FINAL BASIC ASSESSMENT REPORT - publicprocess.co.za

FINAL BASIC ASSESSMENT REPORT

Buck Kraal Dam Expansion:

Proposed Expansion of a Rehabilitated Farm Dam on

Farm 633, near Sunland, Sundays River Valley

Municipality (DEDEAT Ref: EC06/C/LN3/16/48-2021)

October 2021

Prepared for: JN Venter Family Trust PO Box 112 Kirkwood 6120 Prepared by: Sandy Wren, Marisa Jacoby and JP Hechter Public Process Consultants PO Box 27688, Greenacres, PE, 6057 120 Diaz Road, Adcockvale, PE 6001 Phone: 041 – 374 8426; Fax: 041 - 373 2002 Email: [email protected]

Buck Kraal Dam Expansion: Final Basic Assessment Report Table of Contents October 2021

TABLE OF CONTENTS

SECTION A: ACTIVITY INFORMATION ..................................................................................................... 1

1. ACTIVITY DESCRIPTION .................................................................................................................... 1

2. FEASIBLE AND REASONABLE ALTERNATIVES............................................................................... 6

3. ACTIVITY POSITION ............................................................................................................................ 9

4. PHYSICAL SIZE OF THE ACTIVITY .................................................................................................... 11

5. SITE ACCESS ...................................................................................................................................... 12

6. SITE OR ROUTE PLAN ........................................................................................................................ 12

7. SITE PHOTOGRAPHS ......................................................................................................................... 12

8. FACILITY ILLUSTRATION ................................................................................................................... 13

9. ACTIVITY MOTIVATION ...................................................................................................................... 13

10. APPLICABLE LEGISLATION, POLICIES AND/ OR GUIDELINES...................................................... 15

11. WASTE, EFFLUENT, EMISSION AND NOISE MANAGEMENT ......................................................... 15

12. WATER USE ......................................................................................................................................... 17

13. ENERGY EFFICIENCY ........................................................................................................................ 18

SECTION B: SITE/ AREA/ PROPERTY DESCRIPTION ............................................................................ 19

1. GRADIENT OF THE SITE .................................................................................................................... 19

2. LOCATION IN LANDSCAPE ................................................................................................................ 20

3. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE ........................................... 20

4. GROUNDCOVER ................................................................................................................................. 21

5. LAND USE CHARACTER OF SURROUNDING AREA ....................................................................... 32

6. CULTURAL/ HISTORICAL FEATURES ............................................................................................... 33

SECTION C: PUBLIC PARTICIPATION .................................................................................................... 35

1. ADVERTISEMENT ............................................................................................................................... 35

2. CONTENT OF ADVERTISEMENTS AND NOTICES ........................................................................... 38

3. PLACEMENT OF ADVERTISEMENTS AND NOTICES ...................................................................... 38

4. DETERMINATION OF APPROPRIATE MEASURES .......................................................................... 38

5. COMMENTS AND RESPONSES REPORT ......................................................................................... 42

6. AUTHORITY PARTICIPATION............................................................................................................. 42

7. CONSULTATION WITH OTHER STAKEHOLDERS............................................................................ 43

SECTION D: IMPACT ASSESSMENT ........................................................................................................ 44

1. ISSUES RAISED BY INTERESTED AND AFFECTED PARTIES ....................................................... 47

2. IMPACTS THAT MAY RESULT FROM THE PLANNING AND DESIGN, CONSTRUCTION, OPERATIONAL, DECOMMISSIONING AND CLOSURE PHASES AS WELL AS PROPOSED MANAGEMENT OF IDENTIFIED IMPACTS AND PROPOSED MITIGATION MEASURES .............. 48

3. ENVIRONMENTAL IMPACT STATEMENT ......................................................................................... 55

SECTION E: RECOMMENDATIONS OF PRACTITIONER ........................................................................ 56

SECTION F: APPENDICES ......................................................................................................................... 58

Appendix A: Site Plan ................................................................................................................................... 59

Appendix B: Photographs Taken from the Centre of the Site ...................................................................... 60

Appendix C: Facility Illustration(s) ................................................................................................................ 61

Buck Kraal Dam Expansion: Final Basic Assessment Report Table of Contents October 2021

Appendix D: Specialist Reports .................................................................................................................... 62

Appendix D (i): Aquatic Specialist Report .................................................................................................. 62

Appendix D (ii): Desktop Heritage Screening Report ................................................................................ 91

Appendix D (iii): Terrestrial Biodiversity Compliance Statement ............................................................... 112

Appendix E: Comments and Responses Report .......................................................................................... 128

Appendix F: Environmental Management Programme ................................................................................ 134

Appendix G: Other information ..................................................................................................................... 160

Appendix G(i) Site Notice Board and Newspaper Advertisement.............................................................. 160

Appendix G(ii) Database of I&APs ............................................................................................................. 161

Appendix G(iii) Correspondence Sent to I&APs and Authorities ............................................................... 162

➢ PROJECT ANNOUNCEMENT AND REGISTRATION PHASE ...................................................... 162 ➢ EMAIL: NOTICE OF INTENTION TO COMMENCE WITH BA PROCESS TO DEDEAT………….162 ➢ LETTER 1 TO I&APS – NOTICE OF BASIC ASSESSMENT ......................................................... 164 ➢ EMAIL TO I&APS – LETTER 1: NOTICE OF BASIC ASSESSMENT ............................................ 166 ➢ COMMENT FORM MAILED WITH LETTER 1 ................................................................................ 168 ➢ BACKGROUND INFORMATION DOCUMENT MAILED WITH LETTER 1 .................................... 169 ➢ CORRESPONDENCE SENT DURING THE CONSULTATION BASIC ASSESSMENT REPORT

REVIEW ........................................................................................................................................... 175 ➢ SUBMISSION OF THE APPLICATION FORM TO DEDEAT .......................................................... 175 ➢ LETTER 2: NOTIFICATION OF SUBMISSION OF CBAR TO DEDEAT ........................................ 177 ➢ LETTER 2: NOTICE OF CBAR REVIEW PERIOD TO ALL I&APs ................................................ 179 ➢ EMAIL SENT OT ALL I&APs ........................................................................................................... 181 ➢ COMMENT FORM SENT WITH LETTER 2 .................................................................................... 183 ➢ LETTER 2: EMAIL AND COPY OF THE CBAR SENT TO SELLO MOKHANYA – EASTERN CAPE

PROVINCIAL HERITAGE RESOURCES AUTHORITY .................................................................. 184 ➢ LETTER 2: EMAIL AND COPY OF THE CBAR SENT TO CHARLENE BISSET – SOUTH AFRICAN

NATIONAL PARKS .......................................................................................................................... 187

Appendix G(iv) Correspondence from I&APs & Authorities ....................................................................... 190

Appendix G(v) EAPs CV ............................................................................................................................ 197

Appendix G(vi) Authority Contact Details. .................................................................................................. 200

Appendix G(vii) Details of Specialists and Declaration of Interest ............................................................. 201

➢ Terrestrial Biodiversity Specialist ..................................................................................................... 201 ➢ Aquatic Specialist ............................................................................................................................ 217 ➢ Heritage Specialist ........................................................................................................................... 223 ➢ Dam Design Specialist ..................................................................................................................... 232

Appendix G (ix): Supporting Documentation .............................................................................................. 237

➢ Water Use Entitlements from the LSRWUA .................................................................................... 237 ➢ Specialist Impact Assessment Methodology ................................................................................... 238

Buck Kraal Dam Expansion: Final Basic Assessment Report Abbreviations October 2021

ABBREVIATIONS

CARA Conservation of Agricultural Resources Act

CBA Critical Biodiversity Area

CBA Report Consultation Basic Assessment Report

CEMPr Construction Phase Environmental Management Programme

DAFF Department of Agriculture, Forestry and Fisheries

DEA National Department of Environmental Affairs

DEDEAT Provincial Department of Economic Development, Environmental Affairs and Tourism

Draft CBA Report Draft Consultation Basic Assessment Report

DWS Department of Water and Sanitation

EA Environmental Authorisation

ECBCP Eastern Cape Biodiversity Conservation Plan

EIA Environmental Impact Assessment

EIS Ecological Importance and Sensitivity

EMPr Environmental Management Programme

ESA Ecologically Sensitive Area

FBA Report Final Basic Assessment Report

FEPAs Freshwater Ecosystems Priority Areas

FSR Final Scoping Report

I&AP Interested and Affected Party

LSRWUA Lower Sundays River Water Users Association

NBA Nation Biodiversity Assessment (2011)

NEMA National Environmental Management Act (Act 107 of 1998), as amended

NEMAA National Environmental Management Amendment Act (Act 107 of 1998)

NFEPA National Freshwater Ecosystem Priority Areas

NHRA National Heritage Resources Act (Act 25 of 1999)

NPAES National Protected Areas Expansion Strategy

OEMPr Operational Phase Environmental Management Programme

PES Present Ecological State

PoS Plan of Study

SABIF South African Biodiversity Information Facility

SAHRA South African Heritage Resources Agency

SDF Spatial Development Framework

SEA Strategic Environmental Assessment

SRVM Sundays River Valley Municipality

STEP Subtropical Thicket Ecosystem Project

ToR Terms of Reference

Buck Kraal Dam Expansion: Final Basic Assessment Report Executive Summary October 2021

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KEY CHANGES FROM THE CBAR TO THE FBAR

As per the correspondence from the Department of Economic Development, Environmental Affairs

and Tourism (DEDEAT), dated 15 September 2021 (point 3.4.2), amendments to the Final BAR (key

changes) from the Consultation BAR are outlined in the table below and are indicated in the body of

the report by means of underlining.

General changes from the CBAR to the FBAR e.g., Consultation Report to Final Report and

associated date changes, have not been indicated with underlining. These changes have been

made to all relevant Sections, Chapters and Appendices of the FBAR.

SECTION CHANGES

Executive Summary

• Page iv – update on the submission of the FBAR to DEDEAT for their decision-making.

Report

• Page 36 – update on database maintenance for review of the CBAR.

• Page 39 – update on phase of assessment

• Page 40 – update on submission of the Application Form for Environmental Authorisation and the review of the CBAR.

• Page 40-41 – update on public participation during CBAR review

• Page 41 – update on phase of assessment as well as submission of FBAR

• Page 42 – compliance with POPIA

• Page 47-48 – update summary of issues raised by I&APs and responses provided by the EAP

Appendix E • Update on the Comments and Responses Report during the review of the CBAR.

Appendix G(iii) • Inclusion of copies of correspondence to I&APs, Authorities and DEDEAT regarding

the comment period on the CBAR and the submission of the Application Form to the competent authority, as well as proof of delivery of reports to Authorities.

Appendix G(iv) • Inclusion of copies of correspondence received from DEDEAT regarding the

submission of the Application Form and the CBAR.

• Inclusion of copies of correspondence from I&APs.


