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1 Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape Name Date received Comment Response Comments received on the Background Information Document Louis Duvenage Duvenage & De Villiers Attorneys 14 August 2014 Please register me as a I&AP. Noted and confirmed. Kearley’s Transport (Pty) Ltd 18 August 2014 Our telecom of even date refers. Writer acts on behalf of and on instruction of the above company. Writer wishes to place on record that the company wishes to register as an Interested and Affected Party for the project. The company is the title deed holder of erf 11435 which is adjacent to erf 34. The company will email a written comment on the bid in due course. Writer can be contacted at [email protected] . Noted and confirmed. Monique Geldenhuys 18 August 2014 We received your letter dated 15 August 2014 regarding the proposed waste recovery plant. Can you please tell me where (plot) you intend on putting up this plant? We have just move into the area and our facility will be FSSC22000 certified which very specifically stipulates that the environment may not in any way pose a contamination risk to our products. Preferred site alternative is a portion of Erf 34, alongside the current landfill site. Please refer to the Draft Scoping Report for site locality plans. Alternative sites have also been included in the Scoping Phase. Gerrit van Zyl Chairperson: Wellington SPCA 25 August 2014 Air pollution- smoke, dust, ash and soot. Noise pollution- heavy machinery and vehicles. Littering. Escalation in pests, such as rats and snakes. Impact of more traffic on the existing poor road. The following specialist studies will be undertaken during the EIA phase to ascertain the impact of the proposed facility: o Botanical Impact Assessment; o Noise Impact Assessment; o Health Risk Assessment; o Socio and Economic Impact Assessment; o Visual Impact Assessment; o Air Quality Impact Assessment; o Traffic Impact Assessment; o Archaeological and Heritage Impact Assessment; and o Major Hazard Installation Risk Assessment.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Background Information Document

Louis Duvenage Duvenage & De Villiers Attorneys

14 August 2014 Please register me as a I&AP. Noted and confirmed.

Kearley’s Transport (Pty) Ltd

18 August 2014 Our telecom of even date refers. Writer acts on behalf of and on instruction of the above company. Writer wishes to place on record that the company wishes to register as an Interested and Affected Party for the project. The company is the title deed holder of erf 11435 which is adjacent to erf 34. The company will email a written comment on the bid in due course. Writer can be contacted at [email protected].

Noted and confirmed.

Monique Geldenhuys 18 August 2014 We received your letter dated 15 August 2014 regarding the proposed waste recovery plant. Can you please tell me where (plot) you intend on putting up this plant? We have just move into the area and our facility will be FSSC22000 certified which very specifically stipulates that the environment may not in any way pose a contamination risk to our products.

Preferred site alternative is a portion of Erf 34, alongside the current landfill site. Please refer to the Draft Scoping Report for site locality plans. Alternative sites have also been included in the Scoping Phase.

Gerrit van Zyl Chairperson: Wellington SPCA

25 August 2014 Air pollution- smoke, dust, ash and soot. Noise pollution- heavy machinery and vehicles. Littering. Escalation in pests, such as rats and snakes. Impact of more traffic on the existing poor road.

The following specialist studies will be undertaken during the EIA phase to ascertain the impact of the proposed facility: o Botanical Impact Assessment; o Noise Impact Assessment; o Health Risk Assessment; o Socio and Economic Impact Assessment; o Visual Impact Assessment; o Air Quality Impact Assessment; o Traffic Impact Assessment; o Archaeological and Heritage Impact Assessment; and o Major Hazard Installation Risk Assessment.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Background Information Document

4. The Department hereby confirms the following: 4.1 This Department will be a commenting authority during the Scoping and Environmental Impact Assessment process. Future comments will be provided directly to the Department of Environmental Affairs (DEA) and copied to you.

Noted.

4.2 The Department awaits a hard copy of the draft Scoping Report and Plan of Study for the Environmental Impact Assessment for comment.

A hard copy of the Draft Scoping Report and PoS for EIA will be provided to the Department as part of the 40 day commenting period on said report.

5. You are required to quote the abovementioned reference number in any future correspondence in respect of this application to this Department.

Noted.

Environmental Affairs and Development Planning: Land Management Arabel McClelland

25 August 2014

6. The Department reserves the right to revise or withdraw comments or request further information based on any information received.

Noted.

Mr Craig Mitchell Wasteman

25 August 2014 Registered as an I&AP. Noted and confirmed

Jacques Blignaut Distell

27 August 2014 Registered as an I&AP. Noted and confirmed

Kabous Marra Pacmar (Pty) Ltd

27 August 2014 Please refer our herewith provided letter for comments. Secondly, also copy [email protected] on all communications.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Background Information Document

We object to the proposed Waste Recovery site and submit the following reasons therefore:

1. We had insufficient time to investigate this matter in order to provide substantial feedback. Receiving a notice/letter on 27th August with a request to submit our Registration and Comment Sheet by 29th August leaves very little, if any time, to fully investigate and evaluate the matter in order to provide substantial comment. Secondly, we’d not been aware of, and neither previously been advised that the “BID was available for comment from Thursday 7 August to Friday 29 August 2014 at the local library”. So again; insufficient notice and opportunity to investigate and comment.

1. The BID was distributed to neighbouring land occupiers and

owners via registered post on the 6 August and a letter drop was done to premises in the Wellington Industrial Park including the Pacmar facility on the 15 August. In addition the BID was also advertised in one (1) local newspaper (PaarlPost) and one (1) regional newspaper (Die Burger).

2. The Northern border of both the proposed sites is far too close to the Business Park. It is highly likely that the volume of waste being re-worked so close to the Business Park; will over time result in a very substantial increase in the prevalence of flies and other insects. It is furthermore very likely that these could spill over into nearby residential areas which will result in very unpleasant living conditions.

2. The facility will be mainly enclosed and should not result in any increase in nuisance (i.e. flies, odours etc) than is already prevalent in the area due to the existing landfill and sewage treatment facilities. The facility may in fact reduce nuisance in the area as waste will be managed in a more structured and beneficial manner. The following specialist studies will be undertaken during the EIA phase to ascertain the impact of the proposed facility: o Botanical Impact Assessment; o Noise Impact Assessment; o Health Risk Assessment; o Socio and Economic Impact Assessment; o Visual Impact Assessment; o Air Quality Impact Assessment; o Traffic Impact Assessment; o Archaeological and Heritage Impact Assessment; and o Major Hazard Installation Risk Assessment.

Pacmar (Pty) Ltd 27 August 2014

3. What about rats and mice? It is our contention that the site/facility could give rise to a substantial increase in the rodent population. We are very concerned that there will be a “spill-over/increase” of rodents into the Business Park and nearby residential areas with the accompanying possibility of diseases being spread.

3. Effective pest control will have to be implemented as part of operational management requirements for the proposed facility.

It is important to highlight that the proposed activities are significantly different to a landfill operation.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Background Information Document

4. The current landfill and existing re-working sites already and periodically generate very unpleasant odours that could be smelled for anything up to 3 to 5 kilometres. The proposed Recovery Plant/Site will simply give rise to a far more “concentrated foul smell” that will be pervasive over a much greater area. Most unpleasant for those working in the Business Park and nearby residential areas.

4. As per Nr 2 above, the facility will be mainly enclosed and should not result in any increase in nuisance (i.e. flies, odours etc) then is already prevalent in the area due to the existing landfill and sewage treatment facilities. The facility may in fact reduce nuisance in the area as waste will be managed in a more structured and beneficial manner. A Cumulative Air Quality Impact Assessment will be undertaken. The Cumulative study will include the wastewater treatment works, landfill site and proposed new waste management, recovery and beneficiation activities. The study will also include an odour component.

5. We also contend that the close proximity of the site to the Business Park will detract from the “attractiveness” of the Park regarding future development and extension, not to mention a reduction in land and property values.

5. A Socio-Economic Impact Assessment will be undertaken as part of the EIA phase of the assessment.

6. Pacmar and Fruition, being “food factories”, are very concerned about airborne diseases that could emanate from such a “Recovery” operation/site. We have it on good authority that other food factories located in the industrial Park are equally concerned.

6. A Cumulative Air Quality Impact Assessment and Health Risk Assessment will be undertaken as part of the EIA phase of the assessment.

7. We need further information and commitments regarding the safeguards that could be build into such a Recovery Plant/Site before we could even begin to consider our support thereof. Until then, we will continue to object thereto. Attached please find our duly completed “Registration and Comment Sheet”.

7. Comments noted and more information will be made available as the application and project process progresses.

Fritz Brink 27 August 2014 We refer to the below email of 27th August from “mailbag@fcbgroup”, under cover of which a copy of the “BID” document and your notice of 7th August was forwarded to us.

Attached please find our completed “Registration and Comment Sheet” as well as our formal letter of even date. Kindly record us as an Interested Party so we will receive future feedback & notices. Please ensure that you forward future communications to both Mr. Kabous Marra ([email protected]) and Fritz Brink ([email protected]).

We look forward to attend a forthcoming meeting with affected property owners.

Noted and confirmed.

5

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Background Information Document

2. From an environmental health point of view the development of facilities to minimize and recycle waste is supported. Therefore there is no objection to the proposed establishment of a waste recovery, beneficiation and energy project facilities in Wellington on condition that the establishment and operation of these facilities comply with the following requirements:

Comments noted.

2.1 No nuisance (noise, dust, odours, etc), no pollution of any water sources or the environment and no health hazards may occur during the construction phase and also during the daily operation of the facilities thereafter.

The following specialist studies will be undertaken during the EIA phase to ascertain the impact of the proposed facility and to suggest mitigation to prevent any negative impacts: o Botanical Impact Assessment; o Noise Impact Assessment; o Health Risk Assessment; o Socio and Economic Impact Assessment; o Visual Impact Assessment; o Cumulative Air Quality Impact Assessment; o Traffic Impact Assessment; o Archaeological and Heritage Impact Assessment; and o Major Hazard Installation Risk Assessment.

2.2 The proposed mitigation of potential impacts, as described in the Basic assessment report, must be strictly adhered to.

Noted.

Western Cape Government: Health Mr G.J. Olivier

29 August 2014

2.3 Any further requirements of the applicable Municipal Health Services authority (Cape Winelands District Municipality: Environmental Health section) must be adhered to.

Noted.

Mrs Sharlize van Schalkwyk

05 September 2014 As discussed at the SEA meeting on 04.09.2014. Please register VS Tech on the Database as a I&AP.

I will forward my comments asap.

Noted and confirmed.

Emily Herschell Worley Parsons

08 September 2014 Please could you register me as an I&AP for the Waste to Energy project? Noted and confirmed.

Mr. Bernard Joubert Boland Bins

16 September 2014

Not against project in principle, but concerned with regards to traffic. Especially dirt roads condition and the dangerous turn off from the main road. Also mentioned plastics blowing into property from current landfill.

A Traffic Impact Assessment will be undertaken in the EIA phase of the application.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

Frikkie 27 November 2014 Dear Larry

Having read your “Draft Scoping Report” the following concerns and comments as an adjacent property owner of Erf 743:

“decision to include Site Alternative 3 as a further site locality alternative in the process was taken on completion of the BID process” : some more info on how this decision was taken and implemented seeing that it was done after a BID process?

Notification via registered and electronic mail to neighbouring landowners and stakeholders on preliminary stakeholder database Week of 17 November 2014: none received and being part of the SEA that started in 2013 surely we must be named on the preliminary data base but none the less as adjacent property owners we are definitely due a notification.

Off the cuff why was this particular 6 ha portion of Erf 743 chosen – there is already a waste water treatment plant with an adjacent electricity substation on the Southern part of named property with available land use of another 40 ha for similar operations (other side of the N1) which will suite your clients requirements far better if your intention to generate electricity and linking into the grid is a vital part of your proposal. This section is also adjacent to a tarred road with much easier access – the trucks and increased traffic on the Protea Graval road will surely hamper your scoping on air quality due to the increase in dust.

On the Northern border of the property there is an adjacent land owner with a waste authorisation linked to his property (Omega fertilisers currently operate form the site and if my understanding is correct it operated as a waste facility in the past) – would it not be a more logical option to look to as an alternative?

Your feedback will be greatly appreciated.

Email communication at the time Dear Frikkie Thanks for the queries and valued input. Registered letters were sent to all adjacent landowners – possibly the letter is “stuck” in the system. These letters were circulated last week already. We have added at least a week onto the legislated EIA process time frames in case there are still some postal delays. Responses to your queries will follow as per the normal EIA process i.e. the Final Scoping Report will include a Comments and Response section within which all comments will be addressed (please see response to communication dated 28 November 2014 in next section). It is important to take note that this is a Drakenstein municipal project and therefore the identification of alternative sites would have focused on sites within the Drakenstein Municipal boundaries. NB: Public Open day: Thursday 22 January 2015 at Windmeul Cellar, 17h30 to 19h30. This also serves as an opportunity to discuss your queries in more detail.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

Frikkie 28 November 2014 Given that answers will only be forthcoming around the 22nd of January I just want to try and obtain some clarity or at least provide my view on the “jurisdictions” applicable to ERF743 given your response that only alternative sites within Drakenstein Municipal boundaries were considered. As far as I am aware Drakenstein municipality is the title holder of

the whole ERF 743 even though a portion falls within the Stellenbosch boundary. All past decisions relating to the Erf that is on the other side of the N1 e.g. the Capetainer depot application etc. were dealt with by Drakenstein municipality thus making them the authority on granting of rights on this section of land.

