Port St Johns Waste Water Treatment Works, Eastern Cape

Port St Johns Waste Water Treatment Works, Eastern Cape

WETLAND IMPACT ASSESSMENT

Prepared for:

Prepared by:

EAST LONDON 25 Tecoma street

Berea, East London, 5201 043 726 7809

Also in Cape Town, Johannesburg, Grahamstown, Port Elizabeth and Maputo (Mozambique)

www.cesnet.co.za or www.eoh.co.za

October 2017

http://www.cesnet.co.za/

Wetland Impact Assessment

EOH Coastal & Environmental Services ii Port St Johns Waste Water Treatment Works

This Report should be cited as follows: EOH Coastal & Environmental Services, October 2017: Port St Johns Waste Water Treatment Works: Wetland Impact Assessment, EOH CES, East London.

REVISIONS TRACKING TABLE

EOH Coastal & Environmental Services

Report Title: Port St Johns Waste Water Treatment Works, Eastern Cape: Draft Wetland

Impact Assessment Report Version: Final Project Number: P40700128

Name Responsibility Date

Caitlin Smith Report writing October 2017

Dr Cherie-Lynn Mack External Reviewer October 2017

Copyright This document contains intellectual property and propriety information that are protected by copyright in favour of EOH Coastal & Environmental Services (EOH CES) and the specialist

consultants. The document may therefore not be reproduced, used or distributed to any third party without the prior written consent of EOH CES. The document is prepared exclusively for

submission to OR Tambo District Municipality, and is subject to all confidentiality, copyright and trade secrets, rules intellectual property law and practices of South Africa.


EOH Coastal & Environmental Services 1 Port St Johns Waste Water Treatment Works

TABLE OF CONTENTS 1 THE PROJECT TEAM AND EXPERTISE ............................................................................... 1

1.1 Details of specialist .......................................................................................................... 1 1.2 Expertise ......................................................................................................................... 1 1.3 Declaration ...................................................................................................................... 2

2 INTRODUCTION ..................................................................................................................... 1 2.1 Project overview and location .......................................................................................... 1

2.1.1 Project background ...................................................................................................... 1 2.1.2 Project description ....................................................................................................... 1

2.2 Alternatives ...................................................................................................................... 4 2.3 Public Participation .......................................................................................................... 1 2.4 Objectives and Terms of Reference (ToR)....................................................................... 1 2.5 Approach ......................................................................................................................... 1 2.6 Assumptions and Limitations ........................................................................................... 2

3 RELEVANT LEGISLATION .................................................................................................... 3 4 ASSESSMENT METHODOLOGY .......................................................................................... 4

4.1 Wetland Assessment ....................................................................................................... 4 4.2 Tools available to define wetlands and watercourses ...................................................... 6

4.2.1 National Freshwater Ecosystem Priority Areas (NFEPA) ............................................. 6 4.3 Tools available for wetland delineation ............................................................................ 7

4.3.1 DWAF (2005) wetland delineation ............................................................................... 7 4.4 Definition of estuarine systems ........................................................................................ 9 4.5 Hydrological health, geomorphological health and water quality ...................................... 9

4.5.1 Hydrology .................................................................................................................... 9 4.5.2 Geomorphology ........................................................................................................... 9 4.5.3 Water quality ................................................................................................................ 9

4.6 Impact assessment ........................................................................................................ 10 4.6.1 Impact rating methodology ......................................................................................... 10

5 DESCRIPTION OF THE BIOPHYSICAL ENVIRONMENT.................................................... 13 5.1 Desktop Investigation .................................................................................................... 13

5.1.1 Eastern Cape Biodiversity Conservation Plan (ECBCP) ............................................ 15 5.2 Site survey ..................................................................................................................... 17

6 SITE SENSITIVITY ............................................................................................................... 25 7 MANNER IN WHICH THE ENVIRONMENT MAY BE AFFECTED ....................................... 29 8 IMPACT STATEMENT, CONCLUSION & RECOMMENDATIONS ....................................... 44

8.1 Conclusions ................................................................................................................... 44 8.1.1 Alternatives ................................................................................................................ 44

8.2 Water Use Licence ........................................................................................................ 47 8.3 Recommendations for the proposed activity .................................................................. 48

8.3.1 Planning and Design .................................................................................................. 48 8.3.2 Construction .............................................................................................................. 48 8.3.3 Operation ................................................................................................................... 48

8.4 Environmental statement and Opinion of the Specialist ................................................. 49 9 REFERENCES...................................................................................................................... 50

LIST OF FIGURES Figure 1.1 Locality map of the proposed WWTW site alternatives.................................................................... 2 Figure 1.2 Locality map illustrating the location of the Town‟s existing non-functioning oxidation ponds. ....... 2 Figure 1.3 Illustration of the typical extended aeration activated sludge process. ............................................ 3 Figure 2.1 Treated Effluent Discharge Alternatives (indicated by white arrow). Potential irrigation areas are

indicated in yellow. ..................................................................................................................................... 6 Figure 2.2 Effluent discharge alternatives (discharge sites indicated by white arrow). ..................................... 7 Figure 2.3 Potential route of sewage pipeline to site 4B (indicated in yellow). ................................................. 8 Figure 5.1: Wetlands in the study area according to available literature (located within 500 m of any WWTW

infrastructure). .......................................................................................................................................... 14 Figure 5.2 Aquatic Critical Biodiversity Areas for the study area (ECBCP, 2007). ......................................... 16 Figure 5.3 Wetland system 1a and 1b (Also referred by locals as “Isikiligindi” Wetlands). ............................. 17 Figure 6.1 Wetland sensitivity map .................................................................................................................. 26



Figure 6.2 Sensitivity map surrounding site 3 and site 8 (potential discharge areas indicated by white arrow). ................................................................................................................................................................. 27

Figure 6.3 Sensitivity map surrounding site 4B (potential effluent discharge area indicated by white arrow). 28

LIST OF TABLES Table 2.1 Alternatives considered in this report ................................................................................................ 1 Table 2.2: Base data used and quality thereof .................................................................................................. 1 Table 3.1: Environmental legislation considered in the preparation of the Wetland Assessment..................... 3 Table 4.1 Ecosystem services provided by wetlands (Kotze et al., 2008). ....................................................... 5 Table 4.2. Significance Rating Table. .............................................................................................................. 11 Table 4.3 Impact Severity Rating. ................................................................................................................... 11 Table 4.4 Overall Significance Rating. ............................................................................................................ 12 Table 5.1. Wetland classification for the wetlands within the study area (according to available literature). .. 14 Table 7.1 below provides a summary of the potential risks identified and their applicability to each phase of

the proposed activity. ............................................................................................................................... 29 Table 7.2 Impacts and mitigation measures for the planning and design phase ............................................ 32 Table 7.3: Impacts and mitigation measures for the Construction Phase. ...................................................... 35 Table 7.4: Impacts and mitigation measures for the Operational Phase. ....................................................... 38 Table 7.6 No-go impact ................................................................................................................................... 42



1 THE PROJECT TEAM AND EXPERTISE In terms of Appendix 6 of the 2014 NEMA EIA Regulations (amended in 2017) a specialist report must contain- (a) Details of-

(i) The specialist who prepared the report; and (ii) The expertise of that specialist to compile a specialist report including a curriculum vitae;

(b) A declaration that the specialist is independent in a form as may be specified by the competent

authority;

1.1 Details of specialist Ms Caitlin Smith, Pr.Sci.Nat. (Report Writer and Aquatic Specialist) Senior Environmental Consultant. Caitlin holds a BSc degree with majors in Geology and Geography and a BSc Honours Degree (with distinction) in Geology both obtained from Nelson Mandela Metropolitan University. Caitlin is a qualified geologist and has managed and been involved in various Environmental Impact Assessments. Caitlin has completed various Aquatic and Wetland assessments for road and infrastructure projects. She is currently studying her MSc degree in Hydrology at Rhodes University focusing on the groundwater and surface water interactions of the Krom River wetlands. Wetland Training: Rhodes University, Tools for Wetland Assessment (certified competent). Dr Cherie-Lynn Mack, Pr.Sci.Nat. (External Reviewer) Cherie-Lynn holds a PhD and MSc (with distinction) degree in Environmental Biotechnology, with a BSc degree in Microbiology and Biochemistry. She has postgraduate research experience in industrial and domestic wastewater treatment technologies, with particular emphasis on the coal and platinum mining industries. Her interests lie in the water sector, with experience in ecological reserve determination and water quality monitoring and analysis. She has experience in water quality analysis and industrial wastewater treatment research. She has eight years of experience in environmental consulting, including assessment of potential impacts to aquatic environments caused by various development types.

1.2 Expertise Some of the projects Caitlin has worked on include:



Name of project Description of responsibility Date completed

Fort Cox Agricultural College Water and Sanitation Upgrades

Aquatic Assessment 2017

DAFF Qolora Aquaculture Development Zone

Wetland Study 2016

Buffalo City Metropolitan Municipality: Haven Hills Cemetery

Wetland Study 2016

SANRAL R56 Road Upgrade between Matatiele and the KZN Border

Aquatic and Wetland Study 2016

Element Molteno Sewerage Infrastructure

Aquatic Impact Assessment 2015

Lusikisiki Regional Water Supply Scheme

Aquatic Impact Assessment 2015

Element Kwatshatshu Pedestrian Bridge

Aquatic and Botanical Assessment 2016

Element Becclesfarm Bridge Aquatic and Wetland Study 2016

Senqu Pedestrian Bridge Aquatic Impact Assessment 2016

1.3 Declaration

I, Caitlin Smith, declare that, in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998), as amended and the Amended Environmental Impact Assessment Regulations, 2017;

I act as the independent specialist in this application;

I will perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant;

I declare that there are no circumstances that may compromise my objectivity in performing such work;

I have expertise in conducting the specialist report relevant to this application, including knowledge of the Act, Regulations and any guidelines that have relevance to the proposed activity;

I will comply with the Act, Regulations and all other applicable legislation;

I have no, and will not engage in, conflicting interests in the undertaking of the activity;

I undertake to disclose to the applicant and the competent authority all material information in my possession that reasonably has or may have the potential of influencing - any decision to be taken with respect to the application by the competent authority; and - the objectivity of any report, plan or document to be prepared by myself for submission to the competent authority;

All the particulars furnished by me in this report are true and correct; and

I realise that a false declaration is an offence in terms of regulation 48 and is punishable in terms of section 24F of the Act.