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EXECUTIVE SUMMARY

INTRODUCTION

The applicant, the JN Venter Family Trust, proposes to expand a farm dam on Farm 633, referred to as Buck Kraal, measuring ~31ha in extent, near Sunland, in the Sundays River Valley Municipality. It is proposed that the dam, which has a current storage capacity of ~6 521m3 (footprint of ~1.56ha), be expanded by ~39 413m3 (~0.55ha), to have a total storage capacity of ~45 934m³

(~2.1ha). Farm 633 is zoned as Agriculture I and the remainder of the farm has been planted with citrus. The existing dam is proposed to be expanded into an area which is currently modified, but undeveloped. On 12 September 2019 an application was submitted to the Department of Economic Development, Environmental Affairs and Tourism (DEDEAT) Sarah Baartman Region, on behalf of the JN Venter Family Trust, for the proposed expansion of an existing farm balancing dam on Farm 633. The Final Basic Assessment Report (FBAR) was submitted to DEDEAT, for their decision-making, on 22 October 2019. However, prior to receipt of an environmental authorisation, the applicant commenced with activities on site associated with the expansion of the dam. DEDEAT indicated on 13 December 2019 that the original application for environmental authorisation would therefore be closed, and the matter was handed over to the DEDEAT Compliance and Enforcement Division. The applicant subsequently undertook a rehabilitation process to restore the dam to its original capacity, in line with a rehabilitation plan that had been approved by DEDEAT. DEDEAT has approved the rehabilitation of the dam and the docket has been closed by the Compliance and Enforcement Division. The applicant is therefore submitting a new application for Environmental Authorisation to DEDEAT for the expansion of the rehabilitated dam. Farm 633 is located north of the R336 (Kirkwood/ Addo Road) and ~3.3km North-West of Sunland (as the crow flies). Access to the farm is gained by travelling west on the R336, past Sunland, for a distance of ~3.9km, before turning right onto a gravel road and continuing east for a distance of ~1.5km. The nearest boundary of the Addo Elephant National Park is located ~8.6km east of Farm 633. In terms of the NEMA EIA Regulations 2014 (as amended), published in GN R326, 327, 325 and 324, promulgated under Chapter Five of the National Environmental Management Act (Act 107 of 1998) (NEMAA), and published in Government Gazette 40772 on the 7 April 2017, the project requires a Basic Assessment (BA), because it triggers the following listed activity, in Listing Notice 3 (GN R324):

“16. The expansion of reservoirs, excluding dams, where the capacity will be increased by more than 250 cubic metres. a. Eastern Cape i. Outside urban areas: (hh) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from the core area of a biosphere reserve; or…” Public Process Consultants has been appointed by the applicant as the independent Environmental Assessment Practitioners (EAP) to undertake the Basic Assessment, including Public Participation for the project. PROJECT DETAIL

Farm 633, measures ~31ha in extent and is zoned Agriculture I. The rehabilitated farm dam is located in the north-western corner of the property, has a capacity to store ~6 521m³ of water from the Lower Sundays River Water Users Association (LSRWUA) canal system, a footprint of ~1.56ha and a wall height of 4.7m. A manager’s house and storage / maintenance sheds are located near the entrance to the farm, in the south-western corner of the property. Citrus orchards have been established on the remainder of the farm. Irrigation water flows under gravity directly from the LSRWUA system, via an offtake canal, into the existing rehabilitated dam. The area that has been modified by the rehabilitation of the dam is proposed to be utilised for the expansion of the footprint, therefore no intact areas are proposed for clearance. It is proposed that existing Eskom infrastructure on the farm will be used to supply the proposed pumpstation with sufficient electricity supply. A new mainline outlet pipe (250mm) will be installed into the expanded dam to supply irrigation water to the adjacent orchards via internal irrigation pipelines of varying diameters (between 50mm and 250mm). The Sundays River flows adjacent to the eastern boundary of Farm 633, however, the proposed expansion footprint is located ~500m from the edge of the Sundays River riparian floodplain and no development is proposed on or near the banks thereof. Based on the outcome of the specialist assessments and technical input as well as input received during the consultation process, the project will entail the clearing and excavating of a portion of Farm 633 for the expansion of the farm dam. It is proposed that the dam be expanded as follows:

• Details of the existing dam (rehabilitated dam)


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o Capacity in cubic metres: 6 521m3 o Dam footprint in square metres: 15 643m2 (~1.56ha) o Dam wall height in metres: 4.7m

• Details of the proposed expansion o Expansion of capacity in cubic metres: 39 413m3 o Expansion of footprint in square metres: 5 522m2 (0.55ha) o Increase in wall height in metres: 1.2m

• Details of the total expanded dam o Total expanded capacity in cubic metres: 45 934m3 o Total expanded footprint in square metres: 21 165m2 (2.11ha) o Final wall height: 5.9m

The Final Basic Assessment Report (FBAR) provides more detail on the proposed project components which are indicated in the Facility Illustration Drawing attached as Appendix C. Pre-construction Phase

Prior to commencement with construction activities on the farm, the detailed design drawings for the proposed expansion of the existing dam and associated infrastructure, must be finalised. Construction Phase It is anticipated that the proposed construction phase will entail the following activities:

• Existing dam will be drained prior to expansion and allowed to dry out completely.

• Existing south-western wall will be demolished and will be rebuilt during the proposed expansion

• Topsoil to be excavated and temporarily stockpiled onsite during the construction phase

• Installation of a plastic membrane to line the dam basin and walls, to ensure impermeability.

• Excavated topsoil to be used after expansion along with indigenous vegetation to rehabilitate the proposed dam walls in order to manage potential erosion.

• The existing offtake canal to be lined with cement.

• The overflow will be relocated north- and westwards, which will increase the capacity of the dam, and will be lined with cement to reduce erosion.

• Construction of a pumphouse on the southern dam wall

• Installation of an outlet irrigation pipeline with an internal diameter of ~250mm connecting to existing internal irrigation infrastructure.

Operational Phase Water will be supplied to the existing dam from the Lower Sundays River Water Users Association canal system located adjacent to the north-western boundary of Farm 633, wherefrom it will be pumped into the surrounding citrus orchards for irrigation purposes via pipelines of varying diameters. Irrigation water will flow under gravity directly into the dam via a cement offtake canal from the LSRWUA canal system. A new mainline outlet pipe will be installed into the expanded dam to supply irrigation water to the existing orchards via internal irrigation pipelines of varying diameters. The internal diameter of the new mainline outlet pipe will be ~250mm, while the internal irrigation pipelines will vary between 50mm and 250mm. Subsequent to the completion of the proposed dam expansion, the new dam will store water to irrigate ~31ha of citrus orchards, (23ha on Farm 633 and 8ha on Portion 87 of Farm 558) predominantly for the local market but also for the export market. Appendix G(ix) of the FBAR includes confirmation of scheduled water use entitlements for Farm 633 and Portion 87 of Farm 558, from the LSRWUA. BASIC ASSESSMENT PROCESS AND PUBLIC PARTICIPATION

In terms of the NEMA EIA Regulations 2014 (as amended), published in GN R326, 327, 325 and 324, promulgated under Chapter Five of the National Environmental Management Act (Act 107 of 1998) (NEMAA), and published in Government Gazette 40772 on the 7 April 2017, the project requires a Basic Assessment (BA), because it triggers the following listed activity, in Listing Notice 3 (GN R324):

“16. The expansion of reservoirs, excluding dams, where the capacity will be increased by more than 250 cubic metres. a. Eastern Cape i. Outside urban areas: (hh) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from the core area of a biosphere reserve; or…”


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This listed activity requires authorisation from the Department of Economic Development, Environmental Affairs and Tourism (DEDEAT). The BAR needs to show the competent authority, DEDEAT (Sarah Baartman Region), as well as the project applicant, the JN Venter Family Trust, what the consequences of their choices will be in biophysical, social and economic terms. Public participation forms an important component of this process, by assisting in the identification of issues and alternatives to be evaluated, and, together with specialist input, assists the competent authority with their decision-making. The BA Process is currently at the stage where the Final Basic Assessment Report has been submitted to the competent authority. No comment period is proposed for the FBAR. All Interested and Affected Parties will be notified of the submission to the competent authority as well as the outcome of the decision-making process. SPECIALIST STUDIES

The following specialist studies have been undertaken as part of the BA Process in order to inform the FBAR:

• Aquatic Specialist Assessment

• Desktop Heritage Screening Report (Archaeology and Palaeontology)

• Terrestrial Biodiversity Compliance Statement The specialist studies are included in Appendix D (i) – D (iii) of the FBAR. ENVIRONMENTAL IMPACT STATEMENT

The proposed expansion of the existing farm dam is anticipated to have an overall LOW NEGATIVE impact on the receiving environment during the construction phases, if all the recommended mitigation measures are applied. In the operational phase, the overall impact is VERY LOW NEGATIVE to NEUTRAL. Ecological impacts are not anticipated to be significant, as the site is largely modified, and the Sundays River and riparian habitat is located ~550m from the proposed dam expansion footprint. However, with the application of the proposed mitigation measures it has been rated as a LOW NEGATIVE impact, which has a less than 50% chance of occurring. An increase in the potential aquatic habitat would occur due to an increase in available emergent habitat associated with the expanded dam (larger water surface area). This impact has been rated as a LOW POSITIVE. Socio-economic impacts which have been identified, which include the generation of noise and dust, as well as health and safety impacts, can also be mitigated to LOW or VERY LOW NEGATIVE. Heritage impacts can be mitigated to NEUTRAL during the construction phase if the ECO and/ or construction foreman are informed of the types of heritage artefacts which could be uncovered during vegetation clearing and excavations and what action is to be taken should heritage material be uncovered. The application of the proposed mitigation and design measures, as recommended by the respective specialists, to be effectively managed in order to reduce the identified potential impacts so as to not have a detrimental effect on the receiving environment. In addition, some positive impacts have also been predicted. These include the creation of a number of additional employment opportunities and associated economic growth for the local community (rated as LOW POSITIVE), as well as the possible increase of aquatic habitat due to an increase in available emergent habitat associated with the expanded dam (larger water surface area). This impact has been rated as a LOW POSITIVE. No-Go Alternative (compulsory) The No-Go alternative will result in the potential employment and skills development opportunities for the local community not being realised. In turn, the potential opportunity for economic growth in the community will be lost. The securing of irrigation water supply for current agricultural activities will also not be realised. These consequential impacts are regarded as HIGH NEGATIVE.

Version 2 February 2021

BASIC ASSESSMENT REPORT

(For official use only)

File Reference Number:

NEAS Number:

Date Received:

Basic assessment report in terms of the Environmental Impact Assessment Regulations, 2014 as amended,

promulgated in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998), as amended.

Kindly note that:

1. This basic assessment report is a standard report that may be required by a competent authority in terms of the EIA Regulations, 2014 as amended and is meant to streamline applications. Please make sure that it is the report used by the particular competent authority for the activity that is being applied for.

2. The report must be typed within the spaces provided in the form. The size of the spaces provided is not necessarily indicative of the amount of information to be provided. The report is in the form of a table that can extend itself as each space is filled with typing.

3. Where applicable tick the boxes that are applicable or black out the boxes that are not applicable in the report.

4. An incomplete report may be returned to the applicant for revision.

5. The use of “not applicable” in the report must be done with circumspection because if it is used in respect of material information that is required by the competent authority for assessing the application, it may result in the rejection of the application as provided for in the regulations.

6. This report must be handed in at offices of the relevant competent authority as determined by each authority unless indicated otherwise by the Department.

7. No faxed or e-mailed reports will be accepted unless indicated otherwise by the Department.

8. The report must be compiled by an independent environmental assessment practitioner (EAP).

9. Unless protected by law, all information in the report will become public information on receipt by the competent authority. Any interested and affected party should be provided with the information contained in this report on request, during any stage of the application process.

10. A competent authority may require that for specified types of activities in defined situations only parts of this report need to be completed.

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SECTION A: ACTIVITY INFORMATION

Has a specialist been consulted to assist with the completion of this section? YES NO

If YES, please complete form XX for each specialist thus appointed:

Any specialist reports must be contained in Appendix D.

The following specialist studies are included in Appendix D:

Appendix D(i): Aquatic Specialist Report Appendix D(ii): Heritage Screening Report Appendix D (iii): Terrestrial Biodiversity Compliance Statement

1. ACTIVITY DESCRIPTION

Describe the activity, which is being applied for, in detail INTRODUCTION

The applicant, the JN Venter Family Trust, proposes to expand a farm dam on Farm 633, referred to

as Buck Kraal, measuring ~31ha in extent, near Sunland, in the Sundays River Valley Municipality. It

is proposed that the dam, which has a current storage capacity of ~6 521m3 (footprint of ~1.56ha), be

expanded by ~39 413m3 (~0.55ha), to have a total storage capacity of ~45 934m³ (~2.1ha). Farm 633

is zoned as Agriculture I and the remainder of the farm has been planted with citrus. The existing dam

is proposed to be expanded into an area which is currently modified, but undeveloped.