There is a substantial solid waste removal infrastructure, a water waste treatment facility and a power substation less than 2 km from your identified alternative with a lot more available for expansion. A site which will suite your clients project far better, there will be less visual impacts etc. Your current alternative is in the middle of a rural agricultural community with a lot of negatives.

Even if there is a dispute as to the jurisdiction of said portion of Erf 743 between Drakenstein and Stellenbosch then surely it will be short sighted not to do a co-operative venture between the two as Stellenbosch will be facing a similar problem in years to come? The spin offs will be job creation for a poor community such as Klapmuts with a dire need for infrastructural development of this nature.

My concern as a ratepayer has further bearing in that Mandated officials are not applying their minds when alternatives are identified and evaluated – you don’t have to be an EIA expert to realise that the site is far from ideal for the intended use and that there must be a myriad of more suitable sites and alternatives

Email communication at the time – selected changes to avoid confusion. Thanks for comments and definitely a number of issues have been raised which need to be evaluated and responded to as we move forward with this project. Comment noted. The Project Team is aware of the expected advantages specific to Site alternatives 1 and 2 in comparison to Site Alternative 3 and these advantages subject to a review of the facts and information available will be taken into account in preparing the site screening and ranking report in the Assesment Phase of the project. This site alternative screening and ranking assessment will be presented in the Draft Environmental Impact Report (DEIR). The methodology to be used for the site screening and assessment is presented in the Final Scoping Report under Section 3, Tables 3, 4 and 5. The Drakenstein – Interwaste contract requires a site to be identified and established within the Drakenstein municipal area. The regional co-operation that may still develop between Drakenstein and Stellenbosch can be of value for the overall project. Comment noted. It is possible that there are other “agricultural type” alternative sites probably very similar to the proposed area on Erf 743, Alternative 3 within the Drakenstein municipal area.

8

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

within the Drakenstein boundary – Reliance being one example which has a site in close proximity ideal for such a venture/joint venture. During the SEA process and the impact assessments done by Withers Enviro on the exact portion of land by the same municipality the stance was to try and retain the character of the area by keeping it as “GREEN” as possible – the current evaluation being a total opposite.

These are subjective views and I understand there is a greater community to be served so it will be good to get further insights in due course.

Reliance site. It is assumed that reference is being made to the Okran EIA – Proposed Organic Recycling Facility on Farm Corona or alternatively the Olyphantsfontein compost facility.. This portion of property actually falls on the edge of the City of Cape Town municipal boundary and therefore is outside the Drakenstein municipal area. It is an EIA process that is focusing on some different aspects when compared to the Interwaste EIA process. The Strategic Environmental Assessment (SEA) process that was managed by Sivest did make reference to and recommend that the rural – farming nature of the area be maintained. These recommendations were not ignored when including Erf 734. Erf 734 was included due to the fact that consultation with Drakenstein town planning officials confirmed that the recommendations made as part of the SEA process and in the SEA report were not necessarily supported or adopted by Council as yet and that there was still some discussion required as to whether the property could also accommodate developments of a commercial nature. This feedback then confirmed that there was no specific reason based on the information at hand why the site could not be included in the process.

My sentiments regarding this proposal echo those submitted to recent proposals put forward regarding Oliphantsfonteyn in the Paardeberg and Corona farm in the Durbanville district ….

Comment noted. Bridget Johnsen 01 December 2014

PSI, the community it represents and Bridget Johnsen in her personal capacity, will not be participating in this PPP process. Our experience has demonstrated that RMS, as EAP, has not presented or approached facts objectively in the past, nor assisted in upholding the conditions of authorisation. Our history of involvement with waste disposal involving the City of Cape Town and Reliance Compost over the past 10 years demonstrates very clearly a corrupted system, in which we, the public, have had to spend well over R500 000 in hard-earned cash and our precious time submitting inputs, complaints, reports, etc only to have them variably …. flagrantly disregarded, glossed over, but most seriously,

Comments are noted and recorded as being generally irrelevant to the project. Comments made are of a defamatory nature and lack any factual relevance or substance. Comments have been made following the rejection of an appeal on a separate project where RMS was involved by the Provincial Environmental Minister.

9

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

misrepresented. This while the applicant (Reliance) has been earning in excess of R24M p/a of good ratepayers money in many activities breaching applicable legislation or their conditions of operation/authorisation!! I have no desire to waste my time giving inputs now to Drakenstein Municipality in this regard, and especially so when RMS is the appointed EAP.

It is important to highlight that Environmental consultants are not responsible for matters pertaining to enforcement of environmental authorizations or licences.

As well as reams of inputs into all relevant processes and procedures, I submitted in this regard the sentiments of a severely affected community and of businesses unfairly prejudiced, to last year’s Parliamentary Portfolio committee hearings on why EIA’s are failing the public. I am not prepared to sacrifice any more holidays and valuable time with my family, projects and PSI Non Profit Company business assisting this proposal in another “tick-box” exercise. Again, RMS have cleverly released this for inputs just when all of us mere citizens commence our leave periods.

Good luck….I will look for the inclusion of this letter being included prominently as my only submission as I&AP in this PPP. I cannot afford to spend any more time or effort in this negative energy space.

Comments not project related.

Karen Starke 01 December 2014 With regard to your letter and supporting documents sent to The EJ Starke Will Trust, please could you email these same documents to: Mr L Starke at [email protected] as well as Mr J Armitage at [email protected]. Please could you also register them as I&AP’s for this project. Please do not use this email address for any documentation sent to me. To confirm my address: 24A Highway, Fish Hoek 7975

Recorded response to query. “Dear Trustees

Please find attached a copy of the correspondence sent via registered mail.

Confirmation that you have also been included on the project database as registered stakeholders”.

NERSA 10 December 2014 The National Energy Regulator acknowledges receipt of a draft scoping report of an environmental assessment process. The draft scoping report is for the proposed Waste Recovery, Beneficiation & Energy Project, Drakenstein Municipality, Western Cape.

Comment noted

10

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

Kindly note that the National Energy Regulator is not involved in the application process of the Environmental Authorisation and does not comment on environmental documents of the prospective applicants. However, the Environmental Authorisation Record of Decision (ROD) will form part of documents to be submitted when applying for a generation licence. The Environmental Authorisation RoD will also form part of the generation licence conditions, if the generation licence application is approved.

1. In general, CapeNature supports projects that will reduce waste and the need for additional landfills and landfill expansions provided that projects are appropriately sited and do not impact on threatened vegetation or aquatic ecosystems and do not produce unacceptable air pollution.

Comment noted.

2. Site alternatives 1 and 2 on Erf 34 as well as Site alternative 3 on Erf 736 are all located in areas historically covered by Critically Endangered vegetation types – namely Swartland Alluvium Fynbos on Erf 34 and Swartland Granite Renosterveld on Erf 736. However, the proposed development site alternatives have already been largely transformed.

Comment noted. Level of site transformation to be elaborated on during assessment phase of the project.

3. CapeNature is of the opinion that the site alternatives on Erf 34 should be considered as preferred as the sites have little/no natural vegetation remaining and are close to other existing compatible landuses, namely a landfill and sewage treatment plant. When compared to the site on Erf 736, the sites on Erf 34 are also further away from a river and appear to have less potential to impact on groundwater used by farms.

Comment noted. The three (3) alternative candidate sites will be subjected to a screening process taking, environmental, social, financial and technical aspects into account. The screening and ranking process will provide an indication as to which of the alternative sites should be considered further in the impact assessment phase of the project. Refer to Section 3 of the Final Scoping Report. The Screening and Ranking process will confirm which of the three (3) sites will be included in the specialist assessment phase of the project.

4. CapeNature supports the way forward, especially the inclusion of a botanical constraints analysis, air quality impact assessment and hazard assessment. If the site on Erf 736 is put forward to the EIA phase, more information on potential groundwater impacts must be provided.

Comment noted and agreed. Refer to above comment.

CapeNature 18 December 2014

CapeNature will comment again once the EIR and associated specialist studies have been provided.

Comment noted.

11

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

We acknowledge receipt of your letter of 25 November 2014 addressed to our client, County Fair, a division of Astral Operations Limited, care of ourselves under cover of which you kindly forwarded to us a copy of the Draft Scoping Report (DSR) for the above project. In what follows, we submit our client’s comments on the DSR.

As you are aware, we, on our client’s behalf, commented on the Klapmuts North Strategic Environmental Assessment (SEA) which was commissioned by the Drakenstein Municipality. In commenting on the Klapmuts North SEA, we advised the environmental consultants of the various poultry farms which our client operated in the area both within the study area and adjacent to it. We note from the DSR that a third alternative site (which is a portion of a property included in the study area) was included after the public participation on the Background Information Document (BID) had run its course. We understand that this was done at the request of the Municipality.

The inclusion of the third site alternative was based on the request from the Drakenstein Municipality and the Stellenbosch Municipality which in summary required further alternatives to be considered and in the case of Stellenbosch Municipality potential sites located closer to the Stellenbosch municipal boundary.

ENSafrica

15 January 2015

Our client has no difficulty with the preferred alternative site (Alternative 1) nor with Alternative 2 as depicted in Figure 1 to the DSR. Indeed, site Alternative 1 is located adjacent to the existing Wellington landfill site and according to your description of the site, it has been “highly degraded and little to no vegetation remains”. In addition, site Alternative 2 is located where the current Drakenstein Municipality green waste and builders rubble facilities are located with the Municipality’s Waste Water Treatment Works located to the west and the landfill site to the south. Your DSR also mentions that this alternative is located within the Proposed Eco-corridor for the Wellington Industrial Park to the south of the site. Having regard to the nature of the activities at the proposed facility, these sites are, in our respective view, far more suitable from an environmental point of view than site Alternative 3. On the contrary, and for the reasons that follow, our client considers site Alternative 3 wholly inappropriate and in fact objects to it being sited there.

Comment noted. The three (3) candidate sites will be subjected to a screening process taking, environmental, social, financial and technical aspects into account. It has been decided to complete this alternative site screening and ranking process as part of the initial assessment phase of the project and not during the Scoping Phase.

The screening and ranking process will provide an indication as to which of the alternative sites should be considered further in the impact assessment phase of the project. Refer to Section 3, Tables 3, 4 and 5 of the Final Scoping Report.

The listed comments made with respect to the view as to which of the alternative sites should be the more preferred alternative are noted. Currently the alternative site (site Alternative 1) neighbouring the landfill site is reflected as the preferred site in the Final Scoping Report. The Alternative Site Screening and Ranking process to be completed will confirm or dispute this viewpoint.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

Our client’s concerns relate to Alternative 3 which is depicted on Figure 2 to the DSR and will occupy approximately 6 hectares of Erf 786 just to the north of the Protea gravel road.

Because the BID process dealt with Alternatives 1 and 2, there was no need for our client to register as an Interested and Affected Party (I&AP) nor to participate in any way in regard to those sites. Because site Alternative 3 has now been included in the DSR, kindly register our client as and I&AP and confirm to us that this has been done.

Request for registration noted and confirmed.

Our client’s concerns are thus addressed towards site Alternative 3. As you will see from Figure 2 to the DSR, two of our client’s broiler farms are visible to the west of the proposed Alternative 3 site. The one nearest the N1 is the larger of the two and is known as Bonanza and it houses 11 chicken houses housing 277,300 broilers per cycle. There are 8.1 cycles per annum. The farm thus produces 2,246,130 broilers per annum. To the north thereof is a smaller broiler farm known as Linwood and it houses 10 chicken houses housing 249,600 broilers per cycle. There are 8.1 cycles per annum. The farm thus produces 2,021,760 broilers per annum.

Just to the west of Linwood but not visible on Figure 2 is a further broiler farm known as Protea. It houses 10 chicken houses housing 300,000 broilers per cycle. There are 8.1 cycles per annum. The farm thus produces 2,430,000 broilers per annum. Just above the word “South” and to the east of the R44 which can be seen on Figures 2 and 19 to the DSR, is Erf 786/9. On this property, our client conducts a broiler farm known as Klapmuts Broilers and it houses 14 chicken houses housing 224,000 broilers per cycle. There are 8.1 cycles per annum. The farm thus produces 1,814,400 broilers per annum.

Extent of County Fair operations in the area noted.

13

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

We are unable to gauge the distances between our client’s abovementioned farms and the proposed location of site Alternative 3. We note that in paragraph 2.1.2 on page 19 of the DSR under the heading “Surrounding Land Use” that you record that the “distance from the County Fair operations (to the proposed site) exceeds 1,000m”. While this distance is noted, having regard to the nature of the proposed Materials Recovery Facility (“proposed facility”) and the various activities to be conducted thereon, our client is concerned whether this distance will be sufficient. This is particularly so when one considers the fact that bacteria can be transported through the air over distances in excess of 1,000 m and this can pose serious threats to our client’s operations.

It is standard practice for operations and projects of this nature to complete an air quality impact assessment on the selected site alternatives which will confirm the suitability of a particular site location in relation to the surrounding land uses.

Our client’s concerns: 1. The proposed site Alternative 3 is in an agricultural area. Our client developed its infrastructure in this area because of the agricultural/rural nature of the area, its relative underdevelopment and its close proximity to the greater Cape Town urban area. Our client tends to develop its operations in remote areas where urban development is not anticipated.

Comment noted. The relevant comments listed 1-7 below are important with respect to the sensitivity of the current land-uses surrounding site alternative 3 and would inform all specialist studies should alternative 3 be selected for further assessment after conclusion of the site screening and ranking process.