2 INTRODUCTION In terms of Appendix 6 of the 2014 NEMA EIA Regulations (amended in 2017) a specialist report must contain- (c) An indication of the scope of, and the purpose for which, the report was prepared; (cA) An indication of the quality and age of the base data used for the specialist report; (d) The duration, date and season of the site investigation and the relevance of the season to the outcome of the assessment; (i) A description of any assumptions made and any uncertainties or gaps in knowledge; (o) A description of any consultation process that was undertaken during the course of preparing the

specialist report; (p) A summary and copies of any comments received during any consultation process and where

applicable all responses thereto

2.1 Project overview and location 2.1.1 Project background OR Tambo District Municipality is proposing the development of a new waste water treatment works (WWTW) with a capacity of 3.5 Ml/day to serve the town of Port St Johns (PSJ). PSJ is currently serviced by a combination of septic tanks, conservancy tanks and pit latrines. Raw sewage is currently entering the Mzimvubu Estuary and possibly other watercourses in PSJ. Conservancy tanks in town are also overflowing into the streets. Sewage from conservancy tanks is collected by honeysuckers and discharged into existing non-funtioning oxidation ponds (Figure 1.2) about 360 m upslope of the Town‟s dam and Water Treatment Works. Various site options (up to 9 sites) have been discussed and site visits have been undertaken with stakeholders (DEDEAT, DWS, DAFF, etc.) and the PSJ Local Municipality (LM) over a number of years in order to identify available sites. 2.1.2 Project description The proposed WWTW sites that will be considered in the Basic Assessment Report (BAR) are indicated in Figure 1.1 below.



Figure 1.1 Locality map of the proposed WWTW site alternatives.

Figure 1.2 Locality map illustrating the location of the Town’s existing non-functioning oxidation ponds.



The proposed treatment option is an extended aeration activated sludge system. In the extended aeration system raw sewage is digested in a sealed, aerated biodigestor. The efficiency of treatment of an extended aeration system results in a higher quality effluent than a normal activated sludge process. Scope of works:

Construction of an inlet works (manual screening & de-grit channels); (effluent is screened for

large solids at inlet works which are placed in skips, disposed of with dried sludge)

Installation of flow measuring equipment;

Construction of a biological reactor (extended aeration);

Construction of 2 x clarifiers (sedimentation for sludge or suspended solids removal);

Construction of mechanical sludge dryer with skips for disposal (this is to keep the site footprint

as small as possible. Sludge drying beds require large areas, which means a larger footprint for

the site. Dried sludge to be disposed at the local landfill site, but can be used as fertiliser,

should there be interest in using it);

Construction and lining of 2 x maturation ponds / reed beds; (this is for tertiary treatment of

effluent)

Construction of a chlorination channel or UV disinfection (which is an alternative disinfection

method, although more expensive);

Final effluent discharge (Effluent discharged to DWS – General Standards).

Figure 1.3 Illustration of the typical extended aeration activated sludge process.



2.2 Alternatives The alternatives that will be considered in this report include the following:

WWTW location alternatives

Treated effluent discharge alternatives Both discharge to watercourses and irrigation/discharge to land is considered. Due to

the high rainfall in PSJ, however, it is unlikely that all effluent could be discharged to land or used for irrigation (some would be required to be discharged to watercourses).

Sewage reticulation alternatives Refer to table 2.1 below for an analysis of alternatives considered.



Table 2.1 Alternatives considered in this report

Alternative level Alternatives Advantages Disadvantages Reasonable and feasible

Further assessment

Comment

WWTW site alternatives

Fundamental alternative – property or location

Construction of a WWTW at the old military base waste water treatment works (site 3)

Construction will not directly impact on a wetland.

None YES YES These alternatives will be assessed further in the report.

Construction of a WWTW upslope of the Mzimvubu Estuary (site 4B)

None Construction activity may impact wetland.

YES YES

Construction of a WWTW at site 8

Construction will not directly impact a wetland.

None. YES YES

Effluent discharge alternatives

Fundamental alternative – property or location: Discharge from site 3

Discharge of treated effluent into the upper reaches of Bulolo River

No direct discharge into wetlands downstream

Treated effluent significantly diluted before it reaches wetland at Bulolo Estuary

Ineffective treatment of effluent/system failures could pollute downstream wetland

Increased water inputs into downstream wetlands may alter their hydrological and geomorphic integrity

YES YES This alternative will be assessed further in the report.




Further assessment

Comment

Discharge of treated effluent into a stream running into the upper reaches of the Mthumbane river

No direct discharge into wetlands at Mthumbane Estuary

Treated effluent significantly diluted by the time it reaches Mthumbane wetland

Ineffective treatment of effluent/system failures could pollute downstream wetland

Increased water inputs into downstream wetlands may alter their hydrological and geomorphic integrity (difficult to quantify this impact without available information on the current flows through these rivers)

YES YES

Discharge/irrigation of land adjacent to site 3

No direct discharge of effluent into the Bulolo or Mthumbane Rivers (not affecting wetlands)

No impact on wetlands.

YES YES

Fundamental alternative – property or location: Discharge from site 4B

Discharge of treated effluent into one of two possible watercourses >1km upstream of the Mzimvubu Estuary wetlands

No direct discharge of treated effluent into the wetland.

Treated effluent will be significantly diluted by the time it reaches the wetland

The wetland can further “purify”

Ineffective treatment of effluent/system failures could contaminate downstream wetlands


YES YES This alternative will be assessed further in the report.




Further assessment

Comment

treated effluent water before it reaches the Mzimvubu Estuary

Irrigation of cropfields near the Mzimvubu Estuary (upstream) with treated effluent

No direct discharge into wetlands and lower contamination risk of wetlands

None. YES YES

Fundamental alternative – property or location: Discharge from site 8

Discharge to a stream which runs into the Mthumbane River and wetlands

Treated effluent significantly filtered before it reaches the wetland (travels over a distance of about 1.6km)

Ineffective treatment of effluent/ system failure will contaminate downstream wetlands with faecal coliforms and high nutrient loading


YES YES These alternatives will be assessed further.

Discharge piped to stormwater infrastructure (along Second Beach Rd) routed through PSJ and is finally discharged at the mouth of the Mzimvubu Estuary

No direct impact on wetlands associated with estuaries.

None. YES YES

Discharge to land No direct impact to None. YES YES




Further assessment

Comment

in the grasslands on the ridge near site 8

wetlands.

Irrigation of golf course with treated effluent

No direct impact to wetlands

None. YES YES

Sewage reticulation alternatives

Incremental alternative –Sewage reticulation north of the Mzimvubu Estuary towards site 4B Refer to figure 2.3 below.

Above ground pipeline routed north of the Mzimvubu Estuary through the wetland to site 4B

Pipeline will follow existing road – lower disturbance during construction phase

Leaks can be easily detected and repaired

Risk of contamination of the wetland if pipeline is damaged (floods/vandalism, etc)

YES YES These alternatives will be assessed further in the report.

Below ground (trenched pipeline) routed through the wetland to site 4B

Less risk of contamination from leaks due to damage/ vandalism

Risk of destruction of wetland vegetation during trenching

Difficult to detect and repair leaks

YES YES

Below ground (directionally drilled) pipeline from the Mzimvubu bridge, under the wetland to site 4B

Lower risk of destruction of wetland vegetation

Lower risk of contamination due to damage/vandalism

Difficult to detect and repair leaks

YES YES

No-go impact This refers to the current status quo and the risks and impacts associated with it.

No construction of a WWTW in PSJ.

No risk of damage to wetlands during construction activity.

No risk of contamination of wetlands (due to ineffective

Continued contamination of the Mzimvubu Estuary that is possibly contaminating wetlands north of Mzimvubu Estuary (quantification of this

YES YES This alternative will be assessed further for each WWTW site.




Further assessment

Comment

treatment of effluent/ system failures)

and direct linkages are made difficult by tidal dynamics)



Figure 2.1 Treated Effluent Discharge Alternatives (indicated by white arrow). Potential irrigation areas are indicated in yellow.

Possible irrigation area


Possible irrigation areas (indicated in yellow)

Piped to stormwater infrastructure and routed through town

Bulolo River Mthumbane River



Figure 2.2 Effluent discharge alternatives (discharge sites indicated by white arrow).

Possible irrigation site



Figure 2.3 Potential route of sewage pipeline to site 4B (indicated in yellow).



2.3 Public Participation The Public Participation Process (PPP) followed to date has been described in detail in the Basic Assessment Report (BAR). No comments were received on the draft Wetland Impact Assessment Report.

2.4 Objectives and Terms of Reference (ToR) The ToR of this assessment is the following:

Provide a general description of the status of the wetlands in the area according to published literature;

Delineate identified wetland areas (based on desktop information and limited field work);

Provide Present Ecological State (PES) and Ecological Importance and Sensitivity (EIS) of affected wetlands (using available desktop PES and EIS data, if available);

Provide a sensitivity map and define and map no-go areas;

Provide an assessment of the potential direct and indirect impacts resulting from the proposed development on wetlands during construction and operation; and

Provide a detailed description of appropriate mitigation measures that can be adopted to reduce negative impacts for each phase of the project, where required, including appropriate recommendations.

2.5 Approach The proposed project area and surrounds were described using a two-phased approach. Firstly, a desktop assessment of the project area was conducted in terms of current surface water classifications and biodiversity programmes and plans. This included the consideration of the following base data:

Aquatic CBA classification according to the Eastern Cape Biodiversity Conservation plan (ECBCP, 2007)

The National Freshwater Ecosystem Priority Areas (NFEPA) project (2011 - 2014)

The National Wetland Classification System (NWCS) – SANBI (2009) The quality of the base data used for this specialist report has been described in Table 2.2 below. It should be noted that only datasets and base data relevant to the study area and affected environmental features have been discussed below. Table 2.2: Base data used and quality thereof

BASE DATASET DATA AGE

DATA QUALITY

Aquatic CBA classification according to the Eastern Cape Biodiversity Conservation plan (ECBCP).

2007 Aquatic CBAs were identified on the basis of sub-quaternary catchments, addressing the linkages between catchments, important rivers and sensitive estuaries. Priority areas were identified through a systematic conservation planning analysis. The data was compiled by Derek Berliner & Philip Desmet for the Department of Water Affairs and Forestry Project No 2005-012. The data is outdated and currently all the ECBCP shapefiles and supporting documentation is under review and in the process of being updated.

The National Freshwater Ecosystem Priority Areas (NFEPA) project

2011-2014

NFEPA was originally completed in 2011 and has recently (2014) been updated. FEPAs were determined through a process of systematic biodiversity planning and involved collaboration of over 100 freshwater researchers and practitioners. FEPAs were identified based on a



On completion of the desktop assessment a site visit was undertaken on 24th January 2017 and 24th May 2017. It is not expected that the seasonality will affect the outcome of the wetland assessment in this case.

2.6 Assumptions and Limitations The following limitations and assumptions are implicit:

The report is based on a project description provided by the engineers;

Descriptions of the natural environments are based on limited fieldwork and available literature;

A full wetland delineation and wetland health assessments have not taken place.

range of criteria dealing with the maintenance of key ecological processes and the conservation of ecosystem types and species associated with rivers, wetlands and estuaries, described in detail in the NFEPA Technical Report. The data was compiled by a large number of authors/specialists for the Water Research Commission of SA and is the most recent data available.

The National Wetland Classification System (NWCS)

2013 The NWCS uses hydrological and geomorphological traits to distinguish the direct factors that influence wetland function. This is presented as a 6 tiered structure with four spatially nested primary levels that are applied in a hierarchical manner between different wetland types on the basis of these direct factors. This Classification system has been commissioned by Freshwater Consulting Group (through SANBI). This data is the most recent data available.



