APPENDIX F5

REVISED BAR NOTIFICATION LETTERS

From: Mandy KulaTo: Mandy KulaBcc: "brian@wicht.co.za"; "yolandaswart@mweb.co.za"; "admin@bluebaylodge.co.za";

"admin3@bluebaylodge.co.za"; "aduffell-canham@capenature.co.za"; "albiec@cartol.co.za";"andre.vermaak@rhdhv.com"; "andre@bluebaylodge.co.za"; "admin@bluebaylodge.co.za";"arthur@mogscpt.co.za"; "barthlo@sunrise-energy.co.za"; "basil.sylvester@arcelormittal.com";"baysteel@wcw.co.za"; "bb@atlantiscorp.co.za"; "bmathibe4@gmail.com"; "coenraadl@dsp.co.za";"corvdw@elsenburg.com"; "dkotze@wcdm.co.za"; "donovan.samuels@transnet.net"; "doug@sbidz.co.za";"dru.martheze@westerncape.gov.za"; "duncanm@idc.co.za"; "durban@bidports.co.za";"elmien.debruyn@duferco.co.za"; "Ethel.Coetzee@transnet.net"; "frikkie.burger@angloamerican.com";"gavin.venter@za.afrisam.com"; "gerrit.smith@sbm.gov.za"; "grace.swanepoel@westerncape.gov.za";"hannes@sbidz.co.za"; "herman.jonker@westerncape.gov.za"; "hilltopcottage@salnet.co.za";"hugh@lindsaywaters.com"; "info@capebiosphere.co.za"; "info@langebaanratepayers.co.za";"ivor@conrec.co.za"; "jaco.dewaal@arcelormittal.com"; "jakes@genwest.co.za"; "janet@sunrise-energy.co.za"; "janh@dsp.co.za"; "janphillips@iafrica.com"; "jeanette.smit@transnet.net";"jhwicht@coastnet.co.za"; "jillcarnegie@gmail.com"; "johnselby@worldonline.co.za";"kaashifah@sbidz.co.za"; "kimberley.McGregor@smec.com"; "langemeer@mweb.co.za";"mw.charl@mweb.co.za"; "linda@sbidz.co.za"; "lindsey.gaffley@sbm.gov.za"; "louw.venter@aecom.com";"malcolm.watters@westerncape.gov.za"; "metsal@imaginet.co.za"; "morgandebeer11@gmail.com";"mun@sbm.gov.za"; "nazeema.duarte@sbm.gov.za"; "pierreluimalherbe@gmail.com";"Pieter@mogscpt.co.za"; "pjh@fossilpark.org.za"; "portside@telkomsa.net"; "quentin.dollman@gmail.com";"quentin.kordom@transnet.net"; "randall.julies@transnet.net"; "reon@vdmsa.com";"rob.billett@transnet.net"; "rod@pgwc.biz"; "russell@gvj.co.za"; "saldanha@sbto.co.za";"stephan@mogs.co.za"; "susan@avediaenergy.com"; "Wally.Silbernagl@westerncape.gov.za";"willem.roux@transnet.net"; Ena de Villiers; Eloise Costandius

Subject: PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEA&DPREFERENCE NO. 16/3/3/1/F14/17/3011/17): NOTIFICATION OF AVAILABILITY OF REVISED BASICASSESSMENT REPORT FOR REVIEW AND COMMENT

Date: 09 June 2017 09:39:00 AMAttachments: Exec Summary - Revised BAR (9 June 2017).pdf

Let Revised BAR Notification (9June17).pdf

Dear Sirs / Madams We write to inform you about the availability of a revised Basic Assessment Report (BAR) for theabove-mentioned proposed project, which has been compiled in order to incorporate newinformation which became available subsequent to the compilation of the BAR that was releasedfor a 30-day review and comment period which closed on 10 April 2017. The revised has been made available for a 30-day review and comment period from 9Juneto10July2017(including one additional day to cover the intervening public holiday on 16June 2017). The following documentation regarding this matter is attached for you information:

A notification letter; andA copy of the Executive Summary of the revised BAR.