2. Our client’s operations are wholly reliant on an isolated and sanitized environment. As described above, our client’s farming activities in proximity to Erf 786 include laying and broiler farms. Each of these different farming activities require stringent bio-security measures, the details of which are set out below, and each of these different farming activities are spread out from each other again for reasons of bio-security.

Comment noted.

3. On the laying farms, the stocks used in breeding cycles are highly susceptible to disease. The proximity of the proposed facility may compromise our client’s bio-security in that it will increase the risk of disease transmission to a level which could be commercially destructive to our client.

Comment noted.

14

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

4. By way of illustration, should a single laying hen die, our client would lose 40 weeks of production which would have significant impact. In terms of our client’s processes, the laying stock commences laying fertilized eggs after approximately two weeks and will continue laying fertilized eggs from week 23 up until week 62, after which they are slaughtered.

Comment noted.

5. The fertilized eggs are then delivered to our client’s hatchery. The eggs are hatched 21 days later, and the day-old chicks are delivered to the broiler farms.

Comment noted.

6. Once the chickens reach slaughter age, they are delivered to our client’s abattoir and processing facility which produces both fresh and frozen poultry products. 1.6 Million chickens are processed at our client’s abattoir and processing facility every week. This facility is situated approximately 13 kms away from Klapmuts on the R304 south of the Fisantekraal Airfield.

Comment noted.

7. The broiler chicks are housed on our client’s broiler farms in the area and if the farms should be affected by disease and wiped out simultaneously, the farms would effectively

Comment noted.

Risk of disease to our client’s laying and broiler stock:

8. Any development which will bring increased human activities into close proximity with our client’s farms will have a drastic health impact on our client’s operations and bio-security. This would include the development of housing and industry. However, the proposed facility, and the waste management processes described in the DSR, are even worse and have the potential to seriously compromise our client’s bio-security.

The necessary risk assessments would need to be completed if Site Alternative 3 was eventually included in the specialist assessment phase of the EIA process. Relevant to all points up to 9.3.5.

9. The areas which are of utmost concern to tour client may be grouped as follows: 9.1The types of poultry diseases: 9.1.1 The diseases which are of concern to County Fair may be group as follows: “Bacterial viral, mycoplasma, internal and external parasites”

Comment noted.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

9.1.2 These diseases are further grouped as follows: Bacterial - Salmonella

- Haemophiles (Coryza) - Ornitho bacterium rhinotracheitis - Pasterella

Viral diseases – Newcastle disease - Infectious bronchitis - Egg Drop Syndrome - Infectious laringotracheitis - Infectious Bursal Disease - Marek’s Disease - Fowl Pox - Avain Encephalitis - Reo Virus - Pneumovirus - Chicken infectious Anaemia Virus - Avian influenza

External Parasites – Red Mite - Northern Fowl Mite - Lice - Fleas

Internal Parasites – Coccidiosis - Worms

Mycoplasma – Mycoplasma gallisepticum - Mycoplasma synoviae

9.13 The most common dangerous diseases are salmonella infection, Newcastle disease, mycoplasma infection and Avian influenza.

Comment noted.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

9.1.3.1 Salmonella infection: Salmonella is prevalent in rats and other animals, birds and

humans. Salmonella is carried by rats, wild birds, humans and

contaminated feed or water. Salmonella bacteria can kill 10-60% of susceptible chickens Chickens infected with salmonella remain carriers of the

infection and hence the only means of stopping transmission thereof is to slaughter the infected flock.

Chickens which survive salmonella can remain infected and pass on the disease to consumers.

Two types of salmonella have been known to cause death by human consumption of infected poultry.

Newcastle disease:

Newcastle disease is prevalent in wild birds and poultry. It is carried by wild birds, domesticated birds and vectors such as human flies, insects windborne dust, etc.

Newcastle disease constitutes the most dangerous threat to poultry production in South Africa.

The virus can cause 100% mortality and significantly reduces growth in surviving birds.

Vaccinated birds that survived Newcastle disease frequently remain infected for weeks after recovery and constitute and uncontrollable source of infection which can result in an epidemic.

Once infected, a poultry farmer would be required to slaughter his entire stock.

Comment noted.

Mycoplasma infection:

Mycoplasma infection is prevalent in avian species and carried most commonly by wild birds, poultry or rats, windborne and humans/vehicles as vectors.

Comment noted.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

Mycoplasma infection is chronic erosive disease. Mycoplasma can only be treated by eradicating the broiler

stock. Mycoplasma infection is transmitted vertically, so a hen can

pass on the infection to her eggs and thereafter to the hatching chicks.

Mycoplasma can only be treated by eradicating the breeding stock, and this will require months or years to eliminate its effect on breeding stock.

9.2 The threat of disease:

9.2.1 The laying and broiler stocks on our client’s farms are extremely susceptible to disease and infection. Increased sensitivity regarding disease and infection amongst birds and poultry has in fact become a worldwide phenomenon.

9.2.2 Due to the fact that the destruction of stock could result in the loss of our client’s entire chain of production, it is essential that strict measures are enforced to isolate laying as well as broiler stocks from disease.

Comment noted.

9.3 Mandatory bio-security plan:

9.3.1 In light of the susceptibility of the broiler chicken stock to disease and their paramount importance to our client’s operations, our client complies with a stringent bio-security plan to isolate its stock from disease. The two key elements of the bio-security plan are:

9.3.1.1 The distance between its various farms, and between the chicken houses themselves on the farms, and any source of infection; and

9.3.1.2 The human-entry procedures.

Comment noted.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

9.3.2 In terms of the human-entry procedures, no one is allowed on site without having had multiple showers and changes of clothing. All staff change into a first set of protective clothing in an interim change room, approximately 100-150 metres fro the site, leaving all personal clothing and effects behind. Thereafter, they proceed to the shower with soap and shampoo and change into a second set of protective clothing before entering the sites.

9.3.3 All vehicular access is strictly controlled and all vehicles are sprayed with disinfectants before entry onto the sites. Moreover, all equipment is disinfected before being brought onto the site. Electronic equipment that cannot be washed is fumigated for 30 minutes in a sealed container before being taken onto site.

9.3.4 It is vital that a mandatory distance be maintained between the various chicken farms and any source of infection, as many poultry diseases are carried by birds, flies, by the wind, and in the case of the development, by the influx of humans and their pets. By its very nature, development of housing and industrial parks can cause significant impacts which will be exacerbated by litter, waste, sewerage, water use etc. Any airborne molecules, including dust, water, fog etc are a potential carrier of disease. Dust particles attach to these molecules and are thereafter spread by the wind which vectors the disease-laden carrier onto our client’s sites.

9.3.5 For this reason, the various chicken farms are located in the most remote places possible.

Comment noted. Comment noted. Comment noted. Comment noted.

10. The proposed facility will bring a high level of activity very close to our client’s identified farms. Such activity would include increased volumes of vehicular movement with the attendant increase in the vectoring of waste matter and diseases onto our client’s farms. In addition, the description of the activities to be undertaken as set out in pages 5, 6 and 7 of the DSR, are so anathema to our client’s stringent bio-security that our client questions whether the distance of

The necessary risk assessments would need to be completed if Site Alternative 3 was eventually included in the specialist assessment phase of the EIA process.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

1,000m is adequate or not. A full Animal Health Impact Assessment by a recognised expert in the field would need to be procured by the proponent in order to address our client’s concerns. 11. Human activity in close proximity to the farms would increase significantly as would the presence of wild birds of which are potential carriers of fatal diseases. Should the proposed facility be implemented, our client would lose the protection afforded to it by the remoteness of its various farms and upon which it relies for its commercial viability.

The necessary risk assessments would need to be completed if Site Alternative 3 was eventually included in the specialist assessment phase of the EIA process.

Water:

12. Water quality at our client’s farms has a direct bearing on the continued existence of our client’s poultry operations. The norms necessary to sustain such operations are adversely affected by exposing poultry to water that does not conform to the target water quality ranges for specific water quality constituents.

The necessary risk and environmental assessments inclusive of ground water and surface water would need to be completed if Site Alternative 3 was eventually included in the specialist assessment phase of the EIA process.

13. Our client, as poultry farmers, is considered to be a sensitive water user group within a sensitive environment, and as such, stricter water quality guidelines are applicable to its poultry farming operations.

The necessary risk and environmental assessments inclusive of ground water and surface water would need to be completed if Site Alternative 3 was eventually included in the specialist assessment phase of the EIA process.

14. In order to conduct its operations at its various farms identified above, in addition to the water that is required for production and domestic uses, our client requires approximately 600 kilolitres of water per day. At no time can the chickens be allowed to experience an absence of drinking and cooling water. Moreover, it is a prerequisite that the water quality not fluctuate over time so as to alter the mineral nutrition required by the chickens.

The necessary risk and environmental assessments inclusive of ground water and surface water would need to be completed if Site Alternative 3 was eventually included in the specialist assessment phase of the EIA process.

15. Our client currently utilizes water which is sourced from boreholes on its various farms and, in the case of its farm Anysrug (which is not affected by site Alternative 3, but which was dealt with in the context of the Klapmuts North SEA), the borehole supply is supplemented to a limited extent from the Municipality but the quality of the supplementary water is often of a poorer quality than the borehole water in that the supplementary water supply is untreated water. It is

The necessary risk and environmental assessments inclusive of ground water and surface water would need to be completed if Site Alternative 3 was eventually included in the specialist assessment phase of the EIA process.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

therefore important that the natural water resources which our client currently enjoys continue to be of excellent quality and quantity. 16. Our client is therefore concerned about the potential negative impacts which the proposed facility could have on their existing water resources, both in terms of quantity and quality. More particularly, our client is concerned that the use of water by the proposed facility and the potential for the waste water to contaminate the groundwater upon which it is so reliant, will constitute and additional factor increasing the risk of disease transmission and may limit the general water use in the area.

The necessary risk and environmental assessments inclusive of ground water and surface water would need to be completed if Site Alternative 3 was eventually included in the specialist assessment phase of the EIA process.

17. The adverse effects which could be occasioned by the proposed facility using the water resources currently enjoyed by our client will be costly to mitigate and may be irreversible. Moreover, many of the adverse effects may take time to develop before being discernible. They may present sub-clinical problems and they may follow a chronic route.

The necessary risk and environmental assessments inclusive of ground water and surface water would need to be completed if Site Alternative 3 was eventually included in the specialist assessment phase of the EIA process.

18. Accordingly, our client requires a full Groundwater Impact Study to be performed and not merely a Freshwater Constraints Assessment as is being proposed in the DSR.

Comment noted. The level of groundwater study necessary would depend on the current information available and the proposed design of any waste treatment facility proposed.

Deterioration of the environment:

19. In addition to what we have set out above, the proposed facility will prejudice the surrounding environment. It might affect the roads infrastructure by the significant increase in the number of vehicles in the vicinity. A further impact might result from the air and noise pollution, which also affects our client’s chickens.

Traffic and Air Quality Impact Assessments would need to be completed irrespective of which alternative sites are included in the Specialist studies to be completed.

20. There is also a possibility of pollution of the ground by the leakage of oils, fuels and other substances. Such ground pollution may seep into the ground water and contaminate the water sources available to our client and its chicken farms.

The necessary risk and environmental assessments inclusive of ground water and surface water would need to be completed if Site Alternative 3 was eventually included in the specialist assessment phase of the EIA process.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

Financial consequences:

21. The financial consequences of an outbreak of disease on our client’s farms could be crippling. Due to the fact that stock cannot be replaced immediately, as a result of natural cycles, financial losses could amount to several millions of Rands.

The necessary risk and environmental assessments inclusive of ground water and surface water would need to be completed if Site Alternative 3 was eventually included in the specialist assessment phase of the EIA process.

Comments on the DSR:

22. Reference is made in your description of the anaerobic digestion plant to the fact that alternative organic waste streams such as winery waste, condemned food, etc., as well as sewerage sludge from the Paarl Waste Water Treatment Works will be used in relation to this plant. Our client is most concerned with the vagueness of the expression “condemned food”. Because of our client’s aforestated bio-security concerns, it needs to know precisely what this expression will comprise. Will it, for example, include dead animal carcasses, abattoir waste, and the like and if so, in what quantities?

For interest the waste stream can include abattoir waste. There is a significant sensitivity concerning the receipt of condemned animal waste and this aspect would need to be assessed during the specialist phase of the process. Generally condemned animal waste would not be received.

The necessary risk and environmental assessments inclusive of ground water and surface water would need to be completed if Site Alternative 3 was eventually included in the specialist assessment phase of the EIA process.

23. Our client is also concerned with what the nature of the air emissions will be from the direct combustion plant and we assume that more detail will become available once the Air Quality Impact Assessment has been received. Our client’s rights to deal further with this aspect are reserved until after we have received the Draft EIA Report.

Correct – A detailed Air Quality Impact Assessment will need to be completed on those alternative sites selected for further consideration and evaluation.

24. In regard to site Alternative 3, our client considers the absence of a full Groundwater Impact Assessment Report in the list of expert studies to be obtained to constitute a major flaw in the DSR. Our client’s reliance on groundwater is a major concern which needs to be adequately addressed and the Freshwater Constraints Assessment which is envisaged is in our view inadequate for this purpose. Once again, our client’s rights in this regard are expressly reserved.

The necessary risk and environmental assessments inclusive of ground water and surface water would need to be completed if Site Alternative 3 was eventually included in the specialist assessment phase of the EIA process.