3 RELEVANT LEGISLATION Environmental legislation relevant to the proposed activity is summarised in Table 3.1 below. Table 3.1: Environmental legislation considered in the preparation of the Wetland Assessment.

Title of Environmental legislation, policy or guideline

Implications for the project

Constitution Act (108 of 1996)

Obligation to ensure that the proposed development will not result in pollution and ecological degradation; and Obligation to ensure that the proposed development is ecologically sustainable, while demonstrating economic and social development.

National Environmental Management Act (NEMA) (107 of 1998)

The developer must apply NEMA principles, the fair decision-making and conflict management procedures that are provided for in NEMA. The developer must apply the principles of Integrated Environmental Management and consider, investigate and assess the potential impact of existing and planned activities on the environment, socio-economic conditions and the cultural heritage.

National Environmental Management: Biodiversity Act (Act 10 of 2004), and its subsequent amendments. NEMBA Alien and Invasive Species List (Government Notice 599 of 2014)

The proposed development must conserve endangered ecosystems and protect and promote biodiversity; Must assess the impacts of the proposed development on endangered ecosystems; No protected species may be removed or damaged without a permit; The proposed site must be cleared of alien vegetation using appropriate means.

National Water Act (36 of 1998) Regulations for Water Use Licence Applications (Government Notice No. 267 of 2017).

Provides details of measures intended to ensure the comprehensive protection of all water resources, including the water reserve and water quality. All necessary Water Use Licence Applications must be submitted to the Department of Water and Sanitation for approval (for construction over watercourses, within 500 m of a wetland, etc.)



4 ASSESSMENT METHODOLOGY In terms of Appendix 6 of the 2014 NEMA EIA Regulations (amended in 2017) a specialist report must contain- (e) A description of the methodology adopted in preparing the report or carrying out the specialised process

inclusive of equipment and modelling used;

4.1 Wetland Assessment

“Wetland” is a name given to a variety of ecosystems ranging from rivers, springs, seeps and mires in upper catchments, to midland marshes, pans and floodplains, coastal lakes, mangrove swamps and estuaries at the bottom of a catchment. These ecosystems all share the common primary driver of water and its prolonged presence is a fundamental determinant of soil characteristics, vegetation and animal life (DWAF, 2005). The National Water Act (Act No. 36, 1998 as amended in 2013) defines wetlands as: “Land which is transitional between terrestrial and aquatic systems where the water table is usually at or near the surface, or the land is periodically covered with shallow water, and which land in normal circumstances supports or would support vegetation typically adapted to life in saturated soil.” Thus wetlands must have one or more of the following characteristics:

Hydromorphic soils: characteristic soils of prolonged saturation;

Hydrophytes, at least occasionally: highly saturated plants; and

High water table: a high water table that results in saturation at or near the surface, leading to anaerobic conditions developing in the top 50 cm of the soil.

Wetlands are formed from a combination of geology, hydrology and topography. These landforms form in parts of a catchment where the movement of water is slowed down or obstructed, causing soil to become temporarily, seasonally or permanently waterlogged. Wetland Importance South Africa is a Contracting Party to the Ramsar Convention on Wetlands and has thus committed itself to the intergovernmental treaty, which provides the framework for the national protection of wetlands and the resources they could provide. The Ramsar Convention is the only global environmental treaty that deals with a particular ecosystem. The treaty was adopted in the Iranian city of Ramsar in 1971 and the Convention's member countries cover all geographic regions of the planet. Wetland conservation in South Africa is now driven by SANBI under the requirements of the National Environmental Management: Biodiversity Act (NEMBA, 10, 2004). In natural capital terms, wetlands may be seen as a significant economic investment. This monetary value is rooted to the fact that the primary tasks of a wetland are to process water and regulate runoff. This is important as the South African economy is heavily dependent on water and yet the climatic variability of the country has meant that for the most part rainfall occurs as intermittent, high intensity storms. The inherent value of wetlands is that they protect and regulate this water source by acting like sponges, soaking up water during flood events and releasing it during dry periods (DWAF, 2005). By regulating water flows during floods, wetlands may reduce flood damage and help prevent soil erosion. As natural filters wetlands help to purify water by trapping pollutants such as heavy metals and disease causing organisms. Wetlands protect surface waters from the problems of nutrient overload by removing the excess nutrients, some of which are taken up and used by wetland plants, and some of which are converted to less harmful chemical forms in the soil. The most common ecosystem services provided by wetlands (in general) are:



Improved water quality

Flood attenuation

Sediment trapping

Reduce number of water borne diseases

Herbal medicine

Water storage Table 4.1 Ecosystem services provided by wetlands (Kotze et al., 2008).

These ecosystem services are provided at very little cost but with significant payback for the South African economy. Despite being classified as the third most significant life support system on earth (IUCN, 1980), wetlands are some of the most threatened habitats in the world today. It has been reported that more than 50% of the wetland inventory in South Africa has disappeared. The main issues have been draining wetlands for crops and pastures, poorly managed burning and grazing resulting in headcut and donga erosion, planting alien invasive vegetation, mining, pollution and urban development. These have been significant as they alter the natural flow of water in wetlands and as water is the driver of wetland formation it follows that any changes would be damaging. A buffer around a wetland is usually recommended in order to protect the wetland from development in close proximity to it.



Aside from the negative impacts of construction in the vicinity of a watercourse or wetland, a major impact that needs to be considered should be the geotechnical competence of soil which is often waterlogged and prone to flooding. Wetland soils are usually high in clay and prone to wet and dry periods, allowing for expansion and contraction of soils. The wetland and watercourse buffers are therefore also important with regards to the demarcation of areas that are not suitable for construction due to the high soil moisture content and unstable soils. Developing solutions to these problems would be expensive and may not be sustainable in the long term.

4.2 Tools available to define wetlands and watercourses 4.2.1 National Freshwater Ecosystem Priority Areas (NFEPA) The NFEPA programme provides strategic spatial priorities for conserving South Africa‟s freshwater ecosystems and supports sustainable use of water resources. These priority areas are called Freshwater Ecosystem Priority Areas, or FEPAs. The system comprises a hierarchical classification process of defining a wetland based on the principles of the hydro-geomorphic (HGM) approach at higher levels, with structural features being included at the finer levels (SANBI, 2009). Wetland ecosystem types were used by NFEPA for representing natural examples of the diversity of wetland ecosystem types across South Africa. Wetlands of the same ecosystem type are expected to share similar functionality and ecological characteristics. The biodiversity target for freshwater ecosystems in South Africa is 20%, which means that we should keep at least 20% of each wetland ecosystem type in a natural or near-natural condition. This serves to conserve many common species and communities, and the habitats in which they evolve. Information used to classify wetlands as FEPAs included:

Ramsar status;

Known threatened frog and waterbird occurrences; and

Expert knowledge on biodiversity importance. The National Wetland Classification System (or Classification System for Wetlands and other Aquatic Ecosystems in South Africa) uses hydrological and geomorphological traits to distinguish the direct factors that influence wetland function. This is presented as a 6 tiered structure with four spatially nested primary levels that are applied in a hierarchical manner between different wetland types on the basis of these direct factors (SANBI, 2009).

Level 1: Distinguishes between marine, estuarine and inland ecosystems based on the degree of connectivity the systems have with the ocean.

Level 2: Categorises the regional wetland setting using a combination of biophysical attributes at the landscape level.

Level 3: Assesses the topographical position of inland wetlands.

Level 4: Concerns the hydrogeomorphic (HGM) units as defined as follows:

Landform - considering the shape and localised setting of the wetland;

Hydrological characteristics - nature of water movement into, through and out of the wetland; and

Hydrodynamics - the direction and strength of flow through the wetland. The HGM unit is considered the focal point for NWCS as the upper levels mean to classify the broad bio-geographical context for grouping functional wetland units at the HGM level, whilst the lower levels provide more descriptive detail. Wetland FEPAs were chosen based on significant specialist input that relates to information as diverse as crane breeding areas and protected frog habitats. As wetlands are formed under the influence of geology, hydrology and topography it is necessary to note these features when delineating a wetland.



Geology: Geology influences the formation of a wetland by geological obstructions such as erosion resistant rock or impervious material close to the surface forcing groundwater to move close to or onto the soil surface.

Hydrology: The water transfer mechanisms such as source, movement and exit are important features of a wetland.

Topography: The topography of the landscape influences the likelihood of whether a wetland will form. For instance, under the right conditions wetlands may form in floodplains, valley bottoms, hillslopes, depressions and coastal flats.

A range of „hydro-geomorphic‟ types can be defined by considering the above features. Six HGM units are defined for South African inland wetlands (SANBI, 2009):

Figure 4.1: The HGM types for South African Inland wetlands (SANBI, 2009).

4.3 Tools available for wetland delineation

The tools for wetland delineation are described below. Please note, however, that a comprehensive wetland delineation has not been undertaken. This should take place once a final WWTW site and discharge location has been chosen.

4.3.1 DWAF (2005) wetland delineation

The DWAF (2005) guidelines for “a practical field procedure for delineation of wetlands and riparian areas” are recommended in Gazette No. 19182, Notice No. 1091 of the National Water Act, 1998. This guideline explains the field indicators and methods for determining whether an area is a wetland or a riparian area, and how to find its boundaries. Although the primary driver of a wetland is water, due to its dynamic nature water is not a very useful parameter for identifying the outer boundary of a wetland. What is needed is a method of identifying the indirect indicators of prolonged saturation by water. This includes wetland plants (hydrophytes) and wetland (hydromorphic) soils. Their presence or absence implies the frequency and duration of saturation and is a satisfactory indicator to classify the area as a wetland (DWAF, 2005). In wetland delineation there are three zones which are distinguished according to a changing frequency of saturation. These are the permanent, seasonal and temporary zone. The primary objective of wetland delineation is usually to define the outer edge of the temporary zone as it marks the boundary between the wetland and the adjacent terrestrial zone. There are four important indicators that are used to define the boundaries of a wetland. The most important one is the soil wetness indicator with terrain unit, soil form and vegetation acting as confirmation. The point where wetland indicators are not present is regarded as the edge of the wetland.



The permanently wet zone is characterised by dark grey, clay soil, caused by a lack of oxygen required for the oxidation of minerals such as iron in the soil. The seasonally wet zone is characterised by grey soils with lots of orange and black mottles. It is generally recommended that there should be a 100m buffer zone between the edge of the delineated temporary zone and any development. Important indicators of each zone are as follows:

Wetland vegetation In order to tolerate the anaerobic conditions of seasonal or permanent flooding, hydrophytes (water loving plants) have evolved a number of adaptations. Their presence can therefore indicate a moist soil habitat and thus provide a potential boundary of a wetland‟s seasonally flooded or permanent flooded zones (Macfarlane et al., 2007).

o The temporary zone of a wetland will show mainly grasses, some woody species and

some sedges. o The seasonal zone will begin to show more hydrophytic (or water loving) sedges with

tall grasses (over 1m). o The permanent zone will be noticeable by emergent reeds and sedges, bulrushes or

floating and submerged plants. Woody species will have adaptations for permanent wetness such as prop roots (Mangroves).