A full copy of the revised BAR is available for download at the following link:http://slrconsulting.com/za/slr-documents/proposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries. Best regards

mailto:mkula@slrconsulting.commailto:brian@wicht.co.zamailto:yolandaswart@mweb.co.zamailto:admin@bluebaylodge.co.zamailto:admin3@bluebaylodge.co.zamailto:aduffell-canham@capenature.co.zamailto:albiec@cartol.co.zamailto:andre.vermaak@rhdhv.commailto:andre@bluebaylodge.co.zamailto:admin@bluebaylodge.co.zamailto:arthur@mogscpt.co.zamailto:barthlo@sunrise-energy.co.zamailto:basil.sylvester@arcelormittal.commailto:baysteel@wcw.co.zamailto:bb@atlantiscorp.co.zamailto:bmathibe4@gmail.commailto:coenraadl@dsp.co.zamailto:corvdw@elsenburg.commailto:dkotze@wcdm.co.zamailto:donovan.samuels@transnet.netmailto:doug@sbidz.co.zamailto:dru.martheze@westerncape.gov.zamailto:duncanm@idc.co.zamailto:durban@bidports.co.zamailto:elmien.debruyn@duferco.co.zamailto:Ethel.Coetzee@transnet.netmailto:frikkie.burger@angloamerican.commailto:gavin.venter@za.afrisam.commailto:gerrit.smith@sbm.gov.zamailto:grace.swanepoel@westerncape.gov.zamailto:hannes@sbidz.co.zamailto:herman.jonker@westerncape.gov.zamailto:hilltopcottage@salnet.co.zamailto:hugh@lindsaywaters.commailto:info@capebiosphere.co.zamailto:info@langebaanratepayers.co.zamailto:ivor@conrec.co.zamailto:jaco.dewaal@arcelormittal.commailto:jakes@genwest.co.zamailto:janet@sunrise-energy.co.zamailto:janet@sunrise-energy.co.zamailto:janh@dsp.co.zamailto:janphillips@iafrica.commailto:jeanette.smit@transnet.netmailto:jhwicht@coastnet.co.zamailto:jillcarnegie@gmail.commailto:johnselby@worldonline.co.zamailto:kaashifah@sbidz.co.zamailto:kimberley.McGregor@smec.commailto:langemeer@mweb.co.zamailto:mw.charl@mweb.co.zamailto:linda@sbidz.co.zamailto:lindsey.gaffley@sbm.gov.zamailto:louw.venter@aecom.commailto:malcolm.watters@westerncape.gov.zamailto:metsal@imaginet.co.zamailto:morgandebeer11@gmail.commailto:mun@sbm.gov.zamailto:nazeema.duarte@sbm.gov.zamailto:pierreluimalherbe@gmail.commailto:Pieter@mogscpt.co.zamailto:pjh@fossilpark.org.zamailto:portside@telkomsa.netmailto:quentin.dollman@gmail.commailto:quentin.kordom@transnet.netmailto:randall.julies@transnet.netmailto:reon@vdmsa.commailto:rob.billett@transnet.netmailto:rod@pgwc.bizmailto:russell@gvj.co.zamailto:saldanha@sbto.co.zamailto:stephan@mogs.co.zamailto:susan@avediaenergy.commailto:Wally.Silbernagl@westerncape.gov.zamailto:willem.roux@transnet.netmailto:edevilliers@slrconsulting.commailto:ecostandius@slrconsulting.comhttp://slrconsulting.com/za/slr-documents/proposed-new-access-roads-to-the-idz

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EXECUTIVE SUMMARY 1. INTRODUCTION The Applicant, Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC), is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1). The proposed additions to the road network for the SBIDZ would entail the following: A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide

access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant; and

A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant.

SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road. In turn, SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project. The Basic Assessment Report (BAR) and Environmental Management Programme (EMP) was distributed for a 30-day public review and comment period from 10 March to 10 April 2017. Significant new information in the form of Western Cape Biodiversity Spatial Plan data layers, including Critical Biodiversity Areas which affect the proposed project site, became available subsequent to the compilation of the BAR. This, amongst others, constitutes significant new information which had to be incorporated into a revised BAR. It should be noted that all significant changes to the BAR are underlined and in a different font (Times New Roman) in this revised BAR. The revised BAR and EMP has been distributed for a further 30-day public review and comment period from 9 June to 10 July 2017 (including an additional day to cover the public holiday on 16 June 2017). Copies of the report will be available at the following locations from 9 June 2017: Saldanha Public Library; Offices of SLR; and On the following website: www.slrconsulting.com/za. Any written comments on the revised BAR and EMP must reach SLR at the following contact details by no later than Monday 10 July 2017:

SLR Consulting (Pty) Ltd Unit 39, Roeland Square

30 Drury Lane, Cape Town, 8001

Attention: Ena de Villiers

Tel: (021) 461 1118 / 9 Fax: (021) 461 1120

E-mail: edevilliers@slrconsulting.com

After the comment period, the BAR and EMP will be submitted to the Department of Environmental Affairs and Development Planning (DEA&DP) for consideration of the application. All comments received on the revised BAR will be collated into a Comments and Responses Report, which will be submitted to DEA&DP together with the report. After DEA&DP has reached a decision, all registered Interested and Affected Parties (I&APs) will be notified of the outcome of the application and the reasons for the decision. A statutory Appeal Period in terms of the National Appeal Regulations, 2014 will follow the issuing of the decision.

mailto:edevilliers@slrconsulting.com

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2. APPLICABILITY OF THE NEMA EIA REGULATIONS Note: Subsequent to the commencement of the Basic Assessment, the EIA Regulations 2014 were amended on

7 April 2017. Listed activities in terms of the original EIA Regulations 2014 (4 December 2016) are presented in Table A1 for reference purposes, and listed activities in terms of EIA Regulations 2014, as amended, are presented in Table A2. All the potential impacts associated with the amended listed activities have been considered and adequately assessed in this revised BAR.

Table A1: Listed activities in terms of the EIA Regulations 2014 (4 December 2014) - GN No. R. 983 and R. 985

GN R983 Listed Activities Listing Notice 1 Project Description 24 The development of

(ii) a road with a reserve wider than 13.5 meters, or where no reserve exists where the road is wider than 8 metres;

but excluding (b) roads where the entire road falls within an urban area

The proposed eastern access road reserve would be 32.6 m wide. The road reserve for the north-south road would be 30 m wide, except at the southern end, where it would be 54 m wide in order to accommodate the intersection with the eastern access road.

GN R985 Listed Activities Listing Notice 3 Project Description 12. The clearance of an area of 300 square metres or more of

indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan. (a) In Western Cape: i. Within any critically endangered or endangered

ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list, within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004.

The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types. Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA. A 2014 CapeNature (Pence, 2014) status update document, however, increased the threat status to Endangered and it is thus assessed as such.1

18. The widening of a road by more than 4 metres, or the lengthening of a road by more than 1 kilometre. (f) ) In Western Cape: i. All areas outside urban areas: (aa) Areas containing indigenous vegetation

The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 5.5 m at the intersection point.

Table A2: Listed activities in terms of the EIA Regulations 2014, as amended (7 April 2017) - GN No. R. 327 and R. 325

GN R327 Listed Activities Listing Notice 1 Project Description 24 The development of a road

(ii) with a reserve wider than 13.5 meters, or where no reserve exists where the road is wider than 8 metres;

but excluding a road (b) where the entire road falls within an urban area; or (c) which is 1 kilometre or shorter.

The road reserve for the proposed eastern access road reserve would be 30 m wide. The 54 m wide road reserve at the intersection of the new proposed access roads and Street 2, just east of the access to the SBIDZ eastern security entrance, was previously authorised in 2015 as part of the SBIDZ development.2

GN R324 Listed Activities Listing Notice 3 Project Description 12. The clearance of an area of 300 square metres or more of

indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan. (a) In Western Cape:

The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types. Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA. The eastern access road would pass through a designated CBA1 included in

1 DEA&DP, in their comment on the draft BAR, indicated that this classification is not considered applicable. The reason is

that Saldanha Flats Strandveld has not been classified as a critically endangered or endangered ecosystem in terms of the National Environmental Management: Biodiversity Act of 2004 (NEM:BA), List of Threatened Ecosystems in Need of Protection, December 2011),

2 Note that the proposed south-north road no longer triggers this listed activity as its length of 700 m is lower than the

threshold of 1 km.

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ii. Within critical biodiversity areas identified in bioregional plans

the latest Western Cape Biodiversity Spatial Plan (CapeNature, 2017).3

18. The widening of a road by more than 4 metres, or the lengthening of a road by more than 1 kilometre. (i) In Western Cape: ii. All areas outside urban areas: (aa) Areas containing indigenous vegetation

The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 5.5 m at the intersection point.

3. PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ. The SBIDZ was officially designated in October 2013. It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bays deep-water port, neighbouring industrial areas and undeveloped land in the area. The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015. The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development, which was authorised in terms of that process, is nearing completion. The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA. The Western Cape Government: Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area. This would ultimately include a designated freight route along the R45 from Saldanha to the N7, just north of Malmesbury. These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238. The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85/OP7645 (Port Road) Intersection. OP7654 would be upgraded to a Main Road. The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route, while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 (Port Road) as well as to other industries that may be developed in future. At its northern end, the proposed new south-north access road would link with the existing intersection of Gold and Platinum Streets. As such, it would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 as well as to other industries and businesses located along these streets outside of the designated SBIDZ area. A new road (referred to as Street 2) provides access from the Saldanha/Langebaan Road (MR559) to the security entrance to the SBIDZ along its eastern boundary. This road is in use following the completion of its intersection with MR599 in May 2017. The western end of the proposed new eastern access road and the southern end of the proposed new south-north access road would both intersect with the northern end of Street 2. Thus the proposed south-north road would in effect be an extension of Street 2. It should be noted that Street 2 was included in the original SBIDZ EIA and its development was authorised as part of that proposal. The 54 m wide road reserve at the intersection of Street 2 and the two new proposed access roads was already authorised in 2015 as part of the SBIDZ development. The anticipated effect on traffic flow on the local road network area can be described as follows: Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street. The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645. Traffic from Platinum Street and the SBIDZ would therefore flow to both MR559 and OP7645. As the new bridge crossing of MR559 that is

3 This listed activity was not initially included as no terrestrial or aquatic CBAs or ESAs were designated within the study area

when the draft BAR was compiled in March 2017. However, the Western Cape Biodiversity Spatial Plan, which became available in April 2017, includes CBAs which affect the western half of the proposed eastern access road alignment up to its intersection with Street 2.

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currently being constructed would cut off through traffic on Platinum Street, businesses to the west of the bridge would gain access to MR559 via the existing access point. Businesses to the east of the bridge would gain access to MR559 (Main Road) via the new Street 2, or via the proposed new eastern access road to OP7645. The proposed project would comprise the following project components: (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ. The road would be a two-lane asphalt surfaced road with surfaced shoulders. The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the natural ground level to reduce cutting into the natural calcrete. The typical road cross section would be 12.6 m, consisting of a 3.7 m lane in each direction with a 2 m surfaced shoulder and a 0.6 m unsurfaced road edge on each side. Provision would be made for a turning lane to the right at the Afrisam entrance, where the road cross section would increase to 16 m to accommodate the 3.4 m wide additional turning lane. Allowance would also be made for an entrance to the southern portion of Erf 1139 opposite the Afrisam entrance for future use. Three drainage culverts would be constructed to avoid ponding of water next to the proposed road, at km 0.05km; km 0.83; and km 1.10. The road would be located in a 30 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes. The construction of an intersection at the eastern end of the new access road would require the widening of OP7645. The existing road width of 11.6 m would be increased at the intersection to 15.5 m in order to accommodate a 3.4 m wide right turning lane. (2) Development of a south-north access road The proposed south-north access road would extend approximately 700 m along the eastern boundary of the SBIDZ from its (the SBIDZs) eastern entrance up to the existing intersection of Gold and Platinum Streets. The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road. A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other. The typical road cross section would be approximately 12 m, consisting of a 4 m lane in each direction with a 1.5 m sidewalk on the one side and a 2.4 m concrete lined side drain on the other. The road would typically be located in a 30 m wide road reserve, except at the southern end where the road would link to the 54 m wide reserve provided for the intersection at the SBIDZ eastern entrance. Allowance would also be made for an entrance to the west of the proposed new Afrisam cement factory for future use. A drainage culvert would be constructed at km 0.053. 4. AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139, on the coastal plain approximately 1.3 km from the shoreline, north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha. The property comprises open land, which has historically been used for agriculture (cultivation and grazing) but is now intended for industrial use. It is surrounded by roads and industrial plants. The proposed eastern access road would traverse the property from east to west, crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards. The ridge is a few metres higher in elevation than the surrounding lower-lying areas, which are approximately 20 m above mean sea level. The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ.