25. We do not intend at this stage commenting on the policy and planning framework section of the DSR and fully reserve our client’s rights to deal expressly therewith in due course when commenting on the Draft EIA Report. We do, however, note that the emphasis in

Comment noted. ENS will be continually informed and updated of the project progress.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

regard to the policy and planning framework that you intend taking into account, relates predominately to those planning instruments which seek to minimise the amount of waste to landfill and concentrates on waste recycling methodologies. Our client fully supports same in the right context. But in regard to site Alternative 3, the protection of agricultural resources, which is recognised in the Drakenstein Spatial Development Framework as set out in paragraph 3.2.8 of the DSR, appears to be overlooked by you in regard to this particular site. 26. In this regard, one of the key objective (Objective 8) in the Provincial Spatial Development Framework (PSDF) is the objective to protect agricultural resources. The objective recognises the key role which agricultural activity plays in the Western Cape and the need to retain existing agricultural activities to ensure its key position in the region’s economy. The objective also aims at achieving measures to ensure that land with agricultural potential is not developed and then presented as a candidate for further urban or non-agricultural development purposes.

Comment noted to be assessed further if necessary.

27. In dealing further with this objective under land use management, the PSDF proposes that as a policy, all land in the Western Cape should be defined in terms of certain broad spatial planning categories amongst which is “intensive Agriculture” in order to manage land use changes in the province. Intensive Agriculture is defined in the PSDF as meaning, inter alia, land with existing agricultural activity. There can be no doubt that our client’s vast infrastructure in the area falls within the definition of intensive agriculture. Our client’s infrastructure in close proximity to site Alternative 3 for the proposed facility includes laying farms and broiler farms. Our client has further laying farms and broiler farms in the nearby vicinity and it is one of the major producers of poultry in the Western Cape.

Comment noted

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

28. The PSDF stipulates that spatial development frameworks cannot change existing rights and as a control measure proposes that no development proposals may be approved for a particular project if it is a large scale one. Our client believes that the proposed facility which is to be developed in phases is a large scale one and as far as it has been able to establish, the boundaries of the bioregional spatial planning categories have not yet been delineated and approved. In the action plan for achieving the boundaries of the bioregional spatial planning categories, the PSDF stipulates that approval for such categories should be governed by Land Use Planning Ordinance (LUPO) (or its successor) and that even when approved as part of an Spatial Development Framework, these categories may not take away existing rights. (our emphasis)

Comment noted.

29. Finally, in regard to the PSDF, recognition is given to the essential role land plays in the production of food necessary for sustaining human life and contributing to the cash economy and export market of the province. Agriculture is one of the main pillars of the Western Cape economy especially with respect to employment and it is for this reason that intensive Agriculture has been designated as a provincial broad spatial planning category on its own. Because land designated as Intensive Agriculture is under severe pressure near the urban edge, strict protection is required in these instances as it is in this location where agricultural produce generally enjoys the lowest production costs, especially with respect to transport. Maintaining this will enable produce prices to be kept as low as possible. In order to control development, the PSDF recognises that existing intensive agriculture should be protected from urban development and that the current legal controls under the Conservation of Agricultural Resources Act and LUPO should be enforced.

Comment noted. Socio-economic Specialist Study to address these particular concerns.

30. Our client is accordingly of the view that it is essential in regard to site Alternative 3 that a study be commissioned to consider the impacts which the proposed facility may have not only on its operations in the area but also the other agricultural activities that are being conducted in the vicinity of this site.

Comment noted. The respective specialist studies would need to cover this concern should Site Alternative 3 be included in the specialist phase of the project.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

31. In regard to the question of need and desirability which is dealt with in paragraph 4.3 of the DSR, our client identifies with the following comment made by you on page 60: “With regards to the appropriateness of the facility on a local level; the proposed site is located adjacent to the existing landfill site and would be a logical location for the proposed extended waste management activities.” Siting the proposed facility on site Alternative 3, would contradict this statement and would be most undesirable. Here, too, our client’s rights to deal more fully with the question of need and desirability for the proposed facility on site Alternative 3, is reserved for further consideration upon receipt of the Draft EIA Report.

Comment noted. The Site Screening and Ranking process will take place as part of the Assessment phase of the project and will confirm the preferred site/s to be evaluated in the Specialist phase of the project.

Conclusion

32. Having regard to the BID process where only site Alternatives 1 and 2 were considered, the appropriateness of site Alternatives 1 and 2 for the proposed facility and the fact that the environmental concerns at those two sites are less significant than in regard to site Alternative 3, our client is of the view that the addition of site Alternative 3 for assessment was ill-conceived.

The inclusion of the third site alternative was based on the request from the Drakenstein Municipality and the Stellenbosch Municipality which in summary required further alternatives to be considered and in the case of Stellenbosch Municipality potential sites located closer to the Stellenbosch municipal boundary.

33. For all the reasons set out above, our client considers site Alternative 3 to be wholly inappropriate for the proposed facility and we urge the DEA at this stage of the process to seriously consider removing site Alternative 3 from the EIA process. In this regard, the conclusion on page 43 of the Draft Strategic Environmental Assessment Report in respect of the Klapmuts North SEA is worthy of mention. That conclusion to the effect that: “The largely under-utilised remainder of farm 736 offers a good agricultural empowerment opportunity. The soils are expected to be of medium potential only, but should be adequate for vegetable production and stock farming on planted pastures. This opportunity will however require a full agricultural potential assessment, including a study into the availability of water resources. The use of this land for residential development is not recommended:”, is supported by our client. Although the SEA considered the use of Erf 786 for residential development, we make so bold as to state that the authors of that

The Strategic Environmental Assessment (SEA) process that was managed by Sivest did make reference to and recommend that the rural – farming nature of the area be maintained. These recommendations were not ignored when including Erf 734. Erf 734 was included due to the fact that consultation with Drakenstein town planning officials confirmed that the recommendations made as part of the SEA process and report were not necessarily supported or adopted by Council and that there was still some discussion required as to whether the property could also accommodate developments of a commercial nature. The completion of the SEA process forms part of a separate project.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

report would never have countenanced the proposed facility on this property.

Kindly acknowledge receipt hereof, confirm our client’s registration as an I&AP care of ourselves and address all further communications in regard to this application to the writer for his attention.

Noted. ENS will be continually informed and updated of the project progress.

2. Since the development of a facility to minimise and recycle waste is in line with the current policies and planning framework of the Cape Winelands District Municipality, Municipal Health Services support t he mentioned development.

Thus, if all the legal requirements stipulated in relevant legislation are adhere to, there is no objection to the proposed establishment of a waste recovery, beneficiation and energy project facility in Wellington.

Comment noted.

3. Currently we consider the Draft Scoping Report (DSR) as a broad overview of the proposed project, describing the background, site alternatives, waste activities, different processes / legalities (permits, licences, assessments to be conducted) and the public participation process.

At this stage, we reserve the right to provide comprehensive feedback until we had the chance to scrutinize the various proposed specialist study and/or assessment reports cited on page 15 of the DSR.

Since we are registering as an interested party, we assume that you will forward us copies of the mentioned specialist study and/or assessment reports.

Comment noted. CWDM will be informed of all future correspondence and stakeholder/authority meetings

Cape Winelands District Municipality Jacques le Roux

28 January 2015

4. At this stage we would like to propose and highlight the following comments and or explanations about the information given in the DSR:

4.1 ATMOSPHERIC LICENSING AUTHORITY: With reference to the Cape Winelands District Municipality indicated as the Atmospheric Licensing Authority to issue the Atmospheric

DEADP Pollution Management (Mr Peter Harmse) clarified as to who should be the Licensing Authority – e-mail correspondence received below;

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

Emission Licence for the Proposed Waste Recovery, Beneficiation and Energy Project at Drakenstein Municipality (Pages 11, 31 and 59 refers). With the undermentioned as reference, the applicant must clarify who will be the Atmospheric Licensing Authority. In terms of the National Environmental Management: Air Quality Act (Act 39 of 2004), Section 36(4) states that if a municipality applies for an atmospheric emission licence, a provincial organ of state designated by the MEC must be regarded as the licensing authority for the purpose of –

(a) that application; and (b) the implementation of this Act in relation to any licence that

may be issued to the municipality.

The National Environmental Management: Air Quality Amendment Act (Act 20 of 2014), Section 36(5) relates to circumstances where the Minister becomes the Licensing authority. Section 36(5) of the Air Quality Amendment Act declares that, notwithstanding subsections (1) to (4), the Minister is the licensing authority and must perform the functions of the licensing authority if – “(d) the listed activity relates to the activities listed in terms of Section 24(2) of the National Environmental Management Act, 1998, or in terms of Section 19(1) of the National Environmental Management: Waste Act, 2008, or the Minister has been identified as the competent authority” The National Environmental Management: Air Quality Amendment Act (Act 20 of 2014), make in Section 36(6) provision for an integrated environmental authorisation which will include the Atmospheric Emission Licence.

“The e-mail dated 02 February 2015 from Cape Winelands District Municipality in which it was requested to clarify who the Licensing authority for this application is, refers. After obtaining background information w.r.t this application, a telephonic discussion was held with an official of the National Department of Environmental Affairs (DEA) Mr. Vumile Senene (Director: Air Quality Management) on Monday 09 February 2015(with G. Manuel , D:EA&DP AQM) and again on Tuesday 10 February 2015 (with P. Harmse , D:EA&DP AQM). During this telephonic discussion it was confirmed that the National Department of Environmental Affairs would fulfil the role of the Licensing Authority for this application. The applicable section in the National Environmental Management: Air Quality Act (NEM:AQA) is section 36(5)(d). This section states the following:

S36(5)(d): “Notwithstanding subsections (1) to (4), the Minister is the licensing authority and must perform the functions of the licensing authority if: (d) the listed activity relates to the activities listed in terms of section 24(2) of the National Environmental Management Act, 1998, or in terms of section 19(1) of the National Environmental Management: Waste Act, 2008, or the Minister has been identified as the competent authority; … “

Subsequent to this discussion, an authorities meeting was also held to discuss the application. Officials from Cape Winelands District Municipality and Department of Environmental Affairs and Development planning (Waste and Air Quality Directorates) were present. During this meeting, Peter Harmse shared that the National Department of Environmental Affairs (DEA): Air Quality Management is the responsible competent authority and that they (DEA) will handle the application.”

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

For the purpose of subsection (5)(d), the Minister, as the competent authority empowered under Section 24C(2) of the National Environmental Management Act, 1998, and as the licensing authority empowered under Section 43(1) of the National Environmental Management: Waste Act, 2008, may issue an integrated environmental authorisation for the activities listed under Section 24(2) of the National Environmental Management Act, 1998 and Section 19(1) of the National Environmental Management: Waste Act, 2008.

The integrated environmental authorization process is being followed.

4.2 When the proposed (Page 15 of the DSR refers) SPECIALIST AIR QUALITY IMPACT ASSESSMENT STUDY is commissioned the atmospheric dispersion models as identified by the Department of Environmental Affairs as screening models for regulatory purposes must be used.

4.2.1 Clarity must be provided with the Specialist Air Quality Impact Assessment Study with specific reference to the methodology adopted in assessing presence of odour. The National Ambient Air Quality Standards of GN 1210 of 2009 in terms of Section 9(1) of the National Environmental Management: Air Quality Act (Act 39 of 2004) does not make provision for limit values for an odour indicator, aimed to reduce the detrimental effect on the environment, including health, social-, economic-, ecological conditions or cultural heritage. Although South Africa does not have guidelines for controlling and managing odour, various odour thresholds and guidelines have been published internationally in the determination of the odour impact. It must be noted that this project include area and/or line sources, as well as point sources with possible contributing odours emissions. The limit value used for indicating the odours emissions should accommodate both limits for area and/or line sources and in addition limits for point sources.

Comment noted – to be included in the Terms of Reference (TOR). Comment noted – to be included in the Terms of Reference (TOR). Comment noted. Comment noted – Appointed Air Quality specialist to be sensitised to this information if they are not already aware of its presence. Comment noted – to be included in the Terms of Reference (TOR).

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

In addition, a clear indication must be made between possible human health risk threshold values from the odour impact and the nuisance values from the odour impact within this study.

Comment noted – to be included in the Terms of Reference (TOR).

4.2.2 Odour Mitigation: Best practice measures intended to minimise or avoid offensive odours must be implemented throughout the plant, with specific reference to the following:

4.2.2.1 All buildings that may emit offensive odours must be sealed, according to best practice methods, in order to render the atmosphere inside the building under a negative pressure in relation to the outside atmosphere.

4.2.2.2 All plant equipment that may emit offensive odours must be tied into a centralized ducting system and all these emissions must be treated before being emitted to the atmosphere.

4.2.2.3 Insurance that no offensive or noxious gases will be emitted from the plant, directly into the atmosphere, without undergoing effective treatment.

4.2.2.4 Establish a register for recording all complaints received regarding odours, as well as the follow up actions and responses to the complainants.

Air Quality Specialist to provide guidance in this regard. Report to address these key issues. Air Quality Specialist to provide guidance in this regard. Report to address these key issues in conjunction with plant design. Air Quality Specialist to provide guidance in this regard. Report to address these key issues, in conjunction with plant design. Air Quality Specialist to provide guidance in this regard. Report to address these key issues in conjunction with plant design. Air Quality Specialist to provide guidance in this regard. Report to address these key issues.