Wetland soils Low oxygen levels result in a reduced rate of organic matter decomposition within the soil, where sulphur tends to exist in its reduced form, hydrogen sulphide (H2S), noticeable by its tell-tale rotten-egg smell. These conditions also serve as a catalyst for the metals in the soil to become soluble and begin leaching (DWAF, 2005). The metals produce rich colours of yellow, orange and reds.

o The temporary or seasonal zone of a wetland, where there is more seasonal flooding,

produces mottling of colours, as the metals are still in the process of precipitating. These mottles occur within a grey matrix where the metals have already leached.

o The permanent zone of a wetland, where there is more permanent flooding of the soil, produces leaching of metals, with soils remaining a grey (“gleyed”) colour.

o It is recommended by DWAF (2005) that soils be sampled on the surface (0-10cm) and between 40 and 50cm.

Figure 4.2: A cross-section through a wetland, indicating how the soil wetness and vegetation indicators change as one moves along a gradient of decreasing wetness, from the middle to the edge of the wetland (DWAF, 2005).



It should be noted that riparian systems that are not permanently or periodically inundated are not considered true wetlands, i.e. those associated with the drainage lines.

4.4 Definition of estuarine systems An Estuarine System is defined, in terms of Coastal Management Act (Act No. 24 of 2008), as a “body of surface water – (a) that is part of a water course that is permanently or periodically open to the sea; (b) in which a rise and fall of the water level as a result of the tides is measurable at spring tides when the water course is open to the sea; or (c) in respect of which the salinity is measurably higher as a result of the influence of the sea”. This is the definition that has been adopted for the NWCS. The NWCS (SANBI Classification System; 2009) does consider estuarine ecosystems to be wetlands, however, the NWA (1998) and the DWAF Delineation Manual (2005) does not include estuarine ecosystems in their description of wetlands.

4.5 Hydrological health, geomorphological health and water quality Changes to hydrological, geomorphological health and water quality of a wetland are briefly described below, as inputs of treated waste water could alter the hydrological or geomorphic integrity and water quality of a wetland. The existing sewage situation in PSJ could also have an effect on the water quality of wetlands. 4.5.1 Hydrology Hydrology is the defining feature of wetlands and therefore forms a key component of the assessment of wetland health. The hydrological conditions in a wetland affect many important processes, including the development of anaerobic conditions in the soil (waterlogging), availability of nutrients and other solutes and sediment fluxes. These factors strongly influence which fauna and flora will inhabit a wetland and this in turn has a feedback effect on hydrological conditions. The hydrology of a wetland can be altered through:

1. Human modifications to the wetland‟s catchment that change the quantity and timing of water inputs to the wetland.

2. Modifications taking place within the wetland that alter the distribution and retention patterns of water within the wetland.

Given the high demand for water in South Africa, which in global terms has low rainfall, decreased water inputs are far more widespread than increased inputs, except in urban areas where discharges (e.g. from sewage treatment plants) often increase inflows to wetlands (Macfarlane et al., 2009). 4.5.2 Geomorphology Changes in runoff characteristics alter the ability of water to lift, transport and deposit sediment, leading to erosion (increased discharge relative to sediment yield from catchments) or deposition (increased sediment yield relative to discharge) in the wetland (this is more applicable to non-floodplain wetlands). Those factors that increase water yield and peak flows are most likely to threaten geomorphic integrity (Macfarlane et al., 2009). 4.5.3 Water quality The „‟water quality” of wetlands refers to the concentration of dissolved salts (solutes) and of particulate (clastic) sediment.



It is recognised that the nature and level of solutes found in wetlands varies considerably from one wetland area to the next. Variation over time within a given wetland area may also be considerable, particularly in areas subject to high climatic variation. Solutes can be nutrients, but a variety can have toxic effects (e.g. xenobiotic compounds such as arsenic and salts such as sodium chloride or sodium carbonate). Solutes can be elevated unnaturally in wetlands through two principal means:

1. Importation from an external source into the wetland‟s catchment. 2. Concentration as a result of decreased throughflows in a wetland that would otherwise

have naturally flushed solutes out of the wetland. Imported solutes include those from both non-point sources (e.g. areas of fertilised crop or pasture land and areas where the density of houses with septic tanks or pit latrines exceeds 6 houses per hectare) and point sources (e.g. industrial outfalls, dairies, piggeries or feedlots) (Macfarlane et al., 2009).

4.6 Impact assessment 4.6.1 Impact rating methodology To ensure a direct comparison between various specialist studies, a standard rating scale has been defined and will be used to assess and quantify the identified impacts. This is necessary since impacts have a number of parameters that need to be assessed. Five factors need to be considered when assessing the significance of impacts, namely:

Relationship of the impact to temporal scales - the temporal scale defines the significance of the impact at various time scales, as an indication of the duration of the impact.

Relationship of the impact to spatial scales - the spatial scale defines the physical extent of the impact.

The severity of the impact - the severity/beneficial scale is used in order to scientifically evaluate how severe negative impacts would be, or how beneficial positive impacts would be on a particular affected system (for ecological impacts) or a particular affected party. The severity of impacts can be evaluated with and without mitigation in order to demonstrate how serious the impact is when nothing is done about it. The word „mitigation‟ means not just „compensation‟, but also the ideas of containment and remedy. For beneficial impacts, optimization means anything that can enhance the benefits. However, mitigation or optimization must be practical, technically feasible and economically viable.

The likelihood of the impact occurring - the likelihood of impacts taking place as a result of project actions differs between potential impacts. There is no doubt that some impacts would occur (e.g. loss of vegetation), but other impacts are not as likely to occur (e.g. vehicle accident), and may or may not result from the proposed development. Although some impacts may have a severe effect, the likelihood of them occurring may affect their overall significance.

Each criterion is ranked with scores assigned as presented in the tables below to determine the overall significance of an activity. The criterion is then considered in two categories, viz. effect of the activity and the likelihood of the impact. The total scores recorded for the effect and likelihood are then read off the matrix presented in the tables below, to determine the overall significance of the impact. The overall significance is either negative or positive.



The significance scale is an attempt to evaluate the importance of a particular impact. This evaluation needs to be undertaken in the relevant context, as an impact can either be ecological or social, or both. The evaluation of the significance of an impact relies heavily on the values of the person making the judgment. For this reason, impacts of a social nature need to reflect the values of the affected society.

Cumulative Impacts Cumulative impacts affect the significance ranking of an impact because the impact is taken in consideration of both onsite and offsite sources. For example, pollution making its way into a river from a development may be within acceptable national standards. Activities in the surrounding area may also create pollution which does not exceed these standards. However, if both onsite and offsite activities take place simultaneously, the total pollution level may exceed the standards. For this reason it is important to consider impacts in terms of their cumulative nature. Seasonality Although seasonality is not considered in the ranking of the significance, if may influence the evaluation during various times of year. As seasonality will only influence certain impacts, it will only be considered for these, with management measures being imposed accordingly (i.e. dust suppression measures being implemented during the dry season). Table 4.2. Significance Rating Table. Temporal Scale (The duration of the impact)

Short term Less than 5 years (many construction phase impacts are of a short duration).

Medium term Between 5 and 20 years.

Long term Between 20 and 40 years (from a human perspective almost permanent).

Permanent Over 40 years or resulting in a permanent and lasting change that will always be there.

Spatial Scale (The area in which any impact will have an affect)

Individual Impacts affect an individual.

Localised Impacts affect a small area of a few hectares in extent. Often only a portion of the project area.

Project Level Impacts affect the entire project area.

Surrounding Areas Impacts that affect the area surrounding the development

Municipal Impacts affect either the Local Municipality, or any towns within them.

Regional Impacts affect the wider District Municipality or the province as a whole.

National Impacts affect the entire country.

International/Global Impacts affect other countries or have a global influence.

Degree of Confidence or Certainty (The confidence with which one has predicted the significance of an impact)

Definite More than 90% sure of a particular fact. Should have substantial supportive data.

Probable Over 70% sure of a particular fact, or of the likelihood of that impact occurring.

Possible Only over 40% sure of a particular fact, or of the likelihood of an impact occurring.

Unsure Less than 40% sure of a particular fact, or of the likelihood of an impact occurring.

Table 4.3 Impact Severity Rating. Impact severity (The severity of negative impacts or how beneficial positive impacts would be on a particular affected system or affected party)

Very severe Very beneficial

An irreversible and permanent change to the affected system(s) or party(ies) which cannot be mitigated. For

A permanent and very substantial benefit to the affected system(s) or party(ies), with no real



example the permanent loss of land. alternative to achieving this benefit. For example the vast improvement of sewage effluent quality.

Severe Beneficial

Long term impacts on the affected system(s) or party(ies) that could be mitigated. However, this mitigation would be difficult, expensive or time consuming, or some combination of these. For example, the clearing of forest vegetation.

A long term impact and substantial benefit to the affected system(s) or party(ies). Alternative ways of achieving this benefit would be difficult, expensive or time consuming, or some combination of these. For example an increase in the local economy.

Moderately severe Moderately beneficial

Medium to long term impacts on the affected system(s) or party(ies), which could be mitigated. For example constructing the sewage treatment facility where there was vegetation with a low conservation value.

A medium to long term impact of real benefit to the affected system(s) or party(ies). Other ways of optimising the beneficial effects are equally difficult, expensive and time consuming (or some combination of these), as achieving them in this way. For example a „slight‟ improvement in sewage effluent quality.

Slight Slightly beneficial

Medium or short term impacts on the affected system(s) or party(ies). Mitigation is very easy, cheap, less time consuming or not necessary. For example a temporary fluctuation in the water table due to water abstraction.

A short to medium term impact and negligible benefit to the affected system(s) or party(ies). Other ways of optimising the beneficial effects are easier, cheaper and quicker, or some combination of these.

No effect Don‟t know/Can‟t know

The system(s) or party(ies) is not affected by the proposed development.

In certain cases it may not be possible to determine the severity of an impact.

Table 4.4 Overall Significance Rating. Overall Significance (The combination of all the above criteria as an overall significance)

VERY HIGH NEGATIVE VERY BENEFICIAL

These impacts would be considered by society as constituting a major and usually permanent change to the (natural and/or social) environment, and usually result in severe or very severe effects, or beneficial or very beneficial effects. Example: The loss of a species would be viewed by informed society as being of VERY HIGH significance. Example: The establishment of a large amount of infrastructure in a rural area, which previously had very few services,

would be regarded by the affected parties as resulting in benefits with VERY HIGH significance.