On 12 September 2019 an application was submitted to the Department of Economic Development,

Environmental Affairs and Tourism (DEDEAT) Sarah Baartman Region, on behalf of the JN Venter

Family Trust, for the proposed expansion of an existing farm balancing dam on Farm 633. The Final

Basic Assessment Report (FBAR) was submitted to DEDEAT, for their decision-making, on 22

October 2019. However, prior to receipt of an environmental authorisation, the applicant commenced

with activities on site associated with the expansion of the dam. DEDEAT indicated on 13 December

2019 that the original application for environmental authorisation would therefore be closed, and the

matter was handed over to the DEDEAT Compliance and Enforcement Division. The applicant

subsequently undertook a rehabilitation process to restore the dam to its original capacity, in line with

a rehabilitation plan that had been approved by DEDEAT. DEDEAT has approved the rehabilitation

of the dam and the docket has been closed by the Compliance and Enforcement Division. The

applicant is therefore submitting a new application for Environmental Authorisation to DEDEAT for the

expansion of the rehabilitated dam.

PROJECT LOCALITY

Farm 633 is located north of the R336 (Kirkwood/ Addo Road) and ~3.3km North-West of Sunland (as

the crow flies). Access to the farm is gained by travelling west on the R336, past Sunland, for a

distance of ~3.9km, before turning right onto a gravel road and continuing east for a distance of

~1.5km. The nearest boundary of the Addo Elephant National Park is located ~8.6km east of Farm

633. The locality map attached provides an overview of the location of the property under assessment

(See Map 1 below).

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Map 1: Locality Map of Farm 633 (Buck Kraal)

SURROUNDING LAND USE

Land-uses on the properties adjacent to Farm 633 include commercial agriculture (i.e. citrus orchards

and pastures) and possible livestock grazing/ browsing or derelict land. Vegetation cover on adjacent

farms is therefore characterised by activities associated with the “Sundays River Valley” agricultural

area. The proposed dam expansion is in line with land use activities which currently take place in the

area.

SITE OVERVIEW

The following section provides an overview of the existing land use, project components and activities

on Farm 663 (see Map 2 below).

Farm 633, measures ~31ha in extent and is zoned Agriculture I. The rehabilitated farm dam is located

in the north-western corner of the property, has a capacity to store ~6 521m³ of water from the Lower

Sundays River Water Users Association (LSRWUA) canal system, a footprint of ~1.56ha and a wall

height of 4.7m. A manager’s house and storage / maintenance sheds are located near the entrance

to the farm, in the south-western corner of the property. Citrus orchards have been established on the

remainder of the farm. Irrigation water flows under gravity directly from the LSRWUA system, via an

offtake canal, into the existing rehabilitated dam.

The area that has been modified by the rehabilitation of the dam is proposed to be utilised for the

expansion of the footprint, therefore no intact areas are proposed for clearance. It is proposed that

existing Eskom infrastructure on the farm will be used to supply the proposed pumpstation with

sufficient electricity supply. A new mainline outlet pipe (250mm) will be installed into the expanded

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dam to supply irrigation water to the adjacent orchards via internal irrigation pipelines of varying

diameters (between 50mm and 250mm).

The Sundays River flows adjacent to the eastern boundary of Farm 633, however, the proposed

expansion footprint is located ~500m from the edge of the Sundays River riparian floodplain and no

development is proposed on or near the banks thereof.

Map 2: Existing project components, land use and activities on Farm 633.

PROJECT OVERVIEW

Based on the outcome of the specialist assessments and technical input as well as input received

during the consultation process, the project will entail the clearing and excavating of a portion of Farm

633 for the expansion of the farm dam. It is proposed that the dam be expanded as follows:

• Details of the existing dam (rehabilitated dam)

o Capacity in cubic metres: 6 521m3

o Dam footprint in square metres: 15 643m2 (~1.56ha)

o Dam wall height in metres: 4.7m

• Details of the proposed expansion

o Expansion of capacity in cubic metres: 39 413m3

o Expansion of footprint in square metres: 5 522m2 (0.55ha)

o Increase in wall height in metres: 1.2m

• Details of the total expanded dam

o Total expanded capacity in cubic metres: 45 934m3

o Total expanded footprint in square metres: 21 165m2 (2.11ha)

o Final wall height: 5.9m

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The above components are described in detail in the respective sections below and are indicated in

Map 3 below (also attached as Appendix C to this report).

Map 3: Technical Drawing of the proposed expanded dam (SURPLAN, Attached in Appendix C of this report)

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PROPOSED ACTIVITIES PRE-CONSTRUCTION PHASE

Prior to the commencing with construction activities on the farm, the detailed dam design drawings for

the proposed expansion of the existing dam and associated infrastructure, must be finalised.

CONSTRUCTION PHASE

It is anticipated that the proposed construction phase will entail the following activities:

• Existing dam will be drained prior to expansion and allowed to dry out completely.

• Existing south-western wall will be demolished and will be rebuilt during the proposed expansion

• Topsoil to be excavated and temporarily stockpiled onsite during the construction phase

• Installation of a plastic membrane to line the dam basin and walls, to ensure impermeability.

• Excavated topsoil to be used after expansion along with indigenous vegetation to rehabilitate the

proposed dam walls in order to manage potential erosion.

• The existing offtake canal to be lined with cement.

• The overflow will be relocated north- and westwards, which will increase the capacity of the dam,

and will be lined with cement to reduce erosion.

• Construction of a pumphouse on the southern dam wall

• Installation of an outlet irrigation pipeline with an internal diameter of ~250mm connecting to

existing internal irrigation infrastructure.

OPERATIONAL PHASE

Water will be supplied to the existing dam from the Lower Sundays River Water Users Association

canal system located adjacent to the north-western boundary of Farm 633, wherefrom it will be

pumped into the surrounding citrus orchards for irrigation purposes via pipelines of varying diameters.

Irrigation water will flow under gravity directly into the dam via a cement offtake canal from the

LSRWUA canal system. A new mainline outlet pipe will be installed into the expanded dam to supply

irrigation water to the existing orchards via internal irrigation pipelines of varying diameters. The

internal diameter of the new mainline outlet pipe will be ~250mm, while the internal irrigation pipelines

will vary between 50mm and 250mm.

The farm Buck Kraal is made up of two portions, namely, Farm 633 and Portion 87 of Farm 558, which

have been allocated water use entitlements of 25.7ha and 8.5ha, respectively. Appendix G(ix) of this

report includes confirmation of scheduled water use entitlements from the LSRWUA for Farm 633 and

Portion 87 of Farm 558.

Subsequent to the completion of the proposed dam expansion, the new dam will store water to irrigate

~31ha of citrus orchards, (23ha on Farm 633 and 8ha on Portion 87 of Farm 558) predominantly for

the local market but also for the export market.

PROJECT TIMING

Should the proposed dam expansion receive Environmental Authorisation, it is proposed that the

preconstruction phase (detailed planning and design approval) will commence immediately and will

be completed within ~12 months. The construction phase will commence within 6 months of

completion of the preconstruction phase and will take ~12 months to complete. The expanded dam

will become operational upon completion of the construction phases and will continue in perpetuity.

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2. FEASIBLE AND REASONABLE ALTERNATIVES

“alternatives”, in relation to a proposed activity, means different means of meeting the general purpose and requirements of the activity, which may include alternatives to— (a) the property on which or location where it is proposed to undertake the activity; (b) the type of activity to be undertaken; (c) the design or layout of the activity; (d) the technology to be used in the activity; (e) the operational aspects of the activity; and (f) the option of not implementing the activity.

Describe alternatives that are considered in this application. Alternatives should include a consideration of all possible

means by which the purpose and need of the proposed activity could be accomplished in the specific instance taking

account of the interest of the applicant in the activity. The no-go alternative must in all cases be included in the assessment

phase as the baseline against which the impacts of the other alternatives are assessed. The determination of whether

site or activity (including different processes etc.) or both is appropriate needs to be informed by the specific circumstances

of the activity and its environment. After receipt of this report the competent authority may also request the applicant to

assess additional alternatives that could possibly accomplish the purpose and need of the proposed activity if it is clear

that realistic alternatives have not been considered to a reasonable extent.

Paragraphs 3 – 13 below should be completed for each alternative.

This Basic Assessment included the consideration of layout alternatives. Site alternatives were

not assessed, as this project is for the expansion of an existing dam on Farm 633. The following

factors have contributed to the identification of the preferred layout alternative:

• Location of the existing farm dam

• Location of existing infrastructure, including existing irrigation infrastructure, Eskom electrical

point as well as the LSRWUA canal system

• Water availability requirements

Layout 1 (not preferred)

Initially the proposed dam was to be expanded to a have a storage capacity of 49 680m³, a

footprint of 2.27ha and a wall height of 5m. It was to be expanded into an area that was previously

cultivated fields (i.e. Lucerne fields), but was subsequently replaced with citrus orchards. In order

to avoid loss of existing citrus orchards, the proposed location of the dam has been moved ~90m

in a westerly direction. Additionally, the applicant indicated that the proposed dam was larger

than the amount of water required to be stored. Therefore, the size of the expansion was reduced.

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Map 4: Initial proposed layout (Layout 1) which is no longer preferred.

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Layout 2 (preferred Layout)

Layout 2, as outlined above in Section 1 (Activity Description), is the preferred layout for the dam

expansion and has been assessed in full (see map 3 above). The dam is proposed to be

expanded to have a storage capacity of 45 934m³, a footprint of 2.11ha and a dam wall height of

5.9m. The dam will be expanded by rebuilding and shaping the southwestern wall, as well as the

overflow, so as to increase the storage capacity.

No-Go Alternative

In addition to the alternatives discussed in this section, the No-Go Alternative was assessed in full

in the Impact Section of this report (Section D). The expansion of the dam is primarily required to

store additional water from the LSRWUA canal system in order to sustainably irrigate the existing

citrus orchards. Currently the applicant has a temporary arrangement in place with the Sundays

River Citrus Company (SRCC), to irrigate directly from a pipeline that they have installed in the

road reserve adjacent to Farm 633. The orchard trees are still young and therefore do not require

a lot of water. However, as the orchards mature, more water will be required than can be delivered

via the pipeline. The No-Go option would result in the applicant not being able to irrigate the

orchards sufficiently, thus causing a significant loss in capital investment and existing employment.

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3. ACTIVITY POSITION

Surveyor General 21 Digit Code(s)

C 0 7 6 0 0 0 0 0 0 0 0 0 6 3 3 0 0 0 0 0

1 2 3 4 5

Indicate the position of the activity using the latitude and longitude of the centre point of the site for each alternative site. The co-ordinates should be in degrees and decimal minutes. The minutes should have at least three decimals to ensure adequate accuracy. The projection that must be used in all cases is the WGS84 spheroid in a national or local projection. List alternative sites if applicable. Alternative:

Latitude (S):

Longitude (E):

Alternative S11 (preferred or only site alternative)

33° 28.887‘ 25° 36.144‘

Alternative S2 (if any) o ‘ o ‘

Alternative S3 (if any) o ‘ o ‘ In the case of linear activities:

Alternative: Latitude (S): Longitude (E): Alternative S1 (preferred or only route alternative)

• Starting point of the activity o ‘ o ‘

• Middle point of the activity o ‘ o ‘

• End point of the activity o ‘ o ‘

Alternative S2 (if any)




Alternative S3 (if any)




For route alternatives that are longer than 500m, please provide an addendum with co-ordinates taken every 250 meters along the route for each alternative alignment.

1 “Alternative S..” refer to site alternatives.

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Coordinates for the property where the proposed dam expansion will take place (Preferred alternative).

Point Number

Latitude (S) (DDMMSS) Longitude (E) (DDMMSS)

1 33° 28' 51.63"S 25° 36' 5.70"E

2 33° 28' 44.24"S 25° 36' 26.69"E

3 33° 28’ 15.01"S 25° 36' 27.38"E

4 33° 28’ 40.77"S 25° 36' 26.07"E

5 33° 28’ 48.48"S 25° 36' 33.39"E

6 33° 28' 59.38"S 25° 36' 35.44“E

7 33° 29’ 1.63"S 25° 36' 34.80"E

8 33° 29' 1.03"S 25° 36' 31.99"E

9 33° 29’ 0.48"S 25° 36' 31.97"E

10 33° 29’ 2.21"S 25° 36’ 8.94"E

Map 5: Plan indicating the coordinates of the boundary of Farm 633, upon which the development is proposed to take place.

Coordinates demarcating the proposed dam footprint (Preferred alternative).