4.2.3 Ambient Air Quality Monitoring: Indication must be made in the Scoping Report to the sampling for compliance monitoring to be conducted in terms of the National Ambient Air Quality Standards of GN 1210 of 2009 for the listed activities.

Comment noted. This aspect will be addressed in the Draft Impact Assessment Report

4.2.4 Dust Mitigation: In order to comply with the National Dust Control Regulations (Regulation 827 of 01 November 2013), the applicant is required to submit a fugitive dust management plan as detailed below:

(a) Identify all possible sources of dust within the affected site; (b) Detail the best practicable measures to be undertaken to

mitigate dust emissions; (c) Detail an implementation schedule;

Comments noted. This important aspect will be highlighted in the Specialist TOR.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

(d) Identify the line management responsible for implementation; (e) Incorporate the dust fallout monitoring plan; and (f) Establish a register for recording all complaints received

regarding dust fall and for recording follow up actions and responses to the complainants

4.3 SITE ALTERNATIVES: 4.3.1 Provide detailed Environmental Sensitivity Maps for locations 1 and 2 on Erf 34.

4.3.2 Provide a detailed meteorology impact assessment of sites 1 and 2 regarding the influence the project might have on future weather patterns in Wellington.

These two aspects to be addressed as part of and on completion of the specialist studies in the Impact Assessment Phase.

4.4 WASTE MANAGEMENT AND ENVIRONMENTAL POLLUTION CONTROL: 4.4.1 Due to the fact that the application for a Waste Management Licence involves hazardous waste management activities, such as the treatment of hazardous waste, we request a list of all hazardous waste (biological and chemical) which is going to be received and processed at the plant.

Clarify if condemned abattoir waste, as defined in terms of the Meat Safety Act (Act 40 of 2000), will be accepted.

General and hazardous waste list to be compiled and provided in the DEIR. This list will also form an important base to determine the emissions inventory for the air quality impact assessment. It is unlikely that condemned abattoir waste or possibly even abattoir waste will be received at the Anaerobic Digestion component of the project. To be formally clarified and confirmed in the DEIR.

4.4.2 Define all waste to be used at the proposed Waste to Energy Plant, and the subsequent control measurements to prevent environmental pollution.

General and hazardous waste list to be compiled and provided in the DEIR.

4.4.3 Specifically stipulate how waste streams are going to be managed nuisance free concerning the “storage of raw materials for later use” (wet and dry waste) and the rotation period thereof. Nuisance free includes effective vector and pest control, obnoxious odour control and the control of bio-aerosois.

Comment noted. To be addressed in the DEIR and relevant specialist reports

4.4.4 The transport of waste streams such as sewage sludge and possibly abattoir waste to the proposed facility is an issue of concern.

Comment noted. A Health Risk Assessment report will be compiled as part of the Impact Assessment phase of the project.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

These streams have inherent hazards, notably in respect of pathogen content, and these hazards need to be managed both in terms of transport, as well as in terms of materials handling at the facility. 4.4.5 From a transport perspective, hazardous materials and wastes routinely have to be moved from point of generation to treatment, recycling or disposal facility. Therefore, provide assessment of the significance (from a human health perspective) of potential risk from exposure to potential infectious diseases because of direct contact with hazardous material that could result from accidental spillage of these hazardous wastes during transport. Outline measures that will be put in place to protect against such incidents and its subsequent spillage to ground and potential ground or water contamination, along with consequent direct or indirect human exposure.

Define the precautionary and emergency response measures that will be followed for the transport of hazardous materials.

Comment noted. A Health Risk Assessment report will be compiled as part of the Impact Assessment phase of the project.

4.4.6 Providers and/or contributors of waste to this proposed project must be named with their relevant contact detail.

Relevant information will be provided should this be practically possible. Reporting waste volumes to the authority’s waste information system is a legal requirement, and will specifiy the types, tons (volumes) and sources of waste.

4.5 When the proposed (Page 15 of the DSR refers) HEALTH IMPACT ASSESSMENT REPORT is commissioned the following must be comprehensively included:-

4.5.1 Identify all biohazards associated with the different feedstocks

4.5.2 Hazard and Exposure Assessment, specifically with regard to health

4.5.3 Health risks associated with the transport of feedstock, in the form of organic waste, to the facility

4.5.4 Health risks associated with waste processing at the proposed facility; specifically potential health risks from community exposure to hazardous emissions or disease vectors from the facility

Comments noted. All comments 4.5.1 to 4.5.9 to be included in the TOR of the Health Risk Assessor.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

4.5.5 Health risks associated with use of end products produced from the facility

4.5.6 Ascertain meteorological conditions important in respect of potential dispersion of emissions or disease vectors from the facility

4.5.7 Categorise the potential health risk impacts to resident communities and/or workers surrounding the proposed facility as a result of potential inhalation exposures (chemical and bioaerosol emissions)

4.5.8 In terms of bioaerosol emissions, a comprehensive literature review of potential emissions and hazards associated with the proposed activities must be undertaken to define minimum process control and management measures that are required in terms of international best practices

4.5.9 Health Risk Assessment of all Chemical and Bioaerosol Emissions from Waste Processing The storage, handling and processing of waste feedstocks at the proposed facility may result in potential health risks due to the release of emissions to atmosphere at various stages in the process. In view of that, assess the relevant hazards (e.g. potential chemical and biological emissions to atmosphere) and its potential health risks, and define mitigatory measures required for management of these risks. These emissions to the atmosphere from the proposed beneficiation facility will probably be investigated and quantified in detail in the specialist Air Quality Specialist Report. Define the measures that are required to ensure acceptable management and mitigation of potential health risks associated with emissions from the proposed facility. These include both process design requirements and abatement measures, as well as quality control testing.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

4.6 WATER POLLUTION & QUALITY CONTROL: 4.6.1 Investigate the baseline status of groundwater at the proposed sites and determine whether certain impact assessments or the drill of monitoring boreholes is necessary from a geohydrological perspective.

4.6.2 Explain how any wastewater, as result of waste processing activities, will be managed to eliminate and/or minimise environmental pollution.

The current landfill - waste management activities in close proximity to the preferred alternative site and the current groundwater monitoring network in place will ensure that adequate groundwater information can be provided without a detailed groundwater impact assessment being necessary.

The necessary information for Site alternative 3 would need to be collated should this site be included in the Specialist phase of the project.

Wastewater generated from the waste processing facilities will either be retained within the process and treatment cycles or discharged to the municipal sewerage reticulation system.

4.7 PLANT MAINTENANCE: Biogas contains, apart from methane and carbon dioxide, water vapour, hydrogen sulphide and siloxanes.

These compounds can cause corrosion and precipitation inside generators and other equipment causing premature equipment failure. It is thus necessary to condition the biogas. Therefore, describe how these compounds will be removed to mitigate premature equipment failure.

To be addressed as part of the Conceptual Site Design and Air Quality Impact Assessment.

4.8 EMERGENCY PREPAREDNESS AND ABNORMAL OPERATING CONDITIONS PLAN:

The applicant must formulate an internal emergency preparedness plan for acute pollution with the transport, storage or processing of waste. All risks identified in the plan must be systematically managed using one of the following approaches:

4.8.1 Environmental Management Procedures; and/or

4.8.2 A Contingency Plan to minimize the impact of the incident through efficient and effective emergency response. This should include as a minimum a description of responsible personnel, their expertise, contact numbers, response procedures, staff training programmes and personal protective equipment. A list of material and

Comment noted. To be addressed in DEIR Comment noted. To be addressed as part of DEIR and Operational and Monitoring Management Plans.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

equipment used in the event of acute pollution for containment, clean-up, response or prevention must be available for inspection. The Contingency Plan should include media specific response, i.e. storm-water and groundwater, discharges to sewer, waste, air pollution, etc.

5. PUBLIC PARTICIPATION PROCESS AND REGISTRATION AS AN INTERESTED PARTY:

Please include Mr. H.G. Boock, Deputy Director: Municipal Health Services, Cape Winelands District Municipality, as an interested party, to your database. Refer to the related attached registration form.

Comment noted. Confirmation that stakeholder database has been updated.

In principal the Solid Waste Department: City of Cape Town supports the diversion of waste from landfill. The proposed Waste Recovery, Beneficiation and Energy Project not only provides for the diversion of waste from landfill, but also through the latest technology specifically relating to beneficiation of waste.

Comment noted.

In our opinion the overall project concept and details are accurately captured and also includes the relevant legislative requirements with specific reference to specialist studies that need to be undertaken. The City of Cape Town therefore reserves the right to in future peruse and comment on the specialist studies, once conducted and related information is available.

Comment noted and agreed.

City of Cape Town: Solid Waste Management Tamzin October

30 January 2015

An aspect key to the success of the project is the availability of adequate quantities of feedstock/waste for the project. Detail and information on this matter is not yet available, the project still being in the planning phase. The City of Cape Town recommends the source(s) of feed material be identified and secured soonest to ensure the sustainable implementation of the project.

Comment noted and agreed.

34

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

3. The Drakenstein Municipality has entered into a Public Private Partnership with the applicant, Interwaste, which includes the integrated management of the municipality’s waste management operations. The Waste to Energy project is necessitated by the contract with the Drakenstein Municipality and includes the generation of renewable energy from municipal solid waste and reduction of municipal solid waste to landfill as its main objectives. The primary focus of the project is energy from waste, but it will also entail waste recovery and waste beneficiation activities. All other waste management activities are of secondary importance. The facility will comprise four main elements to be operated in series or as separate entities, namely a materials recovery facility: municipal solid waste pressing plant; anaerobic digestion plant; and direct combustion plant.

Comment noted.

4. The following is this Directorate’s provisional comment on the draft SR:

4.1 This Directorate supports the identified specialist studies that are to be undertaken to inform the environmental impact assessment phase of the application.

Comment noted.

4.2 It is recommended that special consideration is given to mitigation measures that minimise the potential impacts of the proposed development on the occupants and residents of areas with proximity of the site.

Comment noted. Aspects to be dealt with in the Social Impact Assessment, Air Quality and Risk related specialist studies.

Environmental Affairs and Development Planning: Development Management Arabel McClelland

02 February 2015

4.3 The Directorate notes that site alternative 2 currently contains a green waste chipping and building rubble crushing facility. Should this site alternative be authorised, the Drakenstein Municipality will be required to relocate the facility. It is stated that it would likely be relocated to site alternative 1. given that the operation of these facilities constitute activities that result in dust, noise and nuisance impacts, it is recommended that the impacts associated with relocating these operations is considered as part of this application. This is with particular respect to adjacent land uses and potential receptors.

Comment noted. The cumulative impacts of relocating current activities to a new site must be taken into account. It is also important to ensure that the necessary licences, authorizations are in place to ensure that such a move does not result in an illegal activity commencing.

It can be confirmed that DEADP Waste Management have issued Drakenstein Municipality with a Waste Management Licence for the Green waste and Building Rubble activities on site alternative 2. The site area is currently being engineered. The area now available for the proposed project is too small. Despite this development site alternative 2 in combination with

35

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

site alternative 1 will be considered in terms of potential site layout alternatives. Refer to the final scoping report for futher discussion under the Site Alternative section.

4.4 According to Chapter 2 (page 18) of the draft SR, the Berg River is less than 3km from the site. It is noted, however, that the Berg River is approximately 1km from site alternative 2 and approximately 1.5km to the west of site alternative 1.

Comment noted.

4.5 Based on the maps and imagery provided, it is evident that the railway line abuts site alternative 1. On this basis, it is recommended that Transnet is consulted as a stakeholder during the public participation process.

Transnet is registered on the stakeholder database.

4.6 The applicant is reminded that on 4 December 2014 the Minister of Environmental Affairs promulgated regulations in terms of Chapter 5 of the National Environmental Management Act, 1998 (Act No. 107 of 1998) (“NEMA”), viz, the Environmental Impact Assessment (“EIA”) Regulations 2014 (Government Notice (“GN”) No. R. 982, R. 983, R. 984 and R. 985 in Government Gazette No. 38282 of 4 December 2014). These regulations came into effect on 8 December 2014. The EIA Regulations 2014 replace the EIA Amendment Regulations that were promulgated in 2010 and also introduce new provisions regarding environmental impact assessments.

The application will follow the NEMA 2010 regulations, as per the transitional arrangement in the 2014 Regulations. The new provisions will however be consulted as necessary.

4.6.1 In terms of the transitional arrangements specifies in Regulation 53 of GN No. R. 982 of 4 December 2014, a pending application submitted in terms of the previous NEMA EIA Regulations, must be dispensed with in terms of those regulations as if they were not repeated. However, the regulations further state that should your pending application comprise any activities that were not listed under the previous NEMA notices, but are now listed in terms of the NEMA EIA Regulations 2014, the competent authority may dispense with such an application in terms of the previous NEMA EIA Regulations on condition that all impacts of the newly identified listed activities (in terms of the EIA Regulations 2014) have been considered and adequately assessed by the applicant and/or their Environmental Assessment Practitioner (“EAP”).

The application will follow the NEMA 2010 regulations. The new provisions will however be consulted as necessary.

36

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

4.6.2 It is therefore recommended that the new listing notices, as contained in GN No. R. 983, R. 984 and R. 985 of 4 December 2014, are consulted and all activities (similarly and/or newly listed) applicable to the application are included. An indication on how the impacts of the additional activities, listed in terms of the NEMA EIA Regulations, 2014, have been adequately assessed should also be included. In addition to this, all (registered) interested and Affected Parties must be informed of any new listed activities that may be triggered in terms of the EIA Regulations 2014, as well as the potential impacts thereof.