HIGH NEGATIVE BENEFICIAL

These impacts will usually result in long term effects on the social and/or natural environment. Impacts rated as HIGH will need to be considered by society as constituting an important and usually long term change to the (natural and/or social) environment. Society would probably view these impacts in a serious light. Example: The loss of a diverse vegetation type, which is fairly common elsewhere, would have a significance rating of

HIGH over the long term, as the area could be rehabilitated. Example: The change to soil conditions will impact the natural system, and the impact on affected parties (such as

people growing crops in the soil) would be HIGH.

MODERATE NEGATIVE SOME BENEFITS

These impacts will usually result in medium to long term effects on the social and/or natural environment. Impacts rated as MODERATE will need to be considered by society as constituting a fairly important and usually medium term change to the (natural and/or social) environment. These impacts are real but not substantial. Example: The loss of a sparse, open vegetation type of low diversity may be regarded as MODERATELY significant.

LOW NEGATIVE FEW BENEFITS

These impacts will usually result in medium to short term effects on the social and/or natural environment. Impacts rated as LOW will need to be considered by the public and/or the specialist as constituting a fairly unimportant and usually short term change to the (natural and/or social) environment. These impacts are not substantial and are likely to have little real effect. Example: The temporary changes in the water table of a wetland habitat, as these systems are adapted to fluctuating

water levels. Example: The increased earning potential of people employed as a result of a development would only result in benefits

of LOW significance to people who live some distance away.

NO SIGNIFICANCE

There are no primary or secondary effects at all that are important to scientists or the public. Example: A change to the geology of a particular formation may be regarded as severe from a geological perspective,

but is of NO significance in the overall context.

DON‟T KNOW

In certain cases it may not be possible to determine the significance of an impact. For example, the primary or secondary impacts on the social or natural environment given the available information. Example: The effect of a particular development on people‟s psychological perspective of the environment.



5 DESCRIPTION OF THE BIOPHYSICAL ENVIRONMENT In terms of Appendix 6 of the 2014 NEMA EIA Regulations (amended in 2017) a specialist report must contain- (f) Details of an assessment of a specific identified sensitivity of the site related to the proposed activity or

activities and its associated structures and infrastructure inclusive of a site plan identifying alternatives; (g) An identification of any areas to be avoided, including buffers; (h) A map superimposing the activity including the associated structures and infrastructure on the

environmental sensitivities of the site including areas to be avoided, including buffers;

5.1 Desktop Investigation Wetlands in South Africa have been mapped on a broad-scale by various stakeholders and have been included in the National Freshwater Ecosystem Priority Assessment (NFEPA, 2011-2014). Due to the broad-scale nature of the NFEPA map it is not spatially accurate and therefore some error is expected. The location of NFEPA wetlands was derived from the National Land Cover 2000 (Van Den Berg et al., 2008) and inland water features from the Department of Land Affairs‟ Chief Directorate: Surveys and Mapping (DLA-CDSM). All wetlands are classified as either „natural‟ or „artificial‟ water bodies. The NFEPA wetland map identifies important or sensitive wetlands and wetland clusters. A wetland cluster is a group of wetlands all within 1 km of each other and which are surrounded by relatively natural vegetation. The NFEPA wetlands listed in the study area and that fall within 500 m of the proposed infrastructure include the wetlands at the Mzimvubu, Bulolo and Mthumbane Estuaries (refer to the Estuary Impact Assessment Report for details on these estuaries). These wetland systems are located within the Estuarine Functional Zone (EFZ) and receive both freshwater and estuarine inputs (Figure 5.1). Additional delineated freshwater “dune slack wetlands” that were identified by a wetland specialist (Dr Brian Colloty) during a wetland study in 2016 are also indicated in Figure 5.1. It is unlikely that these dune slack wetlands would be affected by any of the proposed WWTW infrastructure. Refer to table 5.1 for a description of wetlands listed within the study area.



Figure 5.1: Wetlands in the study area according to available literature (located within 500 m of any WWTW infrastructure). Table 5.1. Wetland classification for the wetlands within the study area (according to available literature). Wetlands Level 3:

Landscape Unit

Level 4: HGM Unit

Landscape setting

HGM Type Wetland Type

Natural/ Artificial

NFEPA wetland condition (if available)/ PES

Present Ecological State (PES)

Ecological importance and sensitivity (EIS)

Wetland 1 (estuarine wetlands located within the floodplain of the Mzimvubu Estuary)

n/a n/a Estuarine Natural Z2 – heavily to critically modified.

Wetland 2 (delineated by Colloty, 2016). Referred to as “dune slack”.

Valley floor Unchannelled valley bottom

Indian Ocean Coastal Belt Unchannelled Valley Bottom Wetland

Natural (modified)

- C – moderately modified.

Moderate - high

Wetland 3 (delineated by Colloty, 2016). Referred to

Valley floor Unchannelled valley bottom

Indian Ocean Coastal Belt Unchannelled Valley Bottom Wetland

Natural - - -

Wet 1

Wet 2

Wet 3

Wet 4

Wet 5



Wetlands Level 3: Landscape Unit

Level 4: HGM Unit

Landscape setting

HGM Type Wetland Type

Natural/ Artificial

NFEPA wetland condition (if available)/ PES

Present Ecological State (PES)

Ecological importance and sensitivity (EIS)

as “dune slack”.

Wetland 4 (estuarine wetland at Mthumbane Estuary)

Estuarine Natural Z2 –heavily to critically modified

Wetland 5 (estuarine wetland at Bulolo/ Second Beach Estuary)

Estuarine Natural Z2 – heavily to critically modified

5.1.1 Eastern Cape Biodiversity Conservation Plan (ECBCP) The ECBCP is a first attempt at detailed, low-level conservation mapping for land-use planning purposes. Specifically, the aims of ECBCP were to map critical biodiversity areas through a systematic conservation planning process. The current biodiversity plan includes the mapping of priority aquatic features, land-use pressures, critical biodiversity areas and develops guidelines for land and resource-use planning and decision-making. The main outputs of the ECBCP are “critical biodiversity areas” or CBAs, which are allocated the following management categories: 1. CBA 1 = Maintain in a natural state 2. CBA 2 = Maintain in a near-natural state The ECBCP maps CBAs based on extensive biological data and input from key stakeholders. Although ECBCP is mapped at a finer scale than the National Spatial Biodiversity Assessment (Driver et al., 2005) it is still, for the large part, inaccurate and “course”. Therefore it is imperative that the status of the environment, for any proposed development MUST first be verified before the management recommendations associated with the ECBCP are considered (Berliner and Desmet, 2007). It is also important to note that in absence of any other biodiversity plan, the ECBCP has been adopted by the Provincial Department of Economic Development and Environmental Affairs (DEDEAT) as a strategic biodiversity plan for the Eastern Cape. As with terrestrial CBAs, aquatic CBAs are grouped into Biodiversity Land Management Classes (BLMCs). The ECBCP recommends limits (thresholds) to the total amount of land transformation that should be allowed in an ABLMC 1 and 2, if biodiversity is to be conserved. The goal is to maintain sufficiently large intact and well-connected habitat patches in each sub-quaternary catchment.



ABLMC CBA Code

Description of CBAs ABLMC Transformation Threshold

ABLMC 1 CBA1 Critically important river sub-catchments; Priority primary catchments for E1 estuaries

Less than 10 % of total area of sub-quaternary catchment

ABLMC 2a CBA2 Important sub-catchments, Primary catchment management areas for E2 estuaries.


ABLMC 2b CBA3 Catchments of free flowing rivers important for fish migration


The study area is located within a CBA 1 area linked with the Mzimvubu, Bulolo and Mthumbane Estuaries (Figure 5.2).

Figure 5.2 Aquatic Critical Biodiversity Areas for the study area (ECBCP, 2007).



5.2 Site survey Below is a description of the wetland systems based on the site assessments and consultation with local residents. Wetland system 1 in the Mzimvubu Estuarine Functional Zone (EFZ) was divided into “1a” and “1b” (Figure 5.3) in the photographs. The boundaries of the wetlands illustrated in Figure 5.3 is derived from available desktop information (including topographical data) and limited field work. Wetland system 1a would likely be more impacted by tidal changes and receive more regular estuarine inputs than wetland system 1b (mostly freshwater inputs).

Figure 5.3 Wetland system 1a and 1b (Also referred by locals as “Isikiligindi” Wetlands).



Wetland system 1:

Current impacts on this wetland system include:

Inhabitation by people – removal of wetland vegetation for construction of houses

Cultivation of crops within wetlands

Pollution (solid waste, possible sewage, possible groundwater pollution from septic tanks) – a river running through this wetland was sampled and indicated the presence of faecal coliforms (700 cfu/100ml). Quantification of this and direct linkages are difficult to determine.

Ecosystem services currently provided by this wetland system:

Fertile soils for cultivation of crops by locals

Locals make use of the streams running through the wetlands

Cleansing streams of pollutants before they flow into the Mzimvubu Estuary

Tourism/ recreational value (located within an existing tourism route)

Photographs of wetland system 1a:

Phragmites sp. (common reed) in wetland 1 a



Upstream view of a stream running through wetland 1a with Phragmites sp. in the background.

Coordinates: 31°35'32.38"S, 29°31'46.77"E

Downstream view of stream running through wetland 1a.



Photographs of wetland system 1 b:

Mielie plants in wetland 1 b

Coordinates: 31°35'40.35"S, 29°31'50.32"E

Coordinates: 31°35'36.60"S, 29°31'49.08"E



Typha capensis (bulrush)

Coordinates: 31°35'35.30"S, 29°31'48.97"E

Wet marshy area in wetland 1b. Coordinates: 31°35'42.20"S, 29°31'54.61"E.



Wetland 2: dune slack

Wetland 2 was considered as a possible site option for the WWTW in 2016 as it was thought to be an artificial wetland. A wetland study conducted by Dr Brian Colloty indicated that this wetland is not, however, suitable for development.

A dam wall has been created from tyres and sand bags and it was speculated that this dam wall resulted in the creation of the wetland. According to Colloty (2016), however, this wetland is a natural feature characterised by Typha capensis (Bulrushes) and Carex sp. (sedges). This wetland is not suitable for development and it is considered to be a unique coastal wetland only found in isolated areas associated with dune formations.

Coordinates: 31°38'1.89"S, 29°32'24.65"E

Dune slacks (wetland 2 and 3). No photographs available for wetland 3.



Wetland 4 - Mthumbane estuary:

Current impacts:

There is dense informal settlement within the valley through which the Mthumbane river flows, with likely pollution inputs into the river and ultimately the wetlands.

Ecosystem services provided by these wetlands:

Tourism/recreational value (located within an existing tourism route)



Wetland 5 at Bulolo Estuary

Current impacts on these wetlands:

Minor cattle grazing and trampling Ecosystem services provided:

Tourism/ recreational value (located within an existing tourism route). Tourists pass these wetlands to access “Bulolo Falls” along the Bulolo River.