Point Number

Latitude (S) (DDMMSS) Longitude (E) (DDMMSS)

1 33° 28' 51.65"S 25° 36' 5.80"E

2 33° 28' 51.43"S 25° 36' 7.09"E

3 33° 28’ 51.03"S 25° 36' 7.39"E

4 33° 28’ 50.16"S 25° 36' 9.86"E

5 33° 28’ 50.92"S 25° 36' 11.02"E

6 33° 28' 54.32"S 25° 36' 12.09“E

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7 33° 28’ 55.23"S 25° 36' 11.25"E

8 33° 28’ 55.59”S 25° 36' 8.95”E

9 33° 28’ 55.78”S 25° 36' 8.04”E

10 33° 28’ 55.85”S 25° 36' 7.13”E

Map 6: Plan indicating the coordinates of the proposed expanded dam on Farm 633.

4. PHYSICAL SIZE OF THE ACTIVITY

Indicate the physical size of the preferred activity/technology as well as alternative activities/technologies (footprints): Alternative: Size of the activity:

Alternative A12 (preferred activity alternative) 21 165 m2

Alternative A2 (if any) m2


or, for linear activities: Alternative: Length of the activity:

Alternative A1 (preferred activity alternative) m

Alternative A2 (if any) m

Alternative A3 (if any) m

Indicate the size of the alternative sites or servitudes (within which the above footprints will occur): Alternative: Size of the

site/servitude:

Alternative A1 (preferred activity alternative) 313 976 m2



2 “Alternative A..” refer to activity, process, technology or other alternatives.

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5. SITE ACCESS

Does ready access to the site exist? YES NO

If NO, what is the distance over which a new access road will be built m

Describe the type of access road planned:

Access to Farm 633 is gained by travelling west on the R336, past Sunland, for a distance of ~3.8km, before turning right onto the gravel road just past the Summerville liquor store and continuing east for a distance of ~1.5km. The existing south-western access point, associated with the farmhouse, is proposed to be utilised (see Map 2 above). A Traffic Impact Assessment is not proposed for the expansion of the existing dam, as the impacts on the surrounding roads will be temporary and limited to the Construction Phase of the development. It is not anticipated that the Operational Phase, where it relates to the operation of the expanded dam, will increase the traffic volumes on the surrounding roads.

Include the position of the access road on the site plan and required map, as well as an indication of the road in relation to the site. 6. SITE OR ROUTE PLAN

A detailed site or route plan(s) must be prepared for each alternative site or alternative activity. It must be attached as Appendix A to this document. The site or route plans must indicate the following: 6.1 the scale of the plan which must be at least a scale of 1:500; 6.2 the property boundaries and numbers of all the properties within 50 metres of the site; 6.3 the current land use as well as the land use zoning of each of the properties adjoining the site or sites; 6.4 the exact position of each element of the application as well as any other structures on the site; 6.5 the position of services, including electricity supply cables (indicate above or underground), water supply pipelines,

boreholes, street lights, sewage pipelines, storm water infrastructure and telecommunication infrastructure; 6.6 all trees and shrubs taller than 1.8 metres; 6.7 walls and fencing including details of the height and construction material; 6.8 servitudes indicating the purpose of the servitude; 6.9 sensitive environmental elements within 100 metres of the site or sites including (but not limited thereto):

▪ rivers; ▪ the 1:100 year flood line (where available or where it is required by DWA); ▪ ridges; ▪ cultural and historical features; ▪ areas with indigenous vegetation (even if it is degraded or invested with alien species);

6.9 for gentle slopes the 1 metre contour intervals must be indicated on the plan and whenever the slope of the site exceeds 1:10, the 500mm contours must be indicated on the plan; and

6.10 the positions from where photographs of the site were taken.

A Site Plan has been included in Appendix A.

7. SITE PHOTOGRAPHS

Colour photographs from the centre of the site must be taken in at least the eight major compass directions with a

description of each photograph. Photographs must be attached under Appendix B to this form. It must be supplemented

with additional photographs of relevant features on the site, if applicable.

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Photographs from the centre of the site, in all 8 compass directions, are included in Appendix B.

8. FACILITY ILLUSTRATION

A detailed illustration of the activity must be provided at a scale of 1:200 as Appendix C for activities that include structures. The illustrations must be to scale and must represent a realistic image of the planned activity. The illustration must give a representative view of the activity. A Facility Illustration (preferred Layout) has been included in Appendix C.

9. ACTIVITY MOTIVATION3

9(a) Socio-economic value of the activity

What is the expected capital value of the activity on completion? R2.8 Million

What is the expected yearly income that will be generated by or as a result of the activity? N/A

Will the activity contribute to service infrastructure? YES NO

Is the activity a public amenity? YES NO

How many new employment opportunities will be created in the development phase of the

activity? 10

What is the expected value of the employment opportunities during the development phase? R 450 000

What percentage of this will accrue to previously disadvantaged individuals? 100%

How many permanent new employment opportunities will be created during the operational

phase of the activity? 1

What is the expected current value of the employment opportunities during the first 10 years? R 1.2 Million

What percentage of this will accrue to previously disadvantaged individuals? 100%

9(b) Need and desirability of the activity

Motivate and explain the need and desirability of the activity (including demand for the activity): South Africa’s National Development Plan, 2011, has as one of its focal points, the expansion of

agriculture in order to facilitate job creation. The Final IDP (2020/ 2021) for the SRVM indicates that

the current unemployment rate in the municipal area may be as high as 38.54%. The Agricultural

sector provides room for growth in terms of employment opportunities, as it currently represents

~11% of the employment for the SRVM area. The NMBM Integrated Development Plan 2017/2018

– 2021/2022 (3rd Edition, Adopted 19 June 2019) highlights some of the key socio-economic

challenges in the NMBM and lists unemployment and poverty among them. Some of the reasons

cited in the NMBM IDP (2017/2021) for the low economic growth experienced in the NMBM (1.36%

per annum) are the high unemployment and dependency ratios (unemployment rate 36.8%). The

NMBM is experiencing a devastating drought, one of the worst recorded, and it has strained all

main economy sectors of NMBM including Agro-processing, one of the four main economic sectors

in the NMBM (NMBM IDP 2017/2021). The nearby communities associated with the towns of

Kirkwood and Addo in the SRVM, as well as the greater NMBM area, represent an important labour

force in close proximity to the proposed development.

3 The information provided in this section refers only to the activities that trigger the need for Environmental Authorisation

and thus does not include the socio-economic information associated with the citrus orchards. As such, the dam is not anticipated to generate an income itself but will support the proposed orchards which will generate an annual income of approximately R20 Million.

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The citrus industry is a very important component of the Eastern Cape’s agricultural economy and

of the “Sundays River Valley” in particular. The expansion of the existing dam on Farm 633 has a

direct correlation to employment creation, as the Construction Phase of the project will create

additional temporary employment opportunities. The long-term land use of citrus orchards would

indirectly create additional seasonal, as well as permanent Operational Phase employment

opportunities. By making use of the local labour market, the proposed development would also

support the vision of the Sundays River Valley Local Economic Strategy, as outlined in the SDF

(April 2013), which indicates agriculture as a Local Economic Development Priority and identifies

the need to “…expand the agricultural section in the region.”, as an Economic Development

Objective.

Water supply from the LSRWUA canal system is only released at scheduled times and is thus not

readily available to farmers at all times. Therefore, a balancing dam is required in order to allow the

temporary storage of LSRWUA canal water for irrigation purposes. The applicant has entered into

a temporary agreement with the Sunday River Citrus Company (SRCC) to access irrigation water

from a pipeline that they have installed in the road reserve adjacent to Farm 633, to irrigate existing

citrus orchards on Farm 633 and Portion 87 of Farm, 558. The orchard trees are still young and

therefore do not require a lot of water. However, as the orchards mature, more water will be required

than can be delivered via the pipeline, at which point, the applicant intends to use the proposed

expanded farm dam.

The proposed expansion of the dam will ensure the security of future irrigation water supply to the

citrus orchards.

Indicate any benefits that the activity will have for society in general:

The project will provide economic stimulation in the SRVM, through a temporary increase in

demand for goods associated with the Construction Phase of the dam expansion. In the long-term

and during the Operational Phase of the activity, which includes sustainable irrigation of citrus

orchards, positive indirect economic benefits are associated with the creation of additional

employment opportunities; an increase in shipping and cargo handling requirements; as well as

increased transport requirements for goods and labour.

Indicate any benefits that the activity will have for the local communities where the activity will be located:

The Final IDP (2020/ 2021) for the SRVM indicates that the current unemployment rate in the

municipal area may be as high as 38.54%. The proposed development will indirectly create an

additional ~11 employment opportunities during the construction and operational phases

combined. The indirect employment opportunities that will be generated by the proposed

development will improve the buying power of individuals in the local communities, which in turn,

may provide a boost for the local economy and enable these individuals to improve their standard

of living.

The project will also provide economic stimulation in the SRVM, through a temporary increase in

demand for goods associated with the Construction Phase of the dam expansion. In the long-term

and during the Operational Phase of the activity, positive indirect economic benefits are associated

with the seasonal employment opportunities (related to the farming operations, as well as indirectly

in support services); an increase in shipping and cargo handling requirements; as well as

increased transport requirements for goods and labour.

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10. APPLICABLE LEGISLATION, POLICIES AND/OR GUIDELINES

List all legislation, policies and/or guidelines of any sphere of government that are applicable to the application as contemplated in the EIA regulations, if applicable:

Title of legislation, policy or guideline: Administering authority:

Date:

GN R 324 (Listing Notice 3) 16. The expansion of reservoirs, excluding dams, where the capacity will be increased by more than 250 cubic metres. a. Eastern Cape i. Outside urban areas: (hh) Areas within 10 kilometres from national parks or world heritage sites or 5 kilometres from any other protected area identified in terms of NEMPAA or from the core area of a biosphere reserve; or The existing reservoir is proposed to be expanded by ~39 413 cubic metres, to have a total storage capacity of ~45 934 cubic metres. The site is located in the Eastern Cape, outside of an urban area and ~8.6 kilometres from the nearest boundary of Addo Elephant National Park.

Department of Economic Development,

Environmental Affairs and Tourism – Sarah Baartman Region

2014 (as Amended)

11. WASTE, EFFLUENT, EMISSION AND NOISE MANAGEMENT

11(a) Solid waste management

Will the activity produce solid construction waste during the construction/initiation

phase? YES NO

If yes, what estimated quantity will be produced per month? 10m3

How will the construction solid waste be disposed of (describe)?

The main Construction Phase waste is excavated soil that will originate on site from

demolishing the existing dam walls. The majority of the excavated soil will be used in

the construction of the new proposed dam wall. Excess excavated soils generated will

be used on the property to level and restore any disturbed areas adjacent to the

proposed dam expansion. Additional Construction Phase waste is expected to be

limited to litter generated by the construction staff, which must be disposed of at a

licensed waste disposal site. Waste will be recycled as far as possible. Non-recyclable

waste will be sorted into different types and disposed of at a suitably licensed waste

disposal facility.

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Where will the construction solid waste be disposed of (describe)?

Construction Phase solid waste, if any, will be disposed of at the nearest licensed

waste disposal site (Patterson Waste disposal site or Kirkwood Waste Disposal Site).

Waste considered unsuitable for municipal waste disposal sites will be disposed of at

a suitably licensed hazardous waste disposal facility.

Will the activity produce solid waste during its operational phase? YES NO

If yes, what estimated quantity will be produced per month?

How will the solid waste be disposed of (describe)?

The Operational Phase of the development will consist of the completion of the dam

expansion and utilising it for irrigation purposes. It is not anticipated that solid waste

will be produced during the Operational Phase of the proposed development.

Where will the solid waste be disposed if it does not feed into a municipal waste stream (describe)?

It is not anticipated that solid waste will be produced during the Operational Phase of

the proposed development.

If the solid waste (construction or operational phases) will not be disposed of in a registered landfill site

or be taken up in a municipal waste stream, then the applicant should consult with the competent authority

to determine whether it is necessary to change to an application for scoping and EIA.

Can any part of the solid waste be classified as hazardous in terms of the relevant legislation?

YES NO

If yes, inform the competent authority and request a change to an application for scoping and EIA.