The application will follow the NEMA 2010 regulations. The new provisions will however be consulted as necessary.

5. The Department reserves the right to revise or withdraw comments or request further information based on any information received.

Comment noted.

Hester De Kock 3 February 2015 Ek het ‘n e-pos ontvang vanaf mnr. Deon Louw, Departement Infrastruktuur Drakenstein Munisipaliteit, met die aanhegsel vanaf u kantoor vir besware indien teen die beoogde Waste to Energy projek te Wellington.

Ongelukkig het my rekenaar se e-posprogram foutief geraak reeds in Desember en is nou eers weer herstel. Ek het ek al die gestoorde inligting in spesiale folders verloor asook al my kontakte. U kontakbesonderhede het meneer Louw vandag op versoek vir my aangestuur. Ongelukkig nie weer die brief vanaf u kantoor nie.

Ek benodig die e-pos wat hy aan my getuur het vir “ons beswaardes” wat die beoogde projek aanbetref om te reageer voor die sperdatum?.

Kan u dit asseblief vir my aanstuur. Indien ek reeds die sperdatum verpas het, hoe help u my?

Baie dankie.

Hi Hester Jy kan u insette vir my stuur. Die sperdatum was Maandag 2 Februarie 15 maar stuur nogtans u brief of briewe. Groete Larry Eichstadt Responses attached as part of Annexure A, Appendix D. Also see communication below.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

2. The Directorate: Waste Management has the following comments on the information contained in the DSR:

2.1 The proposed project must not create any nuisance conditions (i.e. dust, odour, windblown litter vermin etc.) which may affect the surrounding areas, particularly the business park across the R44 from the proposed activity. Any incident that causes excessive nuisance conditions must be monitored managed and mitigated within 24 hours from which time the incident occurred.

The specialist air quality study must address the air quality, nuisance aspects highlighted.

2.2 A storm water/wastewater management plan which gives a design plan of both the waste water system as well as the storm water system must be developed. An implementation plan for constructing these systems needs to be developed. The proper management of these systems will prevent contamination of the surface and groundwater.

A detailed stormwater management plan will be prepared which is integrated with the freshwater and biodiversity aspects already identified within the immediate area as part of the Strategic Environmental Assessment conducted by Worley Parsons and Associates.

2.3 The stormwater/wastewater management system must effectively separate storm water and waste water.

Comment noted.

2.4 It is noted that the illegal dumping has been stopped: measures and signage should still be put in place to prevent future dumping.

Comment noted

Environmental Affairs and Development Planning: Waste Management Licensing Tauriq Mohidin

12 February 2015

3. The Department reserves the right to revise initial comments and request further information based on the information received.

Comment noted.

Hester de Kock 4 March 2015 Heeltemal mosterd na die maal, ek weet. Ek moes egter eers tyd iewers soek om weereens deur 'n magdom inligting te werk en besluit watter ek sal aanstuur en daardeur my kop in 'n bynes steek. Ek maak egter staat op u goedgesindheid en versoek dat u asseblief sal kyk na dit wat ek selekteer het. Baie daarvan is sekerlik bekend vir u. Ek beskik oor ruim nog soveel kundige besware van individue. En ook inligting wat ek op die Web gekry het. Ek laat dit eers.

Die inligting wat ek het volgens die vergadering WTE by Windmeul Kelder op 22 Januarie 2015:

Comments noted. It is important to understand that RMS have been appointed to facilitate the EIA process and has no jurisdiction with respect to the appointment of contractors by the Drakenstein Municipality. Queries in this regard must be directed to the Drakenstein Municipality. Your comments regarding traffic will be addressed in the EIA with the completion of the Traffic Impact Assessment.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

Die volgende was bespreek/gevra:

Huidig ontvang Wellington stortingsterrein slegs Vullis van Drakenstein Area: Dus is dit ? Munisipale Funksie Indien Interwaste die stortingsterrein oorneem, sal hulle vullis ontvang vanaf ander areas: Dus word die storting? Distriks Funksie. Volgens mnr. Deon Du Plessis van Drakenstein Munisipaliteit sal hul hierdie probleem oorbrug deur? kontrak met Interwaste te onderteken. Wat dus beteken dat Interwaste dan die reg het om enige kontrak aan te gaan vir invoer van vullis.

Die probleem wat ek hier voorsien is: Drakenstein en veral Wellington Belastingbetalers sal geen beheer/ jurisdiksie hê oor die vullis wat ingevoer word deur Interwaste nie asook die kontrakte wat Interwaste wil aangaan nie. Indien die vullis wat hul gaan invoer nie genoeg is nie, het hulle dus die reg om meer vullis in te voer. Die infrastruktuur betreffende die pad asook die verkeer wat daardie spesifieke gedeelte pad reeds dra, gaan andersoortige probleme skep.

Interwaste se brekende tarief op die huidige ekonomiese speerpunt is R100 per ton vullis wat hulle inbring. Dit is baie minder as wat die Drakensteinse besighede en inwoners per ton betaal. M.a.w. Interwaste se kliënte wat buite Drakenstein is, word bevoordeel bo Drakenstein inwoners wat weggooi koste aanbetref.

Volgens die verslag beplan Interwaste om 200 ton vullis per dag in te "voer" vanaf omliggende dorpe. Dit is baie meer is as wat huidig daagliks deur Drakenstein gestort word. Dit sal verdere druk plaas op die infrastruktuur van die deurgang paaie na die stortingsterrein. Byvoorbeeld die padoppervlakke deur die gebruik van ekstra vragmotors wat die verskillende toevoerroete via Wellington distrik na die stortingsterrein gaan gebruik en wat almal uitloop op een plek na die ingang van die terrein. Die verkeersvloei van die reeds té besige roete sal verder gestrem word tot nadeel van ons dorp se werkersklas wat die afgelope 45 jr. weens verskeie redes gedwing

The comment received is noted. The EIA related queries included in the comments received will need to be responded to during the next phase of the EIA process.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

word om in omliggende dorpe en in die stadsgebiede te werk.

Baie dankie vir u tyd en aandag. Manuel Green Way Interiors

16 March 2015 Contacting you with regards the landfill project that has been initialised by the Drakenstein.

We run a wood working factory and are currently disposing of our waste/cutoffs/rumble in the best manner that’s been made available to us.

Staying conscious to the environment and our impact to it; we would like to stay updated as to the processes we should be manoeuvring/implementing to aid our "environmental community”.

I look forward to hearing from you and enlightening us to the future plans/process of this initiative.

Comment noted and registration confirmed. You will be notified of all future project developments.

Deon du Plessis 18 March 2015 Ronald

Die onlangse versoek vd Wellington sakekamer vir n opvolg inligtingsvergadering het betrekking. 1. Kry terugvoer of daar enige besware/klagtes/kommentaar itv die

EIA proses ontvang was? 2. Ek stel voor dat ons n opvolg inligtingsvergadering hou, reël

datum met hulle maar versoek dat hul op skrif aantoon waaroor hul uitklaring benodig. Die EIA opedag en ander info vergaderings bv by Wellington SEA vergaderings het volgens my al hul vorige issues aangespreek bv 1. Keuse van WTE terrrein 2. Addisionele vervoer probleme 3. Besoedeling, reuke ens 4. Interwaste se aanstelling onder“ wolk van ongeruimdhede” 5. WTE is nie beproefde tegnologie nie en onekonomies . Ek stel ook voor dat ons na die vergadering al die sake( issues) per amptelike skrywe beantwoord vir toekomstige verwysing.

3. Voorsien ook afskrif vd “ inligtingstuk” wat saam met rekeninge moet uitgaan.

Hi Ronald The Chamber of Business need to submit all comments directly to RMS and not via the municipality or any other third party! We cannot have parallel public consultation processes or extended public consultation processes running as this will confuse what is part of the consultation process and what is not. Other stakeholders can also then question why we are engaging with certain stakeholders and not others at certain times.

40

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

Ek stel voor dat die saak met D Louw bespreek word voordat finale reëlings vir n opvolg vergadering gemaak word. Kan voor more se WTE vergadering bespreek word.

Ronald Brown 22 March 2015 Hi Larry, We’ve again received complaints from the Wellington Chamber of Business regarding the installation of the WtE system. In order to lay this to bed we’ve decided to:

To make available the comments from the EIA (all comments and the open day)

Request written questions as it tends that the same questions are ask over and over again

Minutes be recorded of each meeting and distributed to all stakeholders

I’ve discussed this matter with Leon at our Thursday TSC meeting to request engaging with you for the information and I trust you can assist me in this regard please?

Your assistance will be immensely appreciated.

It will be appreciated if the comments received can be forward to RMS and the relevant persons contact details also distributed in order that the correct message can be sent out how the EIA communication process must function for transparency purposes. All the required information forms part of the documents on the website which were available for the required 40 day comment period. The municipality also received four copies of the reports. I think it is important that RMS communicate with the stakeholders and not the municipality to avoid confusion. All comments must be submitted directly to RMS and not via the municipality. The municipality should not facilitate the communication process for RMS.

Goei dag aan wie dit mag aangaan (Larry Eichstadt)

Agri Wes-Kaap wil in hierdie laat stadium as ‘n I&AP registreet om afskrifte van die konsep EIR en EIR, s00s en wanneer dit beskikbaar is, te ontvang.

Johan Bothma Agri Wes-Kaap

02 April 2015

Die AWK kontakpersoon sal soos volg wees, naamlik

Mnr. Carl Opperman, HUB, Agri Wes-Kaap Tel (021) 8603800 E-pos: [email protected]

As alternatiewe kontakpersoon myself, Johan Bothma as Hoofbestuurder AWK by dieselfde telefoon nommer en e-pos adres van [email protected]

Bevestig asseblief dat u AWK as I&AP geregistreer het en ons van alle relevante dokumente sal voorsien waarop ons kommentaar kan indien.

Ons bevestig dat Agri Weskaap is nou geregistreer as ‘n I&AP vir die Interwaste Drakenstein Waste to Energy Project. Ons sal u in kennis stel wanneer die volgende verslae beskikbaar sal wees vir publieke komentaar.

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

[email protected] 23 April 2015 I hav just spoken to welling ton. Im going to phon mr stowman we want to help keep our town kleen. The tractor team must NOT thwart this beatifull gesture.

Recycling I live at no 5 appollis street, the collectors left my two bags for the 2 nd week the first week they took it what am I supposed to do. I support recycling like I said in bailey nd charmains time we promoted it

Comment noted.

AANDAG: ALLE WELLINGTONNERS

IN SAKE: “WASTE TO ENERGY” PROJEK IN WELLINGTON

Dit kom voor of talle inwoners van Wellington nog onbewus is van die GROOT ROMMELWERF en verbrandings oonde wat ons pragtige skoon Bolandse dorpie met rook en as gaan besoedel!

Weens die beperkte ruimte van die stortingsterrein, het Drakenstein Munisipaliteit ‘n ooreenkoms met Inter Waste gesluit en word Wellington geag om die geskikte perseel te wees vir die rommel verwerkings fasiliteit.

Tans lewer Wellington en Paarl sowat 300 ton per dag, maar om die projek lewensvatbaar te maak moet ‘n addisionele 200 ton rommel vanaf aanliggende dorpe aangery word na die verbrandingsoonde in Wellington.

The Final Scoping Report outlines which studies are recommended. The following are likely to be necessary (NB: Subject to authority acceptance)

a) Air Quality Impact Assessment (Atmospheric Emissions Licence required) b) Health Risk Assessment c) Social Impact Assessment (Scoping and Specialist phase) d) Economic Impact Assessment e) Traffic Impact Statement f) Noise Impact Assessment g) Heritage Impact assessment (Heritage Approval required) h) Major Hazardous Installation (MHI) Assessment i) Freshwater and Botanical Screening Assessments (work already completed as part of the Strategic Environmental Assessments for the areas within which all 3 alternative sites are located will be reviewed as necessary). j) Visual Impact Assessment Comment noted.

Deon Louw 23 April 2015

BEKOMMERNISSE:

1. Giftige plastiek dampe en as 2. Konstante rook 3. Grondwater besoedeling 4. Landboukundige implikasies –Moontlike belemmering van uitvoere 5. Waardevermindering van eiendom 6. Verkeers implikasies-Addisionele Vragmotors 7. Finansiële implikasies-Kostes met oprigting 8. Gesondheids risikos - Dioxine afskydings(Veroorsaak kanker ) 9. Invloed op toerisme

Concerns will need to be addressed during the impact assessment phase of the project. This phase will include the completion of a number of specialist studies.

The Final Scoping Report outlines which studies are recommended. The following are likely to be necessary (NB: Subject to authority acceptance)

a) Air Quality Impact Assessment (Atmospheric Emissions Licence required) b) Health Risk Assessment c) Social Impact Assessment (Scoping and Specialist phase) d) Economic Impact Assessment

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Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

e) Traffic Impact Statement f) Noise Impact Assessment g) Heritage Impact assessment (Heritage Approval required) h) Major Hazardous Installation (MHI) Assessment i) Freshwater and Botanical Screening Assessments (work already completed as part of the Strategic Environmental Assessments for the areas within which all 3 alternative sites are located will be reviewed as necessary). j) Visual Impact Assessment

Fasiliteit is so ontwerp vir maklike aanbouing en vergroting in die toekoms wat nog meer neagtiewe implikasies tot gevolg mag hê.