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The proposed eastern bypass road would pass through areas mapped in the Western Cape Biodiversity Spatial Plan (CapeNature, 2017) as a CBA1 and an ESA. The proposed northern bypass road would pass through an ESA. The area mapped as CBA1 contains Saldanha Limestone Strandveld which is considered of high conservation importance due to its original small extent. The area mapped as ESA contains a vulnerable vegetation type, Saldanha Flats Strandveld. The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld. The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEM:BA. The threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document4 and has thus been assessed as such. However, it should be noted that DEA&DP, in their comment on the draft BAR, indicated that as the vegetation occurring on the proposed site has not been classified as a critically endangered or endangered ecosystem in terms of the NEM:BA, List of Threatened Ecosystems in Need of Protection, December 2011, this classification is not considered applicable. The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing. The botanical sensitivity is regarded as very low apart from the presence of some geophytes. The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species. This vegetation is thus regarded as of high botanical sensitivity. There are no watercourses or aquatic ecosystems on site. 5. ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Tables 1 to 3. Table 1: Impacts during the construction phase (all impacts are negative unless stated otherwise)

Impact Significance without mitigation Significance with

mitigation Geographical and Physical Aspects NO IMPACT Biological Aspects: Vegetation Loss of vegetation and habitat low-lying areas Low VERY LOW Loss of vegetation and habitat limestone ridge High HIGH Socio-economic Aspects: Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust, noise and visual Low VERY LOW Cultural-historical Aspects: Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE)

Table 2: Impacts during the operational phase

Impact Significance without mitigation Significance with

mitigation Geographical and Physical Aspects NO IMPACT Biological Aspects: Vegetation NO IMPACT Socio-economic Aspects: Contribution to economic growth and development Low (Positive) LOW (POSITIVE)

Cultural-historical aspects NO IMPACT

4 Pence, Genevieve QK (2014). Western Cape Biodiversity Framework 2014 Status Update: Critical Biodiversity Areas of the

Western Cape. Unpublished CapeNature project report. Cape Town, South Africa.

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Table 3: Impacts associated with the No-Go Option

Impact Significance without mitigation Significance with

mitigation Transport infrastructure Low LOW Loss of vegetation and habitat limestone ridge NO IMPACT

The proposed new access roads, which would improve access to industrial sites in the SBIDZ and its immediate surrounds, would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5: Saldanha-Northern Cape Development Corridor project. As such, the proposed project would contribute to economic growth and development in the area, resulting in an impact of LOW (positive) significance. The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and economic development potential related to SIP5. The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance from a socio-economic perspective. In the low-lying areas along the proposed eastern access route the proposed mitigation measures would to some extent limit the biophysical impacts on the loss of Saldanha Limestone Strandveld and Saldanha Flats Strandveld VERY LOW significance with mitigation. However, the loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road has been rated as an impact of HIGH significance. This takes into account the recent selection of this area as a CBA1, assigning irreplaceable status to the vegetation. The only other negative impacts of the proposed project relate to noise, dust and visual impacts associated with construction phase activities. These have been rated as of VERY LOW significance after mitigation. It should be noted that the proposed south-north access road itself does not trigger any listed activity as such. The following discussion regarding the authorisation of the activity thus centres on the implications of the eastern access road as the project component that would require Environmental Authorisation for its implementation. The inherent conflict between the positive implications of the proposed eastern access road to provide access to the SBIDZ on the one hand, and the negative implications for the conservation of a CBA1 area on the other hand, is encapsulated in the inclusion of the site in the Conflict Areas dataset in the Draft EMF for the Greater Saldanha Area (April 2017). As the Draft EMF has not yet been adopted, its implications for local land use planning have not formally been taken into account in the Saldanha Bay Municipalitys development plans. Thus the formal status of the site remains designated for industrial use. Against this background, it is necessary to consider the broader context of the site. The fact is that the SBIDZ is being developed as a Strategic Infrastructure Project adjacent to the established Port of Saldanha. Associated with this is the upgrading of the provincial road network to support the broader industrial development in the area. The site is thus located in the midst of an industrial development area formally designated as such in the relevant local planning documents. Additionally the landowner of the site through which the proposed road would pass, Afrisam, already has approval for developing a cement plant on this site adjacent to the SBIDZ. A portion of the affected property site has very recently been designated as a CBA1 on the basis of the intact Saldanha Limestone Strandveld located on the limestone ridge, as well as a remnant of relatively intact Saldanha Flats Strandveld located in the south-western portion of the property. In the light of the above contradictory needs between development and conservation, a key question regarding the proposed road is to consider what is likely to happen in future. Thus it is necessary to consider the long-term

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viability of maintaining the sensitive vegetation at this particular location which is expected to be subject to substantial development pressure. It should be noted that an offset is not recommended in this case for the proposed eastern access road. The reason is that the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area. We are aware that DEA&DP has appointed a team to undertake an offset study for the Saldanha area. Our understanding is that this study should provide a basis for resolving the conundrum that faces the decision-making between development and conservation in the greater Saldanha area. Thus a viable approach to offset this CBA1 in an area not subject to similar development pressures may inform the decision regarding the proposed road. 6. RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project: Vegetation: Restrict construction activities to the construction zone. Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the eastern/north-

south access roads intersection and prohibit any movement of construction vehicles and workers in these areas.

Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas.

Locate, lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area, particularly Boophone haemanthoides and Brunsvigia orientalis.

Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint.

Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road.

Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction.

Employment: Local BEE services and providers and local labour from the local community should be employed as

far as possible. The appointed contractor must comply with the Proponents labour and procurement specifications. Ensure appropriate training is provided, where required. Compliance with environmental specifications listed in the Construction EMP The proposed project must comply with the environmental specifications listed in the Construction

EMP. Where appropriate, the proposed mitigation measures have been incorporated in the Construction EMP. Key mitigation includes: o Site demarcation; o No-go areas; o Palaeontological monitoring at cuttings; and o Rehabilitation of disturbed areas.

SLR Consulting (South Africa) (Pty) Ltd Page xi

SLR Ref. 720.19083.00005 Report No. 2

Proposed new access roads to the Saldanha Bay IDZ BAR and EMP June 2017

Figure 1: Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)

Proposed north-south access road

Proposed eastern access road

Trunk Road 85

Main Road 559 Minor Road 7645

Saldanha Bay Industrial Development Zone

Duferco

Future Afrisam cement plant

Proposed north-south access road

Proposed eastern access road

SLR CONTACT DETAILSTEL: (021) 461 1118/9 FAX: (021) 461 1120EMAIL: edevilliers@slrconsulting.comAppendices cover pages.pdfAPPENDIX B

Database_7 March17.pdf2 col (Organisation) & Name sort Org

Site Notice Rev 0 (16 Jan 2017) - final.pdfSLR CONTACT DETAILSTEL: (021) 461 1118/9 FAX: (021) 461 1120EMAIL: edevilliers@slrconsulting.com

Advert - new access roads (March 2017).pdfBASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE NOTICE NO: SEMC03AR 02/2017 DEA&DP REF NO. 16/3/3/1/F4/17/3011/17Application for Environmental Authorisation (EA) to undertake the following activities: The proposed project triggers Listed Activities in terms of the EIA Regulations, 2014 promulgated in terms of NEMA, namely: Government Notices (GN) R983 (Listing Notice 1): Activity 24; and R985 (Listing Notice 3): Activities 12 and 18. A Basic Assessment is required in order to apply for EA.Opportunity to participate: In accordance with the EIA Regulations (GN R982), you and/or your organisation are hereby invited to register as an Interested and Affected Party (I&AP) and comment on the Basic Assessment Report (BAR) for the proposed project. The BAR has been made available for a 30-day comment period from 10March to 10April 2017 (including an additional day to cover the intervening public holiday). Please contact SLR (at the contact details below) should you wish to register as an I&AP. Any comment should be submitted by no later than 10 April 2017.

Database_5June17.pdf2 col (Organisation) & Name sort Org

Advert - new access roads (March 2017).pdfBASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE NOTICE NO: SEMC03AR 02/2017 DEA&DP REF NO. 16/3/3/1/F4/17/3011/17Application for Environmental Authorisation (EA) to undertake the following activities: The proposed project triggers Listed Activities in terms of the EIA Regulations, 2014 promulgated in terms of NEMA, namely: Government Notices (GN) R983 (Listing Notice 1): Activity 24; and R985 (Listing Notice 3): Activities 12 and 18. A Basic Assessment is required in order to apply for EA.Opportunity to participate: In accordance with the EIA Regulations (GN R982), you and/or your organisation are hereby invited to register as an Interested and Affected Party (I&AP) and comment on the Basic Assessment Report (BAR) for the proposed project. The BAR has been made available for a 30-day comment period from 10March to 10April 2017 (including an additional day to cover the intervening public holiday). Please contact SLR (at the contact details below) should you wish to register as an I&AP. Any comment should be submitted by no later than 10 April 2017.

Draft BAR Comments and Response Report - Rev1 8 June 2017.pdfMETHOD AND DATESUBMITTED BYAUTHORITY COMMENTS AND ISSUESA.COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY1. Draft BAR Comments and Response Report - Rev1 8 June 2017 last edit.pdfMETHOD AND DATESUBMITTED BYAUTHORITY COMMENTS AND ISSUESA.COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY1.