Is the activity that is being applied for a solid waste handling or treatment facility? YES NO

If yes, then the applicant should consult with the competent authority to determine whether it is necessary to change to an application for scoping and EIA.

11(b) Liquid effluent

Will the activity produce effluent, other than normal sewage, that will be disposed of in a

municipal sewage system?

YES NO

If yes, what estimated quantity will be produced per month?

Will the activity produce any effluent that will be treated and/or disposed of on site? Yes NO

If yes, the applicant should consult with the competent authority to determine whether it is necessary to

change to an application for scoping and EIA.

Will the activity produce effluent that will be treated and/or disposed of at another facility? YES NO

If yes, provide the particulars of the facility:

Facility name:

Contact person:

Postal address:

Postal code:

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Telephone: Cell:

E-mail: Fax:

Describe the measures that will be taken to ensure the optimal reuse or recycling of waste water, if any:

The proposed development is not anticipated to produce wastewater, this application

is for the expansion of an existing farm dam to be utilised for irrigation purposes.

11(c) Emissions into the atmosphere

Will the activity release emissions into the atmosphere? YES NO

If yes, is it controlled by any legislation of any sphere of government? YES NO

If yes, the applicant should consult with the competent authority to determine whether it

is necessary to change to an application for scoping and EIA.

If no, describe the emissions in terms of type and concentration:

11(d) Generation of noise

Will the activity generate noise? YES NO

If yes, is it controlled by any legislation of any sphere of government? YES NO

If yes, the applicant should consult with the competent authority to determine whether it

is necessary to change to an application for scoping and EIA.

If no, describe the noise in terms of type and level:

• During the Construction Phase, noise associated with normal construction activities

such as vehicles, generators and plant equipment will be present on site. However,

construction activities will, as far as possible, be limited to normal working hours

(Weekdays between 7am to 6pm).

• Noise levels are to be kept within the legislated limits for the area, in accordance

with the requirements of the relevant national and local noise control by-laws.

• Some noise will be generated by the pumping infrastructure during the operational

phase.

12. WATER USE

Please indicate the source(s) of water that will be used for the activity by ticking the appropriate box(es)

municipal Water

board

groundwater river, stream, dam

or lake

other the activity will not use

water

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If water is to be extracted from groundwater, river, stream, dam, lake or any other natural feature, please

indicate

the volume that will be extracted per month: litres

Does the activity require a water use permit from the Department of Water Affairs? YES NO

It is not anticipated that an application will need to be made to the DWS Safety Office

in terms of the Dam Safety Regulations as the proposed capacity of the expanded dam

will be less than 50 000m³. In addition, because there is no natural inflow or outflow of

the dam and since the water to be stored in the dam is from an already licensed

resource, namely the Lower Sundays River Water Users Association, no WULA in

terms of Section 21 (b) is required.

If yes, please submit the necessary application to the Department of Water Affairs and attach proof thereof

to this application if it has been submitted.

13. ENERGY EFFICIENCY

Describe the design measures, if any, that have been taken to ensure that the activity is energy efficient:

The pumphouse will function at scheduled pumping and release times and will not be

engaged when not in use

Describe how alternative energy sources have been taken into account or been built into the design of

the activity, if any:

None. However, should Eskom power supply fail, a generator will be used to provide

power to the pumphouse.

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SECTION B: SITE/AREA/PROPERTY DESCRIPTION

Important notes:

1. For linear activities (pipelines, etc) as well as activities that cover very large sites, it may be necessary to complete this section for each part of the site that has a significantly different environment. In such cases please complete copies of Section C and indicate the area, which is covered by each copy No. on the Site Plan.

Section C Copy No. (e.g. A):

2. Paragraphs 1 - 6 below must be completed for each alternative.

3. Has a specialist been consulted to assist with the completion of this section? YES

NO

If YES, please complete form XX for each specialist thus appointed:

Specialist Declaration Forms have been completed by the respective specialists and are included

in Appendix G(viii)

All specialist reports must be contained in Appendix D.

The following specialist studies have been included in Appendix D: Appendix D(i): Aquatic Specialist Report Appendix D(ii): Heritage Screening Report Appendix D (iii): Terrestrial Biodiversity Compliance Statement

1. GRADIENT OF THE SITE

Indicate the general gradient of the site.

Alternative S1: Flat 1:50 – 1:20 1:20 – 1:15 1:15 – 1:10 1:10 – 1:7,5 1:7,5 – 1:5 Steeper

than 1:5

Alternative S2 (if any): Flat 1:50 – 1:20 1:20 – 1:15 1:15 – 1:10 1:10 – 1:7,5 1:7,5 – 1:5 Steeper

than 1:5

Alternative S3 (if any): Flat 1:50 – 1:20 1:20 – 1:15 1:15 – 1:10 1:10 – 1:7,5 1:7,5 – 1:5 Steeper

than 1:5

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2. LOCATION IN LANDSCAPE

Indicate the landform(s) that best describes the site: 2.1 Ridgeline 2.2 Plateau 2.3 Side slope of hill/mountain 2.4 Closed valley 2.5 Open valley 2.6 Plain 2.7 Undulating plain / low hills 2.8 Dune 2.9 Seafront

3. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE

Is the site(s) located on any of the following (tick the appropriate boxes)? Alternative S1: Alternative S2 (if

any):

Alternative S3 (if

any):

Shallow water table (less than

1.5m deep)

YES NO

YES NO YES NO

Dolomite, sinkhole or doline

areas

YES NO

YES NO YES NO

Seasonally wet soils (often close

to water bodies)

YES NO

YES NO YES NO

Unstable rocky slopes or steep

slopes with loose soil

YES NO

YES NO YES NO

Dispersive soils (soils that

dissolve in water)

YES NO

YES NO YES NO

Soils with high clay content (clay

fraction more than 40%)

YES NO

YES NO YES NO

Any other unstable soil or

geological feature

YES NO

YES NO YES NO

An area sensitive to erosion YES NO YES NO YES NO

It is likely that after the construction, the dam wall may be susceptible to erosion, if it is not adequately vegetated. Thus, the liberal use of indigenous groundcover vegetation (i.e. Grass) on the dam wall is recommended to reduce the potential impact.

If you are unsure about any of the above or if you are concerned that any of the above aspects may be an issue of concern in the application, an appropriate specialist should be appointed to assist in the completion of this section. (Information in respect of the above will often be available as part of the project information or at the planning sections of local authorities. Where it exists, the 1:50 000 scale Regional Geotechnical Maps prepared by the Council for Geo Science may also be consulted).

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4. GROUNDCOVER

Indicate the types of groundcover present on the site: 4.1 Natural veld – good condition E 4.2 Natural veld – scattered aliens E 4.3 Natural veld with heavy alien infestation E 4.4 Veld dominated by alien species E 4.5 Gardens 4.6 Sport field 4.7 Cultivated land 4.8 Paved surface 4.9 Building or other structure 4.10 Bare soil The location of all identified rare or endangered species or other elements should be accurately indicated on the site plan(s).

Natural veld - good

conditionE

Natural veld with

scattered aliensE

Natural veld with

heavy alien

infestationE

Veld dominated

by alien

speciesE

Gardens

Sport field Cultivated land Paved surface Building or

other structure Bare soil

If any of the boxes marked with an “E “is ticked, please consult an appropriate specialist to assist in the completion of this section if the environmental assessment practitioner doesn’t have the necessary expertise.

CONSERVATION PLANNING FRAMEWORKS

• Vegetation of South Africa, Lesotho and Swaziland Map (VegMap, 2018)

According to the VegMap (2018) mapping resources, the vegetation type that should occur on

Farm 633 is Albany Alluvial Vegetation, which is classified in the National Biodiversity Assessment

(NBA,2018) as Endangered (Map 7). Consequently, it is listed as a Threatened Ecosystem in

terms of the National Environmental Management: Biodiversity Act (10 of 2004).

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Map 7: Vegetation on Farm 633 in terms of VegMap mapping resources

• Eastern Cape Biodiversity Conservation Plan (ECBCP, 2019)

In terms of the ECBCP 2019 mapping resources the majority of Farm 633, including the proposed

dam expansion footprint, has been identified as a Terrestrial ESA 2. A few portions of the site

have also been identified as Terrestrial ESA1, however, these do not fall within the proposed

footprint (See Map 8). The ECBCP Handbook (2019), does not include land-use management

guidelines for developments of this nature, i.e. reservoirs for the off-stream storage of irrigation

water. However, the Handbook does indicate that sites identified as Terrestrial ESA1 should be

maintained in a functional state i.e. a semi-natural state such that ecological function and

ecosystem services are maintained. Ecosystems that are natural/ near-natural should be

maintained and those that are moderately degraded / disturbed should be restored.

For ESA2 sites the land management objective is to maintain current land use with no

intensification. These areas have already been subjected to severe and/or irreversible

modification. Both ESA1 and ESA2 are not required to meet biodiversity targets. Given that the

site has been irreversibly modified, the designation of portions of the site as ESA1, in the ECBCP

2019 mapping resources, appears to be incorrect.

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Map 8: Farm 633 in terms of the ECBCP 2019 Terrestrial mapping resources.

In terms of the ECBCP 2019 mapping resources a portion of Buck Kraal has been identified as an

Aquatic ESA 1 associated with the Sundays River located adjacent to the eastern boundary (see

Map 9). A protruding arm runs in a north-east to south-western direction across a portion of the

farm and is presumably a historic tributary associated with the Sundays River. According to the

ECBCP Handbook (2019), sites identified as Aquatic ESA1 should be maintained in a functional

state i.e. a semi-natural state such that ecological function and ecosystem services are

maintained. Ecosystems that are natural/ near-natural should be maintained and those that are

moderately degraded / disturbed should be restored. However, given that the site has been

irreversibly modified, the designation of portions of the site as ESA1, in the ECBCP 2019 mapping

resources, appears to be incorrect.

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Map 9: Farm 633, in terms of the ECBCP 2019 Aquatic mapping resources.

• Sundays River Valley Municipality Biodiversity Sector Plan (SRVM BSP, 2012)

According to the SRVM BSP (Skowno and Holness, 2012) mapping resources, the majority of

Farm 633 is indicated as No Natural Remaining (NNR) area, which represents the existing

orchards. A small portion of the eastern section of the farm, associated with the Sundays River

and its floodplain, is classified as a Critical Biodiversity Area (CBA) and Ecological Support Area

(ESA). However, the proposed dam expansion is located in the NNR area towards the western

part of the farm (Map 10).

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Map 10: Farm 633 in terms of the SRVM Biodiversity Sector Plan mapping resources.

• National Wetland Inventory V5.2 (2018)

The site falls within one Quaternary catchment, just upstream of the Coerney River confluence

with the Sundays River (N40E) (Map 11), while the remainder of the catchment occurs within a

highly transformed agricultural environment. Furthermore, no natural wetland environments are

located within the development footprint, or within 500m thereof confirmed in Version 5.2 (2018)

of the National Wetland Inventory (Map 12).

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Map 11: Project locality map indicating the N40E quaternary catchment boundary (green line) (Source DWS

and NGI)

Map 12: The various dams, river reaches, and drainage lines within or near the property identified in the

National Wetland Inventory V5.2 (2018), together with the respective buffers

NATIONAL ENVIRONMENTAL SCREENING TOOL

The National web-based Environmental Screening Tool allows for the generating of a Screening

Report referred to in Regulation 16(1)(v) of the Environmental Impact Assessment Regulations

2014, as amended, which is required to accompany any application for Environmental

Authorisation. The National Environmental Screening Tool identifies the following Sensitivities on

the site, which have relevance to this report:

• Terrestrial Biodiversity - Very High (Figure 1).

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• Plant Species sensitivity - Low (Figure 2).

• Animal Species sensitivity – Medium (Figure 3).

• Aquatic Sensitivity is Low (Figure 4).

Figure 1: Terrestrial Biodiversity Sensitivity.