NB: 13 Mei 2015 is die laaste geleentheid om saam te staan en Wellington te beskerm teen hierdie projek! Dit is van kardinale belang dat elkeen in Wellington hierdie vergadering bywoon om hulle te forseer om ‘n ander perseel te identifiseer waar dit minder impak het op ‘n dorp en sy inwoners

Comment noted and to be addressed as part of the Specialist Phase of the project.

The expansion and/or enlargement of any waste management facility requires that a new environmental process be conducted to assess the potential impact of the proposed activities. This new environmental process obviously involves public consultation.

Please take note that the current EIA process makes allowance for ongoing public consultation as follows:

1. Circulation of Final Scoping Report – minimum 21-day comment period.

2. Circulation of Draft Environmental Impact Report – minimum 40-day comment period.

3. Circulation of Final Environmental Impact Report – minimum 21-day comment period.

Anneke Strauss 12 May 2015 Hiermee wil ek my beswaar aanteken teen die voorgestelde projek. Asb, moenie hiermee voortgaan en ons inwoners se gesondheid in die proses op prys stel nie. Gaan doen dit iewers waar daar minder mense bly!!

Comment noted and registration confirmed.

Madelein de Stadler 12 May 2015 Hiermee staan ek, Madelein de Stadler, die bogenoemde projek TEEN, dat dit nie in Wellington sal opgerig word nie.

Comment noted and registration confirmed.

43

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

Helandie Smith 12 May 2015 Halo Admin van WellingtonInfo Ek kan ongelukkig nie die rommel projek se vergadering bywoon nie, maar vra hiermee dat julle my streng teenkanting teen hierdie projek asseblief aan die organiseerders oordra. Hulle is welkom om my naam en/of epos adres te gebruik om enige petisie daarteen, te onderteken.

Comment noted and registration confirmed.

Deon Smith 12 May 2015 Aangesien ek nie vanaand se vergadering kan bywoon nie teken ek (Deon Smith (ID : 7105025039082)) beswaar aan teen die voorgestelde Rommel project.

Comment noted and registration confirmed.

Christine van Wyk 12 May 2015 Hallo Ronald, Deon,

Ek heg hierdie eposse wat ek van Wellingtoin Info na my persoonlike adres gery het, ter inligting aan. Ek vra byvoorbaat om verskoning vir die stortvloed wat dalk mag volg, maar ek moet dit uiteraard onder julle, die Munisipaliteit se aandag bring.

Daar is geen vrae; slegs verskonings dat die sessie nie bygewoon kan word & besware.

Kan julle asseblief ontvangs van my vrae soos vanoggend weer gestuur, erken? Dan het Mev De Kock bv reeds in Januarie direk aan Larry Eischstadt haar vrae/bekommernisse gestuur na aanleiding van die openbare deelname proses; ek vertrou hy sal dit op rekord hê & dat daar more-aand aandag aan gegee sal word?

Baie dankie byvoorbaat; ons sien julle more-aand!

Comment noted and registration confirmed.

Please refer to further communication in table which includes the questions submiited.

Fritz Brink 12 May 2015 Refer our prior e-mail of 27th August and our letter of even date submitted under cover thereof. For ease of reference I’ve attached further copies of our letter and the “Registration & Comment Sheet”.

What is the status of the proposed establishment of the Waste to Energy facility/project? We’ve not received any further feedback; nor reports; nor invitations to public participation meetings. The only communications we’ve received have been from some “concerned” groups.

Please advise.

44

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

Good afternoon,

Have now uncovered your e-mail notice of 21st November 2014 and noted that the DSR review and comment phase had ended on 2nd February 2015. We still stand by the comments that were provided by our original letter dated 27th August 2014.

We note from your Circular dated 21 November that the “EIA process will include an additional three (3) occasions (other than the DSR commenting phase) for the public to comment on various documents that bill be prepared during the Final Scoping and EIA (specialist) phases”.

Could you please update us regarding the current status of this project.

Dear Fritz We are in the process of preparing the Final Scoping Report which we intend to circulate for public comment in June 2015. (as per E-mail) Kind Regards.

45

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

Simon van Wyk 14 May 2015 Larry,

Last night’s public meeting arranged by Drakenstein Municipality has reference.

I would like to be registered as an I&AP on your I&AP Database for this project.

At this stage, I request the following information (with accompanying annexures/appendices):

BID Draft Scoping Report (presumably containing your Multi-Criteria

Decision Analysis approach and methodology for site screening)

Copies of the adverts placed notifying the public of this project The DEA&DP Reference Number and Case Officer details

I request confirmation that I have been added to the I&AP register and await all future notifications as governed by Section 24 of NEMA. I expressly request all correspondence to be via email, SMS and conventional post (physical address provided above).

Presumably, NEM: WA triggers this proposed facility as a Category B Activity 8 listed activity requiring a full EIA, however please ensure all triggers in respective acts are provided e.g. NEM: AQA (Section 21 for Emission Limits), NWA, NHRA, LUPO etc.

When will the Final Scoping Report be available for review and comment?

My contact details are provided below.

Registration confirmed. 1. DSR is on the RMS website and therefore is accessible with all Annexures. 2. Formal site screening process with outcomes will be presented in FSR. 3. BID attached with adverts. 4. DEA is the Competent authority for the Waste Licence application, NEMA application and NEM: AQA application (submitted as and when required)

From a process perspective it would be appreciated if you could conform to the following below as underlined.

I&AP’s should refer to all the relevant reference numbers above, and must provide their comments together with their name, contact details (preferred method of notification, e.g. email address or fax number) and an indication of any direct business, financial, personal or other interest which they have in the application.

FSR circulation date cannot be confirmed at present as it is subject to parallel technical assessment work being conducted at present.

Kind Regards

46

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

Thank you for the speedy response. I have been to your website, under "projects" but failed to see exactly where I can download the information. Kindly provide the direct link so that I can access the information.

My interest in this project is in no way related to business or financial gain. I am a resident of Wellington residing at 32 Burg Street, Wellington (as my previous email indicated). It is expected that the public participation RMS undertakes will comply with DEA&DPs EIA GUIDELINE AND INFORMATION DOCUMENT SERIES, which includes amongst others the "GUIDELINE ON PUBLIC PARTICIPATION". Importantly, a clear and detailed understanding of the "NEEDS AND DESIRABILITY" should be followed in terms of this guideline and information series. I would expect that all the requirements be met in terms of the applicable Policies of the Western Cape Development Framework.

I am merely exercising my right to participate in this EIA as well as to ensure my rights, as contained in the Bill of Rights, Section 24 (a) and (b) are not compromised. I have a very young family, with my son being an asthmatic and thus my concerns relate to guarantees that the environmental impact meets all the sustainability requirements and that this development complies with each of the Sustainability Principles contained in Chapter 2 of NEMA:

PLEASE SEE ATTACHED FOR THE ‘ NEMA SUSTANABLE DEVELOPMENT PRINCIPLE’

Please see Annexure A, Appendix D.

I note your comment that DEA is the decision making authority, I am not sure why as Interwaste is not a governmental or parastatal entity, therefore the provincial decision making authority should apply viz. DEA&DP. I will take this matter up with Gerhard Gerber, Eben de Vos and Jaap de Villiers at DEA&DP to ensure clarity.

I will provide my comments formally post-review for recording within the EIA.

To save yourself time – DEA is the regulatory authority due to the fact that we are dealing with hazardous waste (sewage sludge in AD process) and an energy (electricity) output both of which are DEA competencies and delegations. Recent National Policy decisions now also require Atmospheric Emissions Licence (AEL) applications to be submitted to DEA for projects of this nature. It would be easier if it was a Provincial competency and delegation but unfortunately not the case.

47

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

Gerhard Potgieter, Lewis Coetzee & Truter

14 May 2015 My vullisverwydering kos R185.34 per maand. ‘n 75% verhoging per maand sal gevolglik R139.00 beloop.

“n Klein bedraggie per maand om ‘n potensiële gesondheids risiko te vermy. Dit verhoging beloop ongeveer 4% van my huidige maandelikse rekening van die Munisipaliteit.

Comment noted. It is important to highlight that the project covers the interests of a broad range of community sectors.

Johan Schoeman 14 May 2015 Geagte Larry,

Na aanleiding van gisteraand se vergadering te Wellington in die NG – Noord kerksaal net die volgende.

Nadat ek na jul aanbiedinge asook na die vrae en antwoorde geluister het, is daar nogsteeds iets wat my pla.

Jul bewering dat die aanleg GEEN rook, as of welriekende gasse deur die skoorsteen gaan vrylaat nie dan net die volgende.

Dan wil ek graag weet: “ Waarom is daar dan so ’n hoë skoorsteen nodig, wat gaan dit dan vry laat ?”

Dit gaan gasse vrylaat wat onsigbaar en reukloos is maar geen waarborg kan gegee word dat dit skadeloos gaan wees nie.

Tydens die warm somermaande wanneer daar geen wind in Wellington waai nie gaan die onsigbare en reuklose gasse bokant Wellington en omgewing bly hang.

M.a.w. dit gaan soos ’n kombers oor ons hang wat dan ’n kweekhuis effek gaan skep met honderd-en-tien nagevolge.

Die ergste is dat ons daardie “skoon” lug moet inasem.

Ek vertrou dat die vraag en jul antwoord daarop bygevoeg sal word by gisteraand se besprekings.Baie dankie,

Dankie vir die komentaar. Soos bevestig by gisteraand se vergadering een van die belangrikste spesialis studies sal die “ Air Quality Impact Assessment” wees. Hierdie studie sal alle faktore in ag moet neem voordat daar finale besluit kan wees oor skoorstene hoogte ens. Die “Atmospheric Emissions Licence” aansoek is n aansoek wat apart moet ingedien word by DEA (Nasional). Hierdie lisensie aansoek is een van vier of moontlik vyf ander aansoeke wat ingedien moet word.

48

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

Attie 16 May 2015 Stop WTE! Na Woensdag se inligtingsessie, is ons oorval met eposse van bekommerde Wellingtonners! Die WTE (Waste to Energie) projek wat deur Drakenstein Munisipaliteit in Wellington beoog word, blyk nie ‘n goed deurdagte, selfs goed nagevorsde (volgens kenners teenwoordig) besluit te wees. Waarvan die impak op Wellington se ekonomie, die gesondheid van sy inwoners en die omgewing in geheel, enorm kan wees. Die mandaat van inwoners teenwoordig tydens die vergadering was duidelik: STOP WTE! As jy saamstem, het ons jou stem nodig vir die ten minste 5 000 handtekeninge wat ons beplan om aaN Drakenstein Munisipaliteit te oorhandig. Stuur jou naam en kontak besonderhede na [email protected] of kom teken die petisie tydens kantoorure by: Malanstraat 27. Inligting rondom die projek kan bekom word van: larry@rmsenviro of [email protected] Gaan na www.outlook.com username: [email protected] en die wagwoord is admin@wte Praat later Ek het nou amper jou hele storie verander… jammer? Francois is op pad om die Engelse weergawe te doen; ek sal dit teen 10:45 by jou hê.

Baie dankie vir al jou moeite.

Dear Stakeholders

I think it is important to once again highlight what was said at the information transfer session in terms of the required communication process specific to the EIA process. All queries, objections, comments, etc. must be submitted to RMS as we are responsible for the facilitation of the EIA process. All persons who would like to register as stakeholders so as to receive future reports and be notified of future meetings must register formally with RMS.

Drakenstein Municipality is a direct stakeholder in the process.

The Final Scoping Report outlines which studies are recommended. The following are likely to be necessary (NB: Subject to authority acceptance)

a) Air Quality Impact Assessment (Atmospheric Emissions Licence required) b) Health Risk Assessment c) Social Impact Assessment (Scoping and Specialist phase) d) Economic Impact Assessment e) Traffic Impact Statement f) Noise Impact Assessment g) Heritage Impact assessment (Heritage Approval required) h) Major Hazardous Installation (MHI) Assessment i) Freshwater and Botanical Screening Assessments (work already completed as part of the Strategic Environmental Assessments for the areas within which all 3 alternative sites are located will be reviewed as necessary). j) Visual Impact Assessment

Martie de Wet 17 May 2015 Ons was ongelukkig nie by woensdag se vergadering nie. Kan jy meer inligting gee oor die WTE.

Sal graag teen dit wil stem. Soos die res wat ons verteenwoordig het tydens die vergadering indien nodig.

The Draft Scoping Report is currently on the RMS website should you wish to get the latest information available. (as per email).

Karin Smit 18 May 2015 Goeiedag,

Kan u asb vir my meer inligting oor bogenoemde aanstuur.

Are you requesting to be registered as a stakeholder? Please refer to the RMS website (www.rmsenviro.co.za) where a copy of the Draft Scoping Report for the project is accessible. Go to Projects – Current Projects and scroll down to view document. (as per email).

49

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

Francois Theron, FCB Group

18 May 2015 Re. registration as an affected party, participant and professional observer with regards to Waste to Energy project, Wellington (Drakenstein Municipality)

Dear Larry ,

1. Register me in my personal and professional capacity, participant and observer at [email protected] for all future announcements and documentation

2. I shall observe and participate with Stellenbosch University, School of Public Leadership, including our Institute for Sustainable Development

3. I shall consider to write a report, or/and get MPhil students to assess, following standard research ethics, with the necessary public and professional exposure

4. Kindly confirm no. 1

Attention: Prof. Mark Swilling (ISD, SU), Prof. Kobus Muller (SPL), Prof. Johan Hattingh (Dean), Prof. De Wet Schutte (CPUT)and Beatrix Steenkamp and Jennifer Saunders Identify a student/students who have a professional stake/interest in observing and conducting research on the implication for/the possibility and impact of a Waste to Energy project in Wellington. I can supervise (for SPL participants), as I am on sabbatical and a participant in the above

Registration as a stakeholder confirmed. All comments noted.