Coordinates: 31°38'45.51"S, 29°30'58.06"E

Phragmites sp. (common reed) and sedges Coordinates: 31°38'45.69"S, 29°30'57.96"E

Wetland with sedges in the upper reaches of Bulolo Estuary



6 SITE SENSITIVITY In terms of Appendix 6 of the 2014 NEMA EIA Regulations (amended in 2017) a specialist report must contain- (f) Details of an assessment of the specific identified sensitivity of the site related to the proposed activity or

activities and its associated structures and infrastructure inclusive of a site plan identifying alternatives; (g) An identification of any areas to be avoided, including buffers; (h) A map superimposing the activity including the associated structures and infrastructure on the

environmental sensitivities of the site including areas to be avoided, including buffers;

A wetland sensitivity map (Figure 6.1 to 6.3 below) was developed based on desktop and site information gathered, and was classified into areas of high, moderate and low sensitivity. High Sensitivity

All wetlands All activities within high sensitivity areas must be closely monitored by a qualified ECO to ensure that all proposed mitigation measures are implemented to manage and minimize potential impacts on the wetlands. Moderate Sensitivity

Areas within 50 m of wetlands.

Moderate sensitivity areas act as buffers for the high sensitivity areas. Activities that may have an indirect impact on high sensitivity areas should, as far as possible, not occur in these areas. Such activities would include:

Stockpiling of topsoil, subsoil, etc.

Temporary ablution facilities

Site camp establishment

Temporary laydown areas for equipment/materials

Overnight parking of heavy machinery/vehicles.

Concrete batching Low Sensitivity

500 m buffer placed around wetlands (regulated by DWS: WULA trigger)



Figure 6.1 Wetland sensitivity map



Figure 6.2 Sensitivity map surrounding site 3 and site 8 (potential discharge areas indicated by white arrow).


Possible discharge areas indicated by white arrow

Piped to stormwater infrastructure and routed through town

Possible irrigation area indicated by yellow arrow or circles



Figure 6.3 Sensitivity map surrounding site 4B (potential effluent discharge area indicated by white arrow).




7 MANNER IN WHICH THE ENVIRONMENT MAY BE AFFECTED In terms of Appendix 6 of the 2014 NEMA EIA Regulations (amended in 2017) a specialist report must contain- (cB) A description of the existing impacts on the site, cumulative impacts of the proposed development

and levels of acceptable change; (j) A description of the findings and potential implications of such findings on the impact of the proposed

activity or activities; (k) Any mitigation measures for inclusion in the EMPr;

Impacts that could be a direct or indirect result of the proposed activity were identified for the Planning and Design, Construction and Operation Phase. These included the consideration of direct, indirect and cumulative impacts that may occur and also considers the no-go or existing impacts. Table 7.1 below provides a summary of the potential risks identified and their applicability to each phase of the proposed activity.

THEME APPLICABILITY TO EACH PHASE

Alternative PLANNING AND DESIGN

CONSTRUCTION OPERATION

Legal and policy compliance

All YES Non-compliance with the laws and policies of South Africa as they pertain to the wetland environment.

N/A N/A

Invasion of alien species

All site alternatives

YES Failure to plan for the removal and management of alien vegetation

YES Construction activities within/in close proximity to wetlands could result in translocation of alien species into the wetland areas.

N/A

Water quality All

YES Failure to plan for monitoring of final treated effluent quality

N/A N/A

Sewage reticulation to site 4B (through wetland area)


YES Inappropriate routing of the pipeline through the wetland to site 4B

YES Indiscriminate vegetation removal and encroachment into surrounding wetland areas

N/A


Below ground (directionally drilled) pipeline






from the north of the Mzimvubu Estuary, under the wetland to site 4B

Treated effluent discharge

Discharge from site 3

N/A N/A YES

Discharge of poorly treated effluent

Impact on hydrology and geomorphic integrity of wetlands due to increased water inputs

Discharge from site 4B


WWTW location

Site 3 N/A YES Encroachment into wetland areas and unnecessary vegetation removal

N/A

Site 4B

Site 8

Pipeline leaks at site 4B


N/A YES During the operational phase sewage pipeline leaks may result in contamination of wetlands.


Below ground (directionally drilled) pipeline from the north of the Mzimvubu Estuary, under the wetland to site 4B






Maintenance

N/A N/A YES Poor maintenance of WWTW infrastructure

Table 7.2 to Table 7.5 provides the impacts and rating scales according to the various phases of the proposed activity.



Table 7.2 Impacts and mitigation measures for the planning and design phase

PLANNING AND DESIGN PHASE

ISSUE/RISK ALTERNATIVE (if applicable)

DESCRIPTION OF IMPACT

NATURE OF IMPACT

SPATIAL SCALE

(EXTENT)

TEMPORAL SCALE

(DURATION)

CERTAINTY SCALE

(LIKELIHOOD)

SEVERITY/ BENEFICIAL

SCALE

SIGNIFICANCE PRE-

MITIGATION

MITIGATION MEASURES

SIGNIFICANCE POST-

MITIGATION

Legal and policy compliance

During the planning and design phase non-compliance with the legal requirements and policies of South Africa as they pertain to the wetland environment could lead to damage to wetlands, unnecessary delays in construction activities, and potentially criminal cases, based on the severity of the non-compliance, being brought against the proponent and his/her contractors.

DIRECT Study area Short term Probable Moderately severe

MODERATE NEGATIVE

All legal matters pertaining to permitting must be completed prior to any construction activity.

In particular, all necessary Water Use Licences must be in order for any construction activity within 500 m of a wetland.

It is recommended that once a final site has been chosen that a wetland specialist be appointed to complete a detailed wetland delineation prior to commencement of construction.

An Environmental Control Officer (ECO) must be appointed for the duration of construction activity.

LOW NEGATIVE


During the planning and design phase, failure to plan for the removal and management of

INDIRECT Study area Medium-term

Probable Moderately severe

MODERATE NEGATIVE

During the planning and design phase a Rehabilitation and Alien

LOW NEGATIVE






NATURE OF IMPACT

SPATIAL SCALE

(EXTENT)

TEMPORAL SCALE

(DURATION)

CERTAINTY SCALE

(LIKELIHOOD)


SCALE

SIGNIFICANCE PRE-

MITIGATION

MITIGATION MEASURES

SIGNIFICANCE POST-

MITIGATION

alien vegetation could result in the invasion of alien vegetation in wetland areas during the construction and operation phase. This would have an adverse impact on the aquatic ecosystem.

Vegetation Management Plan must be designed to reduce the establishment and spread of undesirable alien plant species.

Water quality During the planning and design phase failure to plan for monitoring of the quality of final treated waste water could result in contamination of wetlands that are downstream of discharge points during operation of the WWTW.

DIRECT INDIRECT CUMULATIVE

Study area, downstream

Long-term Possible Severe HIGH NEGATIVE

During the planning and design phase an effective water quality (surface and groundwater, if necessary) monitoring programme must be developed to ensure that the quality of treated waste water (discharged to land/watercourses) is suitable

LOW NEGATIVE

Routing of sewage reticulation to site 4B (through wetland area)

A. Above ground pipeline routed north of the Mzimvubu Estuary through the wetland to site 4B

During the planning and design phase inappropriate routing of the pipeline through the wetland to site 4B could result in destruction of the wetland during the construction phase and contamination during the operation phase (if there are leaks due

DIRECT INDIRECT

Study area Medium-term

Possible Severe HIGH NEGATIVE

If the pipeline is placed above ground or trenched it is recommended that as far as possible the route follows the existing road and avoids sensitive wetland vegetation.

If the pipeline is placed above

LOW NEGATIVE

B. Below ground (trenched pipeline) routed through the wetland to site 4B

Long-term Possible Severe HIGH NEGATIVE

LOW NEGATIVE






NATURE OF IMPACT

SPATIAL SCALE

(EXTENT)

TEMPORAL SCALE

(DURATION)

CERTAINTY SCALE

(LIKELIHOOD)


SCALE

SIGNIFICANCE PRE-

MITIGATION

MITIGATION MEASURES

SIGNIFICANCE POST-

MITIGATION

to vandalism/flooding in the wetland area)

ground or trenched it is recommended that it be encased in concrete or constructed using appropriate technology to prevent leaks or damage due to floods.

C. Below ground (directionally drilled) pipeline from the Mzimvubu bridge, under the wetland to site 4B

Short-term Possible Slight LOW NEGATIVE

No mitigation. LOW NEGATIVE



Table 7.3: Impacts and mitigation measures for the Construction Phase. CONSTRUCTION PHASE

ISSUE/RISK

ALTERNATIVE (if applicable)


NATURE OF IMPACT

SPATIAL SCALE (EXTENT)

TEMPORAL SCALE (DURATION)

CERTAINTY SCALE (LIKELIHOOD)

SEVERITY/ BENEFICIAL SCALE

SIGNIFICANCE PRE-MITIGATION

MITIGATION MEASURES

SIGNIFICANCE POST-MITIGATION


All WWTW sites and pipeline routes

During the construction phase construction activities within/in close proximity to wetlands could result in translocation of alien species into the wetland areas.

INDIRECT Study area

Medium-term Possible Moderately severe

MODERATELY NEGATIVE

During the construction phase a rehabilitation and alien vegetation management plan must be implemented (and monitored post-construction).

Alien plants within wetland ecosystems must be removed from the site through appropriate methods such as hand pulling, cutting etc. This must be done under the supervision of the ECO.

LOW NEGATIVE

Destruction of wetland vegetation

WWTW location: Site 3 (no wetlands adjacent to the site)

During the construction phase encroachment into wetland areas and unnecessary vegetation removal could result in the loss of wetland habitat.

INDIRECT CUMULATIVE

Localised Medium-term Possible Slight LOW NEGATIVE

No wetlands should be impacted by construction at this site.

LOW NEGATIVE

Site 4B Medium-term Possible Severe HIGH NEGATIVE

During the construction phase the wetland must as far as possible be avoided.

The construction footprint and route for construction vehicles must be clearly demarcated.

No vehicles and machinery should be parked in the wetland area.

LOW NEGATIVE



CONSTRUCTION PHASE

ISSUE/RISK



NATURE OF IMPACT






MITIGATION MEASURES


An ECO must be appointed for the duration of construction activity.

Site 8 (no wetlands adjacent to the site)

Medium-term Possible Slight LOW NEGATIVE

No wetlands should be impacted by construction at this site.

LOW NEGATIVE

Removal of wetland vegetation: Sewage reticulation to site 4B (through wetland area)


During the construction phase the indiscriminate removal of wetland vegetation and encroachment into surrounding wetland areas could result in loss of wetland habitat.

INDIRECT CUMULATIVE

Localised Medium-term Possible Moderately severe

MODERATE NEGATIVE

During the construction phase all wetland vegetation removal (if necessary) must take place under supervision of the Environmental Control Officer (ECO).

Concrete mixing and stockpiling of construction materials should not take place within 50 m of the wetland.

Removal of wetland vegetation must be avoided, as far as possible.

A Rehabilitation and Alien Vegetation Management Plan must be developed and implemented.

Removal of the alien invasive vegetation should be prioritised.

Vehicles and

LOW NEGATIVE



CONSTRUCTION PHASE

ISSUE/RISK



NATURE OF IMPACT






MITIGATION MEASURES


machinery should not encroach into areas outside/surrounding the project footprint.