Figure 2:. Plant Species Sensitivity

Figure 3: Animal Species Sensitivity

Figure 4: Aquatic Sensitivity

The key biodiversity features that are indicative of this sensitivity, which will be assessed further

in this report, include the following:

Sensitivity Feature(s) in proximity

Terrestrial Sensitivity

Very High Ecological Support Area 2 & Endangered Ecosystem

High None

Medium None

Low None

Plant Sensitivity

Very High None

High None

Medium None

Low Present

Animal Sensitivity

Very High None

High None

Medium Aneuryphymus montanus (Invertebrate) & Sensitive Species 5

Low Present

Aquatic Sensitivity

Very High None

High None

Medium None

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Low Present

CURRENT STATE OF THE VEGETATION ON SITE

Aquatic Environment

An aquatic specialist assessment was undertaken during the previous environmental assessment

process. The full specialist study is attached as Appendix D (i) of this report. Below is an extract

of the findings of that report as it related to the aquatic environment, at that time. Given that the

dam has been modified since the study was undertaken, some of the information therein is no

longer relevant.

The only natural waterbodies found within the study area (site inclusive of 500m buffer), include

the lower portion of the Sundays River riparian zone, suffering from a high degree of Phragmites

australis reedbed and or Vachellia karroo encroachment (Photo 1), possibly because of the

constant baseflow regime (Adams, Cowie & van Niekerk, 2016), high in nutrients. This is a result

of Orange River transfer scheme and agricultural return flows in the catchment (Janse van Vuuren

& Taylor, 2015).

Photo 1: A view of the reed encroachment that has taken place within the Sundays River within the north-

eastern portion of the farm boundary.

This lack of overall natural habitat has resulted in a general absence of indigenous aquatic

species, with only small number of instream / emergent species being found along the mainstem

systems and include:

• Ficinia lateralis

• Juncus kraussii

• Phragmites australis

• Arundo donax (Spanish reed – Invasive)

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• Cyperus obtusiflorus var. obtusiflorus

• Centella asiatica

• Carex clavata

• Typha capensis.

Map 13 includes the delineation of the remaining extent of the Sundays River riparian zone, as

past land use activity has resulted in the cultivation of grazing pastures, limiting the development

of any aquatic habitats, as were seen in the past

Map 13: Final riparian delineation and 60m buffer in relation to the proposed dam expansion footprint. (Note:

This map was prepared by the aquatic specialist during the previous assessment process which

was prior to the establishment of the orchards and utilised a previous expansion footprint layout)

The information provided below is based on the Terrestrial Biodiversity Compliance

Statement prepared by Jamie Pote (SACNASP Registered Ecological Scientist) and

attached as Appendix D(iii) to this report.

Terrestrial Biodiversity

Habitat characteristics indicate the area is transformed and the likelihood of any terrestrial

ecosystem Biodiversity Priority Areas (BPA’s), plant or animal Species of Conservation Concern

being found at the site or within the area of influence is negligible (very low).

Being transformed, comprising of an existing dam, and surrounded by orchards which were

previously irrigated pastures, the site is not considered to be an Ecological Support Area 2 nor

likely to provide ecological function associated with such features.

The nearest natural vegetation is associated with the Sundays River and its floodplain, located

along the eastern boundary of the farm. This vegetation has been encroached by the common

reed Phragmites australis, as well as Vachellia karroo and is outside of the area of influence of

the proposed dam expansion, being separated from this by a block of citrus orchards, which were

historically irrigated pastures that is at least 500m wide.

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Furthermore, since the site is transformed and has no indigenous vegetation, it will not be the

Endangered Ecosystem (Albany Alluvial Vegetation) as identified in the screening tool.

Plant Species

No sensitive plant species were identified as per the screening tool, and none were identified on

site, confirming the designated low sensitivity of the site.

Animal Species

The two animal species, an invertebrate (Aneuryphymus montanus) and Sensitive Species 5 are

not found on the site. In addition, the site, being comprised of transformed habitat, is unlikely to

provide suitable habitat for these species before or after expansion of the dam, due to existing

levels of transformation.

Aquatic Biodiversity

Although outside of the scope of this terrestrial biodiversity compliance statement, it is noted that

the existing farm dam was classified by the aquatic specialist, undertaken as part of the Basic

Assessment Process, as an “artificial dam”. As such, the Present Ecological State and

Conservation Importance of the dam were not determined. The closest natural aquatic feature is

the Sundays River, located over 500m to the east and over 800 m to the north of the site.

Furthermore, expansion of the dam will not affect or alter the flow of any natural watercourse, as

its purpose is to serve as an off-stream reservoir for water abstracted from an irrigation board

canal.

No natural Aquatic Biodiversity features are noted to be present, nor likely to be affected by the

expansion of the off-stream farm storage dam, as confirmed in the aquatic assessment report that

was compiled for the basic assessment, which also confirms the low aquatic biodiversity sensitivity

designation of the screening tool.

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Photo 2: The majority of the farm has been irreversibly modified and converted to Citrus orchards.

Photo 3: An aerial photo of the existing farm dam on Farm 633. (Photo courtesy of Mr. Jamie Pote)

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Photo 4: A view of the vegetated southern dam wall.

5. LAND USE CHARACTER OF SURROUNDING AREA

Indicate land uses and/or prominent features that currently occur within a 500m radius of the site and give description of how this influences the application or may be impacted upon by the application: 5.1 Natural area 5.2 Low density residential 5.15 Dam or reservoir 5.16 Hospital/medical centre 5.33 Agriculture 5.34 River, stream or wetland 5.39 Protected Area 5.40 Graveyard 5.41 Archaeological site 5.42 Other land uses (describe) If any of the boxes marked with an “N “are ticked, how will this impact / be impacted upon by the proposed activity. If any of the boxes marked with an "An" are ticked, how will this impact / be impacted upon by the proposed activity.

If YES, specify and explain:

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If YES, specify:

If any of the boxes marked with an "H" are ticked, how will this impact / be impacted upon by the proposed activity.

If YES, specify and explain:

If YES, specify:

6. CULTURAL/HISTORICAL FEATURES

Are there any signs of culturally or historically significant elements, as defined in section 2 of the National Heritage Resources Act, 1999, (Act No. 25 of 1999), including

YES NO

Archaeological or palaeontological sites, on or close (within 20m) to the site? Uncertain

If YES, explain:

If uncertain, conduct a specialist investigation by a recognised specialist in the field to establish whether there is such a feature(s) present on or close to the site.

Briefly explain the findings of the specialist:

A heritage screening report was compiled by CTS Heritage during the previous

environmental assessment process. The full specialist study is attached as

Appendix D (ii) of this report. Below is an extract of the findings of that report as it

related to the potential for the occurrence of heritage resources on the site. Given

that the farm has been modified since the study was undertaken, some of the

information therein is no longer relevant.

“The area proposed for the dam extension is currently utilised for the cultivation of lucerne and fodder. Based on the distance of the proposed dam expansion from the banks of the Sundays River, as well as the previously disturbed nature of the area, it is unlikely that the proposed development will impact on significance archaeological resources.” “The area proposed for the dam expansion is underlain by alluvial deposits of moderate palaeontological sensitivity according to the SAHRIS Palaeosensitivity Map (Figure 4 and 5). The low sensitivity alluvial deposits overlay sediments of the Sundays River Formation of very high palaeontological sensitivity (Figure 4 and 5). According to the SAHRIS Fossil Heritage Browser, the Sundays River Formation is dated to the early Cretaceous and is known to contain rich marine invertebrate fauna (molluscs, echinoderms etc), vertebrates (eg plesiosaurs), microfossils (foraminiferans, ostracods) and trace fossils of high palaeontological significance. In addition, it is likely that the proposed excavation for the dam extension may intersect with the significant Sundays River Formation.” Recommendations The heritage resources in the area proposed for development are sufficiently recorded. It was initially recommended by the heritage specialist that a site visit by a palaeontologist take place during the construction phase of the project to inspect fresh bedrock for significant fossil material. However, given that the dam has subsequently been expanded and rehabilitated, this recommendation would no longer be necessary.

Will any building or structure older than 60 years be affected in any way? YES NO

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Is it necessary to apply for a permit in terms of the National Heritage Resources Act, 1999 (Act 25 of 1999)?

ESY NO

If yes, please submit or, make sure that the applicant or a specialist submits the necessary application to SAHRA or the relevant provincial heritage agency and attach proof thereof to this application if such application has been made.

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SECTION C: PUBLIC PARTICIPATION

1. ADVERTISEMENT The person conducting a public participation process must take into account any guidelines applicable to public participation as contemplated in section 24J of the Act and must give notice to all potential interested and affected parties of the application which is subjected to public participation by— (a) fixing a notice board (of a size at least 60cm by 42cm; and must display the required information in

lettering and in a format as may be determined by the competent authority) at a place conspicuous to the public at the boundary or on the fence of— (i) the site where the activity to which the application relates is or is to be undertaken; and

(ii) any alternative site mentioned in the application;

A copy of the notice board placed on the fence of the property attached in Appendix G(i)

(b) giving written notice to—

(i) the owner or person in control of that land if the applicant is not the owner or person in control of the land;

(ii) the occupiers of the site where the activity is or is to be undertaken or to any alternative site

where the activity is to be undertaken; (iii) owners and occupiers of land adjacent to the site where the activity is or is to be undertaken

or to any alternative site where the activity is to be undertaken;

Authority Consultation

Notification of the intention to commence with a Basic Assessment Process, was submitted to the

competent authority (DEDEAT: Sarah Baartman Region), as well as affected/ Juristic Organs of

State and State Departments on the 7 May 2021. Included in the notification was a Background

Information Document, comment form, locality map and a link to the project website where

available information can be downloaded. Correspondence sent to I&APs and relevant authorities

are attached as Appendix G(iii) to this report.

Affected/ Juristic Organs of State and State Departments which may be required to issue a licence

or permit prior to commencement of the project, will be consulted and are included on the project

database. Appendix G (vi), includes the authority database with their respective contact details.

All Public Participation documentation (Draft and Final Reports) will be sent to the competent

authority via email, as well as affected/ Juristic Organs of State and State Departments, which are

registered on the project database. The competent authority, affected/ Juristic Organs of State

and State Departments will be provided with a link to the project website, where the report can be

downloaded, as agreed to with the respective Department. Authorities are required to provide their

input on the proposed dam expansion within the timeframes stipulated. Input from the authorities

will be included in the Comments and Response report for the Basic Assessment Process.

Database Development, maintenance and ongoing Information Sharing

The applicant is the landowner.

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The following provides and outline of the approach to the development of the project

announcement database (Pre-Application Phase), as well as the maintenance of the database

and ongoing information sharing throughout the BA Process.

Prior to advertising the Basic Assessment Process, the EAP, drawing on experience in the local

SRV Municipal area, and the project database that was developed for the previous assessment,

developed an initial database of potential I&APs for the proposed expansion. Adjacent

landowners/ tenants were identified through deeds searches (Windeed) and, where required,

contact information was confirmed via telephonic/ email communication. This database included

amongst others, adjacent landowners/tenants, affected/ Juristic Organs of State and State

Departments as well as the competent authority (DEDEAT: Department of Economic

Development, Environmental Affairs and Tourism – Sarah Baartman Region), the Councillor for

Ward 8 and other potential I&APs (WESSA EP Region and CREW).

All potential I&APs were notified by means of Letter 1 sent via email, of intention to commence

with a Basic Assessment Process and the legislated 30-day comment period in which to raise

issues of concern for inclusion on the Consultation Basic Assessment Report (CBAR). Included in

this notification was a comment form and a Background Information Document (BID), including a

locality map of the proposed dam expansion. The 30-day comment and registration extended from

7 May 2021 to 7 June 2021. Prior to advertising the BA process, the project database included

31 Registered I&APs.

Comments were received from three I&APs, namely, Babalwa Layini (Department of Agriculture,

Forestry and Fisheries), Rudi Herholdt (SRVM: Infrastructure Planning and Development) and

Gcinile Dumse (Department of Agriculture, Land Reform and Rural Development).

All I&APs on the project database were notified via Letter 2, sent via email, of the release of the

CBAR for a 32-day comment period. The 32-day comment period extended from 01 September

2021 to 04 October 2021. At the time of the release of the CBAR, the project database included

31 Registered I&APs.

Subsequent to the release of the CBAR one I&AP, Ms Jayshree Govender requested to be

removed from all project databases. The project database for this assessment was amended

accordingly and prior to the submission of the FBAR the project database included 30 Registered

I&APs. Copies of correspondence sent to I&AP and authorities have been included in Appendix

G (iii) and a copy of the I&AP database has been submitted to DEDEAT in a separate document

accompanying the FBAR.