50

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

Christine van Wyk, FCB Group

18 May 2015 WIE DIT MAG AANGAAN

Hiermee my amptelike versoek om registrasie as belanghebbende mbt bogenoemde.

My besware wat reeds deurgegee was, nie aangespreek; in rooi:

Subject: WTE VRAE

Goeiemiddag Ronald, Deon,

My vrae vir die inligtingsessie van die 13de Mei; dankie.

1. In 2012 raak ek vir die eerste keer by “waste” & Wellington se stortingsterrein betrokke; wat my hoegenaamd geen ekspert maak, maar my darem ‘n bietjie agtergrond gee. Tydens daardie spesifieke besoek wat niks met WTE te doen gehad het, word onder almal aanwesig se aandag gebring dat die stortingsterrein die einde van sy leeftyd bereik. Die hoofsaak word genoem as sou die Mun nie oor die nodige fondse beskik (het) om die korrekte masjinerie aan te koop ten einde die terrein korrek te kompakteer. Ek verstaan die finansiële sy; wat my wel tot kommer stem, is die feit dat daar weinig tot geen beheer (reeds) is oor wat & wie vullis in Wellington kom stort. Ek heg fotos & eposse aan & verstaan dat enige iets tot reste van diere deur groot maatskappy wat nie in Wellington gesetel is, gestort word. As gevolg van die swak beheer, raak die stortingsterrein nou selfs vinniger vol EN verloor die Mun boonop inkomste, want inligting wil dit hê dat enige iemand enige iets van ENIGE PLEK boonop, hier kan kom stort, sonder permit, sonder betaal. Ek sal dus graag wil weet:

a) hoekom kan enige iemand enige tipe vullis sonder permit & sonder om te betaal, op ons terrein kom stort & wat word daaraan gedoen. Ek verwys spesifiek na die aangehegte epos as voorbeeld & die feit dat die inwoner bevestig het dat hy daardie vragmotor ELKE Woensdag sien

Registration confirmed. Most of the comments raised, addressed to the Drakenstein Municipality, are not related to the EIA process. Relevant questions, e.g. regarding air emissions and health impacts, site management and overall monitoring of the operations will be addressed in specialist studies and relevant management and maintenance plans during the EIA-phase. The Final Scoping Report outlines which studies are recommended. The following are likely to be necessary (NB: Subject to authority acceptance) a) Air Quality Impact Assessment (Atmospheric Emissions Licence required) b) Health Risk Assessment c) Social Impact Assessment (Scoping and Specialist phase) d) Economic Impact Assessment e) Traffic Impact Statement f) Noise Impact Assessment g) Heritage Impact assessment (Heritage Approval required) h) Major Hazardous Installation (MHI) Assessment i) Freshwater and Botanical Screening Assessments (work already completed as part of the Strategic Environmental Assessments for the areas within which all 3 alternative sites are located will be reviewed as necessary). j) Visual Impact Assessment

51

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

b) die finansiële implikasies van konsultant op konsultant aanstel vir WTE, voorbeeld in Korea besoek ens word na my mening totaal onderspeel. Kon daar nie intussen wel masjinerie aangekoop gewees het of is daar intussen masjinerie aangekoop ten einde die huidige terrein te kompakteer volgens die reël

c) is die Mun bewus daarvan dat naby Pacmar nog ‘n “ingang” na die terrein is? Onbeman uiteraard & wat word daaromtrent gedoen ten einde te keer dat die terrein nog vinniger vol raak. Daar lê vullis, bourommel ens tot teenaan die oewers van die Bergrivier, maar niemand gee blykbaar om

d) ek sal graag die reels & regulasies rondom die stort van vullis op ons terrein voor die 13de onder oë wil hê; ek vra dus ‘n kopie daarvan, asseblief.

2. Ek, so die res van Wellington, soek ‘n antwoord wat sin maak, oor hoekom Interwaste klaar gekontrakteer is ten spyte van die omstredenheid rondom hul werkswyse. Dat die “saak” nog nie uitgesorteer is & daarom kan niemand praat & dat ons nie oor die volle inligting beskik, soos op vorige sessies aan ons voorgehou, gaan nie weer water dra. Gee ons die inligting, die versekering, die bewyse; swart op wit.

3. Drakenstein kan nie die aanleg soos aan ons voorgehou as voorbeeld, bekostig; wat gaan Drakenstein vir Wellington gee? Gaan dit doeltreffend werk? Gaan dit die eerste keer wees dat ‘n aanleg in daardie vorm, in gebruik gestel gaan word & watter waarborg het ons dat dit hoegenaamd/doeltreffend gaan werk?

4. Wie in hierdie land, is bekwaam genoeg om die aanleg soos beplan asook Interwaste te monitor ten einde te sorg dat die aanleg reg werk, hulle nie kortpaaie neem & alles bo verdenking is? Is daardie persoon(e), maatskappy deel van die groter beplanning & wie is hulle?

5. Sou Interwaste nie sy kontrak nakom; wat is plan B?

52

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

6. Miljoene ton vullis gaan ons Vallei binnegery word, kort duskant die hart van die dorp & sy inwoners, ten bate van die geldkoffers van die Munisipaliteit & omdat, volgens die inligting aan ons deurgegee, Stellenbosch bv reeds nie meer plek het om vullis te stort. Gestel Interwaste se kontrak word vir watter rede ook al, gestaak, daar blyk geen ander maatskappy te wees wat dit kan/wil doen; wat word van Drakenstein se kontrakte met die ander Munisipaliteite? En wat word van daardie vullis?

7. Ek soek toetse, bewyse; navorsing wat bewys die “stoom” wat ons atmosfeer binne gestuur word, skadeloos & reukloos sal wees; swart op wit

8. Ons word op elke sessie subtiel gewaarsku/afgedreig, ja, afgedreig, dat ons belasting die hoogte in sal skiet sou die vullis weg gery moet word. Ek wil graag vra watter premie jy plaas op jou gesondheid & die ekonomiese welvaart van ons dorp, elke Sakeman se besigheid. Dis ‘n som wat vir my net 1 antwoord het; ek sal meer betaal as dit verseker dat ek gesond bly, my besigheid se voortbestaan nie bedreig word, my eiendomme se waarde nie tot nul verlaag word.

53

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

Lance du Toit, MD Akura

18 May 2015 Looks like the fun and games has started.

Am I on the notification list for the Drakenstein WtE EIA?

I have not received many notices yet or updates. I missed all the activities from Oct – Feb due to my medical drama.

What information are you able to share on this project,that has been made public to date? Is there access to it via the web?

Last question. I noted in the one correspondence that there is a 3rd alternative site in Klupmuts. What is the motivation for this? Did it come from Muni or Interwaste or Wellingtoners? Or is it to make the project more viable, by being closer to Stellenbosch and Cape Town? Ot is it just to have a 3rd site, and its not a serious consideration.

The Draft Scoping Report is on the RMS website under Projects – Current Projects. The third site comes about from the Drakenstein Municipality requesting a further alternative and also some verbal feedback from Stellenbosch Municipality that a site closer to Stellenbosch should be considered. Whether it is a feasible and reasonable alternative as the Regulations require will be confirmed as part of the screening assessments currently underway. NB: This is not a Regional Project but a Drakenstein Municipality project, where Interwaste is the applicant in terms of their broad waste management contract with DM. Confirmation that we have included Akura on the stakeholder database.

Lorna Smith 18 May 2015 Dear Sirs,

This project just adds another cog to the wheel and I suppose that our rates and taxes will pay for this???

We have a very serious problem in our neighborhoods with unemployed peoples taking our trash from our bins.

This is a) detrimental to our safety at home as these people lie in wait for drums and watch our movements. b) they push huge trollies in the streets and are a danger to traffic. c) the waste is then taken elsewhere and dumped - this is why there is so much waste lying around. Can we be assured that these problems will be addressed? So far letters to the Municipality have proven fruitless.

Confirmation that email was received. Comments noted and wil be responded to where practical during the assessment phase of the project.

54

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

Registration confirmed. Retha Grobbelaar – Sas Oosthuizen Wellington Landbou Vereniging

18 May 2015 As discussed in our telephone conversation, we would like to register I&AP as indicated below. Please confirm that we are on the database. Let me know if there is anything else you need from me.

Our Chairman Sas Oosthuizen will also contact you

Dear Sas

Probable EIA process timeline as provided to Die Burger is presented below. The mail also comments on questions that needed responses to. Specific dates cannot be committed due to the many activities that must take place during the EIA process.

1. At which stage/phase are you in the process at the moment? The Draft Scoping Report public consultation phase was concluded in February 2015. The Final Scoping Report is currently being prepared and will be circulated for public review either June or July 2015.

2. What studies still need to be done?

The Final Scoping Report will outline which studies are recommended. The following are likely to be necessary (NB: Subject to authority acceptance) a) Air Quality Impact Assessment (Atmospheric Emissions Licence required) b) Health Risk Assessment c) Social Impact Assessment (Scoping and Specialist phase) d) Economic Impact Assessment e) Traffic Impact Statement f) Noise Impact Assessment g) Heritage Impact assessment (Heritage Approval required) h) Major Hazardous Installation (MHI) Assessment i) Freshwater and Botanical Screening Assessments (work already completed as part of the Strategic Environmental Assessments for the areas within which all 3 alternative sites are located will be reviewed as necessary). j) Visual Impact Assessment These studies will be supported by the relevant Engineering, Technical and Operational Reports i.e. stormwater and effluent management etc.

55

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

3. When do you hope in finishing this project if all goes according to plan – Submit Final Environmental Impact Report to DEA Integrated Environmental Management (National Regulatory Authority) during first quarter of 2016.

4. What are the next steps in this process?

a) Circulation of Final Scoping Report for public and authority review and comment. b) Submission of Final Scoping Report to DEA Integrated Environmental Management (National Regulatory Authority) c) Acceptance of Final Scoping Report by DEA Integrated Environmental Management (National Regulatory Authority) d) Proceed with and complete Specialist Studies e) Prepare Draft Environmental Impact Report (DEIR) and circulate for public and authority review and comment f) Hold Public Open Day and Meetings as required g) Prepare Final Environmental Impact Report (FEIR) and circulate for public and authority review and comment h) Finalise FEIR for submission to DEA IEM and submit FEIR i) DEA review and assessment of FEIR - DEA IEM make final decision on issuing of required Waste Management Licence and Environmental Authorisation (Integrated Authorisation), Atmospheric Emissions Licence. j) DEA Decision made, issued and RMS communicates decision to all stakeholders k) Appeal Process. It is also hereby confirmed that you (Wellington Landbou Vereniging) are registered on the RMS database for the project.

Jeremy Wagner Diemersfontein Wine & Country Estate

18 May 2015 PLEASE REFER TO GENERAL COMMENTS ATTACHED Registration confirmed and comments noted. Please see Annexure A, Appendix D.

56

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

Lesley Armstrong 19 May 2015 To whom can I address concerns and questions re WTE as an I & AP? What is the due date for final objections?

RMS is facilitating the EIA process and therefore all comments etc must be submitted to ourselves. The Draft Scoping Report which is on the RMS website was available for public review and comment until early Feb 15. Please feel free to submit comments at any stage as the EIA process will probably only formally be completed during first quarter of 2016.

The next report, the Final Scoping Report should be released for public and authority review either June or July 15.

Confirmation that you are registered on the RMS database. Erika Odendaal, Pam Golding Properties (Pty) Ltd

19 May 2015 Please note that our community in Wellington feel that other sites should be investigated for this Programme. We object to it being in Wellington.

Dear Erika

Comment received.

Kim Benvenuto 19 May 2015 Can I please register as an interested and affected party for the above project. I a concerned resident in Wellington, and would like to be kept informed of all future happenings with this project. I would prefer to receive these by email, please.

Many thanks,

Dear Kim Thanks for the mail received. Registration as a stakeholder for the project is confirmed.

Cerkia Barnard 19 May 2015 Please note that we would like to be registered as Interested and Affected Parties to the Interwaste WTE project in Wellington.

Preferred form of communication is email. Cerkia Barnard [email protected]

Andre Barnard [email protected]

Is this all that is needed?

Thanks for mail – registration confirmed. No further information is required.

Wellington Community Forum

26 May 2015 Premier Zille, Minister Bredell, Burgemeester Van Deventer, Mnre Louw & Eichstadt,

Aangeheg vind asseblief Verklaring namens “Wellington Community Forum” wat vanself spreek met ook die skriftelike versoek om “Wellington Community Forum” as belanghebbende in die proses van die beoogde WTE aanleg in Wellington, te registreer.

Registration confirmed.

Please see Annexure A, Appendix D for declaration received.

57

Comments and Responses Table: INTERWASTE (Pty) Ltd Proposed Waste Recovery, Beneficiation and Energy Project, Drakenstein Municipality, Western Cape

Name Date received Comment Response Comments received on the Draft Scoping Report

Bruno Mattheeuws 21 June 2015 We are in a EIA stage and have appointed a consultant to manage such. Please register as a interested party so you can receive all relevant information. I have included the consultant in this mail. Kind Regards Leon Grobbelaar

Registration as an I&AP confirmed.