burger (30 November) in Afrikaans. Copies of the advertisements are provided in Appendix D1;

• Posters: Placement of site notices in venues in Ceres and Wolseley. The details of these locations are provided in Appendix D1;

• Public Open House Day: An Open House Day is planned to be was held on 31 January 2013 in the Wolseley area. Invitations will be were extended to registered I&APs and will be published in the newspapers.

(b) Ongoing Consultation and Engagement Ongoing consultation with all stakeholders and registered I&APs continued beyond the approval of the Scoping Report into the Impact Assessment Phase of the EIA process. Consultation during the EIA process was undertaken by means of the following: • Maintaining an open channel of communication with all stakeholders

and authorities; • Distribution of all project information and findings to registered I&APs;

and • Information in the media and press.



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(c) Public Review of the Draft EIR • The draft EIR and EMP were made available for review on Friday 30

November 2012, for a period of 40 days. The 40 day comment period was be interrupted by the holiday period (15 December to 2 January 2012), and was therefore extended by 20 days, and will ended on 31 January 2013]. The report was made available at the Wolseley Public Library and Ceres Public Library. The reports were also made available on the Gibb website.

• A letter was sent out to all registered I&APs providing them with an update of the project and availability of the draft EIR.

• Comments received during the review period were included in the Final EIR.

• The final EIR and EMP will be were made available for review on [date to be confirmed] 8 February 2013, for a period of 21 days.

• A letter was sent out to all registered I&APs providing them with an update of the project and availability of the Final EIR.

• After the 21 day review period, the Final EIR was updated with comments received and will be submitted to the DEA&DP on [date to be confirmed] 4 March 2013.

6.5 Specialist Studies

A number of specialists as shown in the table below, were involved in the detailed Impact Assessment Phase of the EIA process. Table 6.1: Specialist Studies to be undertaken during the Impact Assessment Phase of the EIA

Specialist Study Specialist Name

Ecology Impact Assessment Simon Todd

Avifauna Impact Assessment Chris van Rooyen of Chris van Rooyen Consulting

Social Impact Assessment Tony Barbour of Tony Barbour Environmental

Heritage Impact Assessment Dr. Lita Webley and David Halkett of ACO Associates cc

Noise Impact Assessment Barend van der Merwe of DBAcoustics

Visual Impact Assessment Reuben Heydenrych of Aurecon and Alan Cave of Bapela Cave Klapwijk cc

Agricultural Impact Assessment Francois Knight of Agri Informatics

Economic Impact Assessment Dr. Hugo van Zyl, Independent Eocnomic Researchers

Bat Sensitivity Assessment Werner Marais, Animalia Consulting

Wetland Delineation and Assessment Dean Ollis of Freshwater Consulting Services

The scope of each of the above individual studies was provided in the Plan of Study for EIA.



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6.6 Conclusion

This Impact Assessment methodology was aimed at meeting the requirements of the 2010 EIA Regulations as a minimum. The methodologies proposed for obtaining the information required to effectively identify and assess the potential environmental impacts of the project are considered to be comprehensive and sufficient to allow for the compilation of this EIR which addresses I&AP concerns and which will provide the competent authority with the appropriate information necessary to allow for informed decision-making on the application for authorisation.

i Tontechnik-Rechner - www.sengpielaudio.com/calculator-distancelaw.htm. Accessed 2 July 2012 30 Evans, T and J. Cooper, Comparison of predicted and measured wind farm noise level and implications for assessment of new wind farms. Acoutics Australia. Vol 40. April 2012. 28-36.

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