The identification and registration of I&APs has been ongoing for the duration of the BA Process.

While not required by the EIA regulations, those I&APs identified at the outset of the BA process

have remained on the project database, have been kept informed of all opportunities to comment

and have only been removed from the database by request.

(iv) the municipal councillor of the ward in which the site or alternative site is situated and any

organisation of ratepayers that represent the community in the area;

Cllr Kausele, Ward 8 Councillor for the Sundays River Valley Municipality (SRVM), has been included on the project database and provided with copies of all the relevant and available

correspondence. A copy of the project database is contained in Appendix G(ii) of this report.

(v) the municipality which has jurisdiction in the area;

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Mr Ted Pillay, acting SRVM Municipal Manager (MM) was included on the project database during the project announcement and registration phase of the assessment process. However, Mr Sydney Fadi has been reinstated as MM and has therefore replaced Mr Pillay on the project database. Mr Fadi will be provided with a link to the project website where available information can be downloaded. A copy of the authority database is contained in Appendix G(vi).

(vi) any organ of state having jurisdiction in respect of any aspect of the activity; and

The following affected/ Jurisitc Organs of State and State Department were proactively identified and included on the project database, prior to advertising the project (Pre-Application Phase) and have been notified of the various stages to comment during this BA Process:

• Maretha Alant – SANParks: Garden Route National Park: Environmental Manager

• Marisa Bloem – Dept. of Water and Sanitation Port Elizabeth: Water Use Authorisation Sector.

• Luzuko Dali – Dept. of Economic Development, Environmental Affairs and Tourism: Biodiversity Section

• Gcinile Dumse – Dept. Agriculture, Land Reform & Rural Development (DALRRD): Land Use and Soil Management.

• Peter Lotter - Eastern Cape Dept. of Transport

• Ruffus Maloma – Provincial Dept. of Rural Development and Agrarian Reform: Soil Scientist.

• Sello Mokhanya - Eastern Cape Provincial Heritage Resources Authority

• Randall Moore - Eastern Cape Dept. Transport: District Roads Engineer.

• Mike Primmer – Lower Sundays River Water Users Association

• Russel Smart – South African National Parks: Park Planning and Development Coordinator.

• Andries Struwig – Dept. of Economic Development, Environmental Affairs and Tourism: Deputy Director IEM.

• Ntombiyamayirha Mpumela – Dept. of Water and Sanitation Port Elizabeth.

• Anban Padayachee – SANParks: Senior Section Ranger

• Ted Pillay – Sundays River Valley Municipality: Acting Municipal Manager

• Ncamile Dweni – Dept. of Water and Sanitation Port Elizabeth

• Charlene Bissett – South African National Parks: Regional Ecologist

• Susan Fourie – Sundays River Valley Municipality: Archives Manager

• Babalwa Layini – Dept. of Agriculture Forestry and Fisheries

• Rudi Herholdt – Sundays River Valley Municipality: Infrastructure Planning and Development Mr Ted Pillay has been replaced by Mr Sydney Fadi as the Municipal Manager of the Sundays

River Valley Municipality. The database has thus been updated to capture this substitution. A copy

of the authorities’ database is contained in Appendix G (vi) of this report.

(vii) any other party as required by the competent authority;

(c) placing an advertisement in— (i) one local newspaper; or

(ii) any official Gazette that is published specifically for the purpose of providing public notice of applications or other submissions made in terms of these Regulations;

A newspaper advertisement appeared in “The Herald” on 7 May 2021. A copy of the advertisement is attached in Appendix G (i) of this report.

(d) placing an advertisement in at least one provincial newspaper or national newspaper, if the activity has

or may have an impact that extends beyond the boundaries of the metropolitan or local municipality in which it is or will be undertaken: Provided that this paragraph need not be complied with if an advertisement has been placed in an official Gazette referred to in subregulation 54(c)(ii); and

It is not anticipated that the proposed development will have any impact that will extend beyond the boundaries of the local municipality.

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(e) using reasonable alternative methods, as agreed to by the competent authority, in those instances

where a person is desiring of but unable to participate in the process due to— (i) illiteracy; (ii) disability; or (iii) any other disadvantage.

None have been identified to date

2. CONTENT OF ADVERTISEMENTS AND NOTICES A notice board, advertisement or notices must: (a) indicate the details of the application which is subjected to public participation; and (b) state—

(i) that the application has been submitted to the competent authority in terms of these Regulations, as the case may be;

(ii) whether basic assessment or scoping procedures are being applied to the application, in the case of an application for environmental authorisation;

(iii) the nature and location of the activity to which the application relates; (iv) where further information on the application or activity can be obtained; and (iv) the manner in which and the person to whom representations in respect of the application

may be made.

In line with these requirements an advert notifying all I&APs on the project database of the commencement of the Basic Assessment Process, appeared in “The Herald” on 7 May 2021 and a Notice Board was placed at the entrance of the site on 7 May 2021. A copy of the notice board and newspaper advert are included in Appendix G(i) of this report.

3. PLACEMENT OF ADVERTISEMENTS AND NOTICES Where the proposed activity may have impacts that extend beyond the municipal area where it is located, a notice must be placed in at least one provincial newspaper or national newspaper, indicating that an application will be submitted to the competent authority in terms of these regulations, the nature and location of the activity, where further information on the proposed activity can be obtained and the manner in which representations in respect of the application can be made, unless a notice has been placed in any Gazette that is published specifically for the purpose of providing notice to the public of applications made in terms of the EIA regulations. Advertisements and notices must make provision for all alternatives. A copy of the notice board and newspaper advert are contained in Appendix G(i) of the report.

4. DETERMINATION OF APPROPRIATE MEASURES The practitioner must ensure that the public participation is adequate and must determine whether a public meeting or any other additional measure is appropriate or not based on the particular nature of each case. Special attention should be given to the involvement of local community structures such as Ward Committees, ratepayers associations and traditional authorities where appropriate. Please note that public concerns that emerge at a later stage that should have been addressed may cause the competent authority to withdraw any authorisation it may have issued if it becomes apparent that the public participation process was inadequate.

The following is an overview of the Public Participation Process prosed for this Basic Assessment Process.

o Pre-Application Phase (Completed):

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o Project announcement, identification, notification, and registration of I&APs, including the competent authority, DEDEAT - Sarah Baartman Region (legislated 30-day comment period).

o Preliminary specialist input. o Application and Basic Assessment Phase: o Submission of Application Form for Environmental Authorisation to DEDEAT o Consultation Basic Assessment Report Review (legislated 30-day comment period). o Submission of Final Basic Assessment Report to DEDEAT (WE ARE HERE). o Decision Making and Appeal Period.

As indicated above, the BA Process has been divided into three phases. The purpose of this

approach is to, amongst others, achieve the following:

o To ensure I&APs (including the competent authority, affected/ Juristic Organs of State and State Departments) have access to information on the proposed project from the outset of the BA Process.

o To facilitate the identification of issues of concern, to inform the range of specialist studies being conducted for this BA.

o To assist in the identification of alternatives for assessment in this BA. o To facilitate the refinement of the project description and preferred development footprint

within the property under assessment.

o PRE-APPLICATION PHASE

Project Announcement, Identification, Notification and Registration of I&APs

In order to notify and inform the public, potential I&APs, affected/ Juristic Organs of State and

State Departments, as well as the competent authority, of the proposed project, the opportunity to

register as an I&AP, as well as to raise issues of concern, the BA Process was announced as

follows:

o Advertisement in One Local Newspaper:

o The Herald, 7 May 2021 (Provincial distribution).

o Site Notice Board:

o A notice board was placed on the fence at the entrance to Farm 633.

o Letter 1 to I&APs - Notice of the BA Process, Comment and Registration Period:

o Letter 1 included a Background Information Document (BID), locality map and

comment form. Written notification of the BA Process was sent to the competent

authority and to all I&APs, including affected/ Juristic Organs of State and State

Departments on the project database, on 7 May 2021, via email. A 30-day comment

and registration period was allowed for I&APs to register their interest on the project

database and raise issues of concern for inclusion in the CBAR. The comment

period extended from 7 May 2021 to 7 June 2021.

o Availability of Information - all project information has been made available on the

website www.publicprocess.co.za.

Appendix G(i) contains a copy of the newspaper advertisement placed in “The Herald”, as well as

photos of the site notice board placed at the entrance to Farm 633. Appendix G(iii) contains copies

of the correspondence sent to all I&APs and authorities and Appendix G(iv) contains copies of

correspondence received from I&APs and authorities in response to the project announcement.

Comments were received from three (3) Organs of State / State Departments during the project

announcement phase. These have been included in the Comments and Responses Report in

Appendix E of the report. All I&APs registered on the project database were notified of the release

of the CBAR for a legislated 30-day review period.

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o APPLICATION AND BASIC ASSESSMENT PHASE

This phase in the BA Process entails the following, which is outlined in more detail below: o Submission of Application Form for Environmental Authorisation to DEDEAT. o Consultation Basic Assessment Report Review (legislated 30-day comment period). o Submit Final Basic Assessment Report to DEDEAT.

Submission of Application Form for Environmental Authorisation to DEDEAT This step entails the submission of the Application Form for Environmental Authorisation to the competent authority (DEDEAT – Sarah Baartman Region), which has 10 days within which to respond to the submission of the application. An electronic copy of the application form, including cover letter was emailed in pdf format to Dayalan Govender and Andries Struwig (DEDEAT- Sarah Baartman Region; Competent Authority) on 31 August 2021. Charmaine Struwig was copied in on this email correspondence. On 01 September 2021 correspondence was received from Ms Struwig to confirm that the application was deemed correct and complete and that the application had been registered on DEDEAT’s system. The Reference Number assigned to the application is EC06/C/LN3/16/48-2021 and the case officer assigned is Ms Nokulunga Ludidi. Ms Ludidi was subsequently added to the database. The applicant must within 90 days of receipt of the application by the competent authority, submit a Basic Assessment Report, inclusive of specialist reports and EMPr, to the competent authority, which has been subjected to a Public Participation Process of at least 30 days and which reflects the incorporation of comments received form I&APs, including any comments from the competent authority. Failure to comply with these timeframes will result in the application having deemed to be lapsed by the competent authority. Consultation Basic Assessment Report Review

In parallel to the submission of the Application Form to the competent authority, the CBAR was released for a minimum legislated 30-day comment period which extended from 01 September 2021 to 04 October 2021. The following indicates the process for the distribution of information during the review of the CBAR:

o Letter 2 to I&APs - Notification of comment period on the CBAR: o All I&APs on the project database were notified of the comment period on the CBAR via

email, which included an executive summary of the CBAR, as well as a Comment Form. o Affected / Juristic Organs of State and State Departments were provided with a

copy of the CBAR, in the format as agreed to with the respective Departments, namely, emailed link to the report on the website or electronic version of the report via email.

o Project information available for the CBAR was placed on the project website: www.publicprocess.co.za

o No telephonic consultations or virtual meetings were requested by I&APs or Organs of State during the comment period.

o Submission of the CBAR to DEDEAT: o Dayalan Govender and Andries Struwig were emailed notification regarding the 30-

day comment period to be provided for the Consultation BAR and this included a link to the project website where the report could be downloaded. Charmaine Struwig was copied in on this email correspondence. Ms Nokulunga Ludidi was assigned as the case officer for this application and was consequently included on the project database and provided with a copy of the notification above. Acknowledgement of Receipt of the Application Form and CBAR was received from Ms Ludidi on 15 September 2021. Correspondence received from DEDEAT is included in Appendix G(iv) of this report.

Copies of all correspondence sent to I&APs are attached as Appendix G(iii) of this report. A comment was received from one (1) I&AP requesting to deregister during the review of the CBAR. Appendix G(iv) contains copies of correspondence received from I&APs and authorities. Apart

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from the request to deregister, no additional issues were raised during the CBAR review period for inclusion in the Comments and Responses Report, attached as Appendix E..