A designated pipeline route must be marked out and surrounding areas avoided. This route should as far as possible follow the existing road.



MODERATE NEGATIVE

C. Below ground (directionally drilled) pipeline from the north of the Mzimvubu Estuary, under the wetland to site 4B

Possible Slight LOW NEGATIVE

LOW NEGATIVE



Table 7.4: Impacts and mitigation measures for the Operational Phase. ISSUE IMPACT NATURE OF

IMPACT SPATIAL SCALE

(EXTENT)

TEMPORAL SCALE

(DURATION)

CERTAINTY SCALE

(LIKELIHOOD)


SCALE

SIGNIFICANCE PRE-

MITIGATION

MITIGATION MEASURES

SIGNIFICANCE POST-

MITIGATION

Treated effluent discharge: Site 3


During the operation phase the release of poorly treated effluent into the environment (discharge/irrigation) could contaminate downstream wetlands with faecal coliforms and result in high nutrient loading

DIRECT INDIRECT


Medium-term


During the operation phase the quality of treated final waste water must be continuously monitored.

The use of treated waste water for irrigation/ discharge must conform to guidelines provided in the Department of Health‟s publication – Guide: Permissible Utilisation and Disposal of Treated Sewage Effluent.

LOW NEGATIVE


Moderately severe

MODERATE NEGATIVE Treated effluent significantly filtered before it reaches the wetland

LOW NEGATIVE


Slight NEGLIGIBLE-LOW

NEGLIGIBLE-LOW

Site 4B


Severe HIGH NEGATIVE

Wetland downstream is utilised by locals

MODERATE NEGATIVE



NEGLIGIBLE-LOW

Site 8


Moderately severe

MODERATE NEGATIVE Treated effluent significantly filtered before it reaches the wetland

LOW NEGATIVE

Discharge piped to strormwater infrastructure (along Second Beach Rd) routed through PSJ and is finally discharged at the mouth of the Mzimvubu Estuary


NEGLIGIBLE - LOW

Discharge to land in the grasslands


NEGLIGIBLE-LOW



ISSUE IMPACT NATURE OF IMPACT

SPATIAL SCALE

(EXTENT)

TEMPORAL SCALE

(DURATION)

CERTAINTY SCALE

(LIKELIHOOD)


SCALE

SIGNIFICANCE PRE-

MITIGATION

MITIGATION MEASURES

SIGNIFICANCE POST-

MITIGATION

on the ridge near site 8



NEGLIGIBLE-LOW

Treated effluent discharge: Site 3


During the operation phase the release of treated effluent (3.5 Ml/day) into watercourses (increased water input) could have an adverse effect on the hydrological and geomorphic integrity of downstream wetlands.

DIRECT INDIRECT


Long-term

Possible Moderately

severe MODERATE NEGATIVE

It is recommended that a portion of the treated effluent water produced is irrigated, discharged to land or re-used elsewhere to minimise the potential impact on the hydrology and geomorphology of downstream wetlands.

LOW NEGATIVE


Moderately severe

MODERATE NEGATIVE

LOW NEGATIVE



NEGLIGIBLE-LOW

Site 4B


Moderately severe

MODERATE NEGATIVE

LOW NEGATIVE



NEGLIGIBLE-LOW

Site 8


Moderately severe

MODERATE NEGATIVE

LOW NEGATIVE

Discharge piped to strormwater infrastructure (along Second Beach Rd) routed through PSJ and is finally discharged at the mouth of the Mzimvubu Estuary


NEGLIGIBLE - LOW

Discharge to land in the grasslands on the ridge near


NEGLIGIBLE - LOW




SPATIAL SCALE

(EXTENT)

TEMPORAL SCALE

(DURATION)

CERTAINTY SCALE

(LIKELIHOOD)


SCALE

SIGNIFICANCE PRE-

MITIGATION

MITIGATION MEASURES

SIGNIFICANCE POST-

MITIGATION

site 8



NEGLIGIBLE - LOW

Sewage pipeline leaks through wetlands below site 4B

A. Above ground pipeline routed north of the Mzimvubu Estuary through the wetland to site 4B

During the operational phase sewage pipeline leaks could result in contamination of wetlands.

INDIRECT CUMULATIVE

Localised Medium-term

Possible Moderately severe Leaks in an above ground pipeline can be identified and repaired faster.

MODERATE NEGATIVE

If any leaks are identified these must be repaired immediately. If the pipeline is placed above ground it should be concrete encased (or constructed using suitable technology to eliminate risk of leakage).

LOW NEGATIVE


Severe Leaks in a trenched pipeline are more difficult to identify.

HIGH NEGATIVE

If any leaks are identified these must be repaired immediately.

A trenched or directionally drilled pipeline must be constructed using suitable material that prevents any risk of damage or leakage.

MODERATE NEGATIVE

C. Below ground (directionally drilled) pipeline from the north of the Mzimvubu Estuary, under the wetland to site 4B

Severe Leaks in a trenched pipeline are more difficult to identify.

HIGH NEGATIVE

MODERATE NEGATIVE

Maintenance of sewage infrastructure

All During the operational phase if the sewage infrastructure (WWTW, pipelines and pump stations) is not regularly maintained and system failures are not repaired timeously this could lead to contamination of

INDIRECT CUMULATIVE

Localised Long-term Possible Severe HIGH NEGATIVE

During the operational phase sewage infrastructure must be maintained and pipelines checked for leaks on a regular basis.

If leaks or other system failures are identified or reported by the

LOW NEGATIVE




SPATIAL SCALE

(EXTENT)

TEMPORAL SCALE

(DURATION)

CERTAINTY SCALE

(LIKELIHOOD)


SCALE

SIGNIFICANCE PRE-

MITIGATION

MITIGATION MEASURES

SIGNIFICANCE POST-

MITIGATION

nearby or downstream wetlands.

public, immediate actions must be taken to repair the infrastructure.

Back-up generators to power the core elements of the WWTW must be installed prior to operation.

All personnel operating and maintaining the WWTW infrastructure must be appropriately trained.



Table 7.6 No-go impact ISSUE ALTERNATIVE IMPACT NATURE OF

IMPACT SPATIAL SCALE

(EXTENT)

TEMPORAL SCALE

(DURATION)

CERTAINTY SCALE

(LIKELIHOOD)


SCALE

SIGNIFICANCE PRE-

MITIGATION

MITIGATION MEASURES

SIGNIFICANCE POST-

MITIGATION

Status quo – No WWTW in PSJ.

Should the project not proceed then the current sewage situation in PSJ would remain the same:

No formal sewage treatment facility.

Raw sewage enters Mzimvubu Estuary and possibly other watercourses in the area.

Overflow of sewage from conservancy tanks and septic tanks.

Continued contamination of the Mzimvubu Estuary that is possibly contaminating wetlands within the floodplain of the Mzimvubu Estuary (quantification of this and direct linkages are made difficult by tidal dynamics). This could have adverse effects on the wetland environments which could continue to receive faecal coliforms and other nutrient inputs via upstream watercourses. This situation will worsen as the population and tourism increases in PSJ.

INDIRECT CUMULATIVE

Study area Long-term Possible Slight LOW NEGATIVE Difficult to quantify this impact without further investigations into water quality of the wetlands. Wetlands are also natural water purifiers and remove toxins in water. Excessive nutrient input in wetlands does, however, have an adverse effect on the wetlands habitat.

n/a LOW NEGATIVE

Wetlands at Bulolo Estuary and Mthumbane

Should the project not proceed then there would be no risk of destruction of wetland

INDIRECT CUMULATIVE

Localised Medium-term Probable Slightly beneficial

FEW BENEFITS

n/a FEW BENEFITS



ISSUE ALTERNATIVE IMPACT NATURE OF IMPACT

SPATIAL SCALE

(EXTENT)

TEMPORAL SCALE

(DURATION)

CERTAINTY SCALE

(LIKELIHOOD)


SCALE

SIGNIFICANCE PRE-

MITIGATION

MITIGATION MEASURES

SIGNIFICANCE POST-

MITIGATION

Estuary downstream of potential discharge points from site 3

habitats (due to construction activity) or contamination of wetlands (due to ineffective treatment of effluent/system failures)

Wetlands associated with Mzimvubu Estuary downslope of site 4B

Moderately beneficial

SOME BENEFITS

SOME BENEFITS

Wetlands at Mthumbane Estuary downstream of potential discharge points from site 8

Slightly beneficial

FEW BENEFITS

FEW BENEFITS



8 IMPACT STATEMENT, CONCLUSION & RECOMMENDATIONS In terms of Appendix 6 of 2014 NEMA EIA Regulations (amended in 2017) a specialist report must contain-

(I) Any conditions for inclusion in the environmental authorisation; (m) Any monitoring requirements for inclusion in the EMPr or environmental authorisation; (n) A reasoned opinion as to-

(i) whether the proposed activity, activities or portions thereof should be authorised; and (iA) regarding the acceptability of the proposed activity or activities, and (ii) If the opinion is that the proposed activity, activities or portions thereof should be authorised, any

avoidance, management and mitigation measures that should be included in the EMPr, and where applicable, the closure plan;

(q) Any other information requested by the competent authority.

8.1 Conclusions OR Tambo District Municipality (ORTDM) is proposing the development of a new waste water treatment works (WWTW) with a capacity of 3.5 Ml/day to serve the town of Port St Johns (PSJ). Three WWTW site alternatives are being considered in the draft BAR. EOH was appointed to conduct a Wetland Impact Assessment for the proposed project. This report provides input into the Draft Basic Assessment Report (DBAR) and Water Use Licence Applications (WULAs) for the project. HIGH pre-mitigation impacts relate to water quality, routing of the sewage pipeline through the wetland below site 4B, destruction of wetland habitat during construction, maintenance of WWTW infrastructure, sewage pipeline leaks and discharge of poorly treated effluent. These HIGH pre-mitigation impacts can be mitigated to MODERATE OR LOW post-mitigation impacts by application of appropriate mitigation measures. 8.1.1 Alternatives The alternatives that were considered in this report and the outcomes of the assessment of these alternatives are summarised below:

WWTW location alternatives (site 3, site 4B and site 8)

There is a higher risk of damage to a wetland habitat if the WWTW is constructed at site 4B. This is due to the fact that the access route to the site is located through the wetland.

The other WWTW site options (site 3 and 8) do not have wetlands close by and thus have lower risks associated with construction activity at these sites.

Treated effluent discharge alternatives Irrigation of land adjacent to site 3, irrigation of land adjacent to site 8, irrigation of the Golf

Course and irrigation of crop fields adjacent to the Mzimvubu Estuary all carry low to negligible pre-mitigation impact rating as these sites should not impact any downstream wetland system.

Discharge into the upper reaches of the Bulolo River and into the watercourses upslope of the Mzimvubu wetlands is rated as a high pre-mitigation impact (if effluent is of a poor quality).

Overall there is a higher risk of pollution to downstream wetlands if treated effluent is discharged into the Bulolo River or tributaries of the Mzimvubu Estuary (upslope of the Mzimvubu wetlands).



Sewage reticulation alternatives (to site 4B) During construction:

An above ground pipeline routed north of the Mzimvubu Estuary through the wetland to site 4B has a high and moderate pre-mitigation impact.

The trenched pipeline alternative has a high pre-mitigation impact for both impacts assessed.

A directionally drilled sewage pipeline is the least environmentally sensitive option during construction.

During operation:

A below ground (trenched) or directionally drilled pipeline has a high pre-mitigation impact (due to difficulty in identifying leaks).

An above ground pipeline is slightly less sensitive (moderate pre-mitigation impact) as it is easy to identify leaks and repair them.

Alternative Issue Pre-mitigation Post-mitigation

Location alternative

Site 3 Destruction of wetland vegetation during construction.

LOW NEGATIVE LOW NEGATIVE

Site 4B HIGH NEGATIVE LOW NEGATIVE

Site 8 LOW NEGATIVE LOW NEGATIVE

Reticulation through wetland to site 4B:

Sewage reticulation to site 4B through wetland area Planning and design phase

Above ground pipeline routed north of Mzimvubu Estuary through wetland to site 4B

Inappropriate routing of reticulation

HIGH NEGATIVE LOW NEGATIVE



Below ground (directionally drilled) pipeline from the Mzimvubu under the bridge to site 4B


Same as above Construction phase


Removal of wetland vegetation

MODERATE NEGATIVE

LOW NEGATIVE


HIGH NEGATIVE MODERATE NEGATIVE



Same as above Operational phase


Pipeline leaks MODERATE NEGATIVE

LOW NEGATIVE

Below ground HIGH NEGATIVE MODERATE



Alternative Issue Pre-mitigation Post-mitigation

(trenched pipeline) routed through the wetland to site 4B

NEGATIVE



Discharge alternatives:

Discharge from site 3:

Treated effluent discharge: Discharge into Bulolo River

Release of poorly treated effluent into the environment


Discharge into a tributary of Mthumbane River

MODERATE NEGATIVE

LOW NEGATIVE


NEGLIGIBLE-LOW

NEGLIGIBLE-LOW

Discharge from site 4B:

Discharge into one of two possible watercourses upslope of the Mzimvubu Estuary Wetlands


Irrigation of cropfields near the Mzimvubu Estuary (upstream)

NEGLIGIBLE-LOW

NEGLIGIBLE-LOW


Discharge to a tributary of Mthumbane River

MODERATE NEGATIVE

LOW NEGATIVE

Discharge piped to stormwater infrastructure and routed through PSJ town to the mouth of Mzimvubu Estuary

NEGLIGIBLE-LOW

NEGLIGIBLE-LOW

Discharge to land in the grasslands on the ridge near site 8

NEGLIGIBLE-LOW

NEGLIGIBLE-LOW

Irrigation of Golf Course

NEGLIGIBLE-LOW

NEGLIGIBLE-LOW

Discharge from site 3:

Treated effluent discharge: Discharge into Bulolo River

Impact on hydrological and geomorphic integrity of wetlands due to effluent discharge

MODERATE NEGATIVE

LOW NEGATIVE

Discharge into a tributary of Mthumbane River

MODERATE NEGATIVE

LOW NEGATIVE


NEGLIGIBLE-LOW

NEGLIGIBLE-LOW

Discharge from site 4B:

Discharge into one of two possible watercourses

MODERATE NEGATIVE

LOW NEGATIVE



upslope of the Mzimvubu Estuary Wetlands

Irrigation of cropfields near the Mzimvubu Estuary (upstream)

NEGLIGIBLE-LOW

NEGLIGIBLE-LOW


Discharge to a tributary of Mthumbane River

MODERATE NEGATIVE

LOW NEGATIVE

Discharge piped to stormwater infrastructure and routed through PSJ town to the mouth of Mzimvubu Estuary

NEGLIGIBLE-LOW

NEGLIGIBLE-LOW

Discharge to land in the grasslands on the ridge near site 8

NEGLIGIBLE-LOW

NEGLIGIBLE-LOW

Irrigation of Golf Course

NEGLIGIBLE-LOW

NEGLIGIBLE-LOW

NO-GO impact The no-go impact was considered and assessed for the proposed WWTW. Although it is expected that due to the lack of a formal sewage treatment facility in PSJ there are probably existing pollution inputs into watercourses (and downstream wetlands), it is difficult to quantify what this current impact is on wetlands. When considering the NO-GO impact (if the project does not proceed) it is clear there would be no risk to wetlands downstream of discharge points or close to the proposed WWTW sites (due to construction activity or contamination). This would be moderately beneficial for the wetlands downslope of site 4B (associated with the Mzimvubu Estuary), in particular.

8.2 Water Use Licence A Water Use Licence Application (WULA) is required for any construction activity within 500 m of a wetland in terms of the following triggers from the National Water Act (No. 36 of 1998):

Sec 21 (c) - impeding or diverting the flow of water in a watercourse;

Sec 21 (i) - altering the bed, banks, course or characteristics of a watercourse. The relevant WULAs must be obtained from the Department of Water and Sanitation prior to commencement of construction. The site 4B WWTW alternative would likely require a Full WULA due to its proximity to wetlands.



8.3 Recommendations for the proposed activity All the mitigation measures provided below are to be implemented in the Planning and Design, Construction and Operation Phases of the proposed activity. 8.3.1 Planning and Design

All legal matters pertaining to permitting must be completed prior to any construction activity.

In particular, all necessary Water Use Licences must be in order for any construction activity within 500 m of a wetland.

It is recommended that once a final site has been approved that a wetland specialist be appointed to complete a detailed wetland delineation prior to commencement of construction.

An Environmental Control Officer (ECO) must be appointed for the duration of construction activity.

During the planning and design phase a Rehabilitation and Alien Vegetation Management Plan must be designed to reduce the establishment and spread of undesirable alien plant species.

During the planning and design phase an effective water quality (surface and groundwater, if necessary) monitoring programme must be developed to ensure that the quality of treated waste water (discharged to land/watercourses) is suitable

If the pipeline (to site 4B from the Mzimvubu Bridge) is placed above ground or trenched it is recommended that as far as possible the route follows the existing road and avoids sensitive wetland vegetation.

If the pipeline (to site 4B from the Mzimvubu Bridge) is placed above ground or trenched it is recommended that it be encased in concrete or constructed using appropriate technology to prevent leaks or damage due to floods.

8.3.2 Construction

During the construction phase a rehabilitation and alien vegetation management plan must be implemented (and monitored post-construction).

Alien plants within wetland ecosystems must be removed from the site through appropriate methods such as hand pulling, cutting etc. This must be done under the supervision of the ECO.

During the construction phase the wetlands at site 4B must as far as possible be avoided.

The construction footprint and route for construction vehicles must be clearly demarcated.

No vehicles and machinery should be parked in the wetland area (at site 4B).

An ECO must be appointed for the duration of construction activity.

During the construction phase all wetland vegetation removal (if necessary) must take place under supervision of the Environmental Control Officer (ECO).

Concrete mixing and stockpiling of construction materials should not take place within 50 m of the wetland (site 4B).

Removal of wetland vegetation must be avoided, as far as possible.

Rehabilitation and Alien Vegetation Management Plan must be developed and implemented.

Removal of the alien invasive vegetation should be prioritised.

Vehicles and machinery should not encroach into areas outside/surrounding the project footprint.

A designated pipeline route must be marked out and surrounding areas avoided (pipeline through wetland to site 4B). This route should as far as possible follow the existing road.

8.3.3 Operation

During the operation phase the quality of treated final waste water must be continuously monitored.



The use of treated waste water for irrigation/ discharge must conform to guidelines provided in the Department of Health‟s publication – Guide: Permissible Utilisation and Disposal of Treated Sewage Effluent.

It is recommended that a portion of the treated effluent water produced is irrigated, discharged to land or re-used elsewhere to minimise the potential impact on the hydrology and geomorphology of downstream wetlands.

If any leaks are identified these must be repaired immediately. If the pipeline is placed above ground (to site 4B) it should be concrete encased (or constructed using suitable technology to eliminate risk of leakage).

If any pipeline leaks are identified these must be repaired immediately.

A trenched or directionally drilled pipeline (through the wetlands to site 4B) must be constructed using suitable material that prevents any risk of damage or leakage.

During the operational phase sewage infrastructure must be maintained and pipelines checked for leaks on a regular basis.

If leaks or other system failures are identified or reported by the public, immediate actions must be taken to repair the infrastructure.

Back-up generators to power the core elements of the WWTW must be installed prior to operation.

All personnel operating and maintaining the WWTW infrastructure must be appropriately trained.

8.4 Environmental statement and Opinion of the Specialist The wetland impacts of aspects considered for the PSJ WWTW were assessed and considered to be acceptable, provided that the mitigation measures provided in this report are implemented. All impacts are rated as MODERATE to HIGH pre-mitigation, therefore implementation of recommended mitigation measures coupled with comprehensive rehabilitation and monitoring in terms of re-vegetation and restoration is an important element of the mitigation strategy. Implementing the recommended mitigations measures will reduce impacts to MODERATE and LOW. It is important that a water quality monitoring programme be developed and implemented for the duration of the operational phase. Overall there is a higher risk to wetlands if site 4B is used compared to site 3 and site 8. If this site is approved by DEDEAT it is recommended that an ECO be appointed for bi-weekly site audits during the construction phase and that a strict water quality monitoring programme is put in place for the operational phase. Whichever site is authorised it is recommended that the option of irrigation and re-use of treated effluent (along with discharge to watercourses) be considered to reduce the volumes of water entering watercourses and potentially impacting downstream wetlands.



9 REFERENCES Colloty, B. (2016). Port St Johns WWTW: Draft Wetland Assessment. Department of Water Affairs and Forestry (2005). A practical field procedure for identification and delineation of wetlands and riparian areas. Guide: Permissible utilisation and disposal of treated sewage effluent (1978). Department of National Health and Population Development. Kotze, D., Marneweck, G., Batchelor, A., Lindley, D. and Collins, N. (2008) WET-Ecoservices: A technique for rapidly assessing ecosystem services supplied by wetlands. WRC Report TT 339/08. Macfarlane, D.M., Kotze D.C., Ellery, W.N., Walters, D., Koopman, V., Goodman, P., Goge, C., (2009).WET-Health: A technique for rapidly assessing wetland health. WRC Report TT 340/09, Water Research Commission, Pretoria National Environmental Management Act (No 107 of 1998) as amended. National Environmental Management: Biodiversity Act (No 10 of 2004). National Spatial Biodiversity Assessment (2004). National Water Act (No 36 of 1998) as amended. NFEPA Atlas, 2011 – 2014. SANBI (2009). Classification System for Wetlands and other Aquatic Ecosystems in South Africa. Technical Report for the National Freshwater Ecosystem Priority Areas project. The Constitution Act (108 of 1996).

Documents

Port St Johns Waste Water Treatment Works, Eastern Cape