Submission of Final Basic Assessment Report to DEDEAT (WE ARE HERE NOW)

The FBAR, inclusive of specialist reports and EMPr, will be submitted to competent authority for their decision-making, within 90 days of submission of the Application Form. The FBAR includes all the comments received from I&APs during the Pre-Application (Project Announcement), as well as the Application and BA Phase (CBAR) of the assessment. The following indicates the process for the distribution of information during the submission of the FBAR:

o Letter 3 to I&APs – Notification of the submission of the FBAR: o All I&APs, including the competent authority, affected/ Juristic Organs of State and State

departments will be notified of the submission of the FBAR via email. o No additional comment period is proposed for the FBAR. o The competent authority, affected/ Juristic Organs of State and State Departments will be

provided with a copy of the FBAR, in the format as agreed to with the respective Departments, namely, emailed link to the report on the website or electronic version of the report via email.

o Availability of Information - all project information will be made available on the website www.publicprocess.co.za.

The competent authority (DEDEAT- Sarah Baartman Region) will have 107 days from receipt of the FBAR, inclusive of specialist reports and EMPr, to either grant Environmental Authorisation in respect of all or part of the activity applied for; or refuse Environmental Authorisation.

o DECISION MAKING AND APPEAL PERIOD

In terms of Regulation 4 (2) of the NEMA EIA Regulations 2014 (as amended), the applicant must, in writing, within 14 days of the date of the decision on the application by the competent authority, notify all I&APs on the project database of the decision and provide them with access to the decision and reasons for the decision, as well as draw their attention to the fact that an appeal may be lodged against the decision in terms of the National Appeal Regulations. The following indicates the process for the notification of I&APs of the decision on the application by the competent authority:

o Letter 4 to I&APs – Notification of the decision and appeal period: o All I&APs, including affected/ Juristic Organs of State and State departments will be notified

of the decision reached by the competent authority, via email. o A copy of the Environmental Authorisation, granted, partially granted or refused, will be

placed on the website www.publicprocess.co.za o Letter 5 to I&APs – Notification of the outcome of the appeal period: o All I&APs on the project database will be notified, via email, of the outcome of the appeal

period if an appeal is lodged. Identification of Issues for Inclusion in the Basic Assessment Report

An important element of the BA Process is to identify issues for inclusion in the BAR and to record comments received from I&APs, including the competent authority, affected/ Juristic Organs of State and State Departments. These comments provide input towards the assessment of alternatives and the scope of the specialist assessments proposed for the BA Process. While all I&APs have confirmed that they have sufficient data to access reports from the project website, should they indicate, at any stage during the assessment process, that this is no longer the case, the EAP will supply data in order to facilitate access to the report. However, this will be subject to the condition that proof is submitted to the EAP that the data was utilised to view/download the reports (e.g. screenshot of the report). Copies of comments received from I&APs have been included in Draft and Final reports for submission to the competent authority. Comments have been received from three (3) Organs of

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State / State Departments and one (1) I&AP. The issues raised can be divided into the following categories:

o Public Participation o Licensing Requirements for Protected Tree Species o Protection of Agricultural Resources (erosion, alien vegetation, water resources)

As required by the NEMA EIA Regulations, 2014 (as amended), this report includes a Comments and Responses Report (See Appendix E) which outlines the issues raised, by whom, the date and manner of receipt of the comment. A response to the issue raised has been provided by the EAP, relevant specialist or the project applicant and where the issue raised falls outside of the scope of this BA, clear reasoning for such has been provided. Compliance with the Protection of Personal Information Act 4 of 2013 The Protection of Personal Information Act 4 of 2013 (POPIA) was enacted to give effect to the constitutional right to privacy by safeguarding personal information processed by a responsible party. As required by Regulation 42 of the NEMA EIA Regulations, 2014 (as amended), any contact information (e.g. telephone number, email address and postal address) will be included on the I&AP database for the duration of the assessment process, and will be submitted to the competent authority, DEDEAT (Sarah Baartman Region). The I&AP register will not be included in the FBAR, nor will it be provided to any other third parties without the explicit consent of the I&APs. In compliance with Regulation 44 of the EIA Regulations, any information contained in comments made during the assessment process will be included in the reports that are made available for public review. However, this will not include personal contact information. In addition, should an appeal be lodged against the DEDEAT’s decision, the appellant will be provided with a copy of the I&AP register, containing contact information, in order to comply with Regulation 4 (1) of the National Appeal Regulations, 2014.

5. COMMENTS AND RESPONSE REPORT The practitioner must record all comments and respond to each comment of the public before the application is submitted. The comments and responses must be captured in a comments and response report as prescribed in the EIA regulations and be attached to this application. The comments and response report must be attached under Appendix E.

The Comments raised during the assessment process have been included in the Comments and Responses Report included in Appendix E of this report

6. AUTHORITY PARTICIPATION

Authorities are key interested and affected parties in each application and no decision on any application will be made before the relevant local authority is provided with the opportunity to give input. The planning and the environmental sections of the local authority must be informed of the application at least 30 (thirty) calendar days before the submission of the application. List of authorities informed:

• Maretha Alant – Garden Route National Park: Environmental Manager

• Marisa Bloem – Dept. of Water and Sanitation Port Elizabeth: Water Use Authorisation Sector.

• Luzuko Dali – Dept. of Economic Development, Environmental Affairs and Tourism: Biodiversity Section

• Gcinile Dumse – Dept. of Agriculture, Land Reform & Rural Development (DALRRD): Land Use and Soil Management.

• Peter Lotter - Eastern Cape Dept. of Transport

• Ruffus Maloma – Provincial Dept. of Rural Development and Agrarian Reform: Soil Scientist.

• Sello Mokhanya - Eastern Cape Provincial Heritage Resources Authority

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• Randall Moore - Eastern Cape Dept. Transport: District Roads Engineer.

• Mike Primmer – Lower Sundays River Water Users Association

• Russel Smart – South African National Parks: Park Planning and Development Coordinator.

• Andries Struwig – Dept. of Economic Development, Environmental Affairs and Tourism: Deputy Director IEM.

• Ntombiyamayirha Mpumela – Dept. of Water and Sanitation Port Elizabeth.

• Anban Padayacee – South African National Parks: Senior section Ranger

• Ted Pillay – Sundays River Valley Municipality: Acting Municipal Manager

• Ncamile Dweni – Dept. of Water and Sanitation Port Elizabeth

• Charlene Bissett – South African National Parks: Regional Ecologist

• Susan Fourie – Sundays River Valley Municipality: Archives Manager


• Rudi Herholdt – Sundays River Valley Municipality: Infrastructure Planning and Development Mr Ted Pillay has been replaced by Mr Sydney Fadi as the Municipal Manager of the Sundays River Valley Municipality.

List of authorities from whom comments have been received: Projection Announcement and Registration Phase


• Gcinile Dumse - Provincial Dept. Agriculture, Land Reform & Rural Development (DALRRD): Land Use and Soil Management.

• Rudi Herholdt – Sundays River Valley Municipality: Infrastructure Planning and Development

7. CONSULTATION WITH OTHER STAKEHOLDERS

Note that, for linear activities, or where deviation from the public participation requirements may be appropriate,

the person conducting the public participation process may deviate from the requirements of that subregulation

to the extent and in the manner as may be agreed to by the competent authority.

Any stakeholder that has a direct interest in the site or property, such as servitude holders and service providers, should be informed of the application at least 30 (thirty) calendar days before the submission of the application and be provided with the opportunity to comment.

Has any comment been received from stakeholders? YES NO

If “YES”, briefly describe the feedback below (also attach copies of any correspondence to and from the stakeholders to this application):

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SECTION D: IMPACT ASSESSMENT

The assessment of impacts must adhere to the minimum requirements in the EIA Regulations, 2014 as

amended, and should take applicable official guidelines into account. The issues raised by interested and

affected parties should also be addressed in the assessment of impacts.

IMPACT ASSESSMENT METHODOLOGY

As per GN R326 Appendix 1, 3. (1) (h) the assessment of impacts must include the alternatives to be

assessed within the preferred site, including the option of not proceeding with the activity. The impact

assessment methodology has been aligned with the requirements for Basic Assessment Reports, as

stipulated in GN R326 Appendix 1, 3. (1) of the 2014 EIA Regulations (as amended), which states the

following:

“A basic assessment report must contain the information that is necessary for the competent

authority to consider and come to a decision on the application, and must include—

(h) a full description of the process followed to reach the proposed preferred alternative within the

site, including—

(v) the impacts and risks identified for each alternative, including the nature, significance,

consequence, extent, duration and probability of the impacts, including the degree to which

these impacts—

(aa) can be reversed;

(bb) may cause irreplaceable loss of resources; and

(cc) can be avoided, managed or mitigated;

(vi) the methodology used in determining and ranking the nature, significance, consequences,

extent, duration and probability of potential environmental impacts and risks associated with

the alternatives;

(vii) positive and negative impacts that the proposed activity and alternatives will have on the

environment and on the community that may be affected focusing on the geographical,

physical, biological, social, economic, heritage and cultural aspects;

(viii) the possible mitigation measures that could be applied and level of residual risk;

(ix) the outcome of the site selection matrix;

(i) a full description of the process undertaken to identify, assess and rank the impacts the activity will

impose on the preferred location through the life of the activity, including—

(i) a description of all environmental issues and risks that were identified during the environmental

impact assessment process; and

(ii) an assessment of the significance of each issue and risk and an indication of the extent to

which the issue and risk could be avoided or addressed by the adoption of mitigation measures;”

As per Guideline Document 5: Assessment of Alternatives and Impacts, the following methodology is

to be applied to the prediction and assessment of impacts and risks. Potential impacts should be rated

in terms of the direct, indirect and cumulative.

• Direct impacts are impacts that are caused directly by the activity and generally occur at the same

time and at the place of the activity. These impacts are usually associated with the construction,

operation or maintenance of an activity and are generally obvious and quantifiable.

• Indirect impacts of an activity are indirect or induced changes that may occur as a result of the

activity. These types of impacts include all the potential impacts that do not manifest immediately

when the activity is undertaken or which occur at a different place as a result of the activity.

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• Cumulative impacts are impacts that result from the incremental impact of the proposed activity

on a common resource when added to the impacts of other past, present or reasonably foreseeable

future activities. Cumulative impacts can occur from the collective impacts of individual minor

actions over a period of time and can include both direct and indirect impacts.

• Spatial extent – The size of the area that will be affected by the impact/ risk

o Site specific

o Local (<2 km from site)

o Regional (within 30 km of site)

o National

• Consequence/ Intensity –The anticipated severity of the impact/ risk

o Extreme (extreme alteration of natural systems, patterns or processes, i.e. where

environmental functions and processes are altered such that they permanently cease)

o High (severe alteration of natural systems, patterns or processes i.e. where environmental

functions and processes are altered such that they temporarily or permanently cease)

o Medium (notable alteration of natural systems, patterns or processes i.e. where the

environment continues to function but in a modified manner)

o Low (negligible alteration of natural systems, patterns or processes i.e. where no natural

systems/environmental functions, patterns, or processes are affected)

• Duration –The timeframe during which the impact/ risk will be experienced

o Temporary (less than 1 year)

o Short term (1 to 6 years)

o Medium term (6 to 15 years)

o Long term (the impact will cease after the operational life of the activity)

o Permanent (mitigation will not occur in such a way or in such a time span that the impact can

be considered transient)

• Reversibility – The degree to which the potential impacts/ risks can be reversed

o Reversible

o Partially Reversible

o Irreversible

• Irreplaceable loss of Resources - The degree to which the impact/ risk may cause irreplaceable

loss of resources

o Replaceable

o Partially Replaceable

o Irreplaceable

Using the criteria above, the impacts will further be assessed in terms of the following:

• Probability –The probability of the impact/ risk occurring

o Improbable (little or no chance of occurring)

o Probable (<50% chance of occurring)

o Highly probable (50 – 90% chance of occurring)

o Definite (>90% chance of occurring)

• Significance – Will the impact/ risk cause a notable alteration of the environment?

o Low to very low (the impact/risk may result in minor alterations of the environment and can be

easily avoided by implementing appropriate mitigation measures, and will not have an

influence on decision-making)

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o Medium (the impact /risk will result in moderate alteration of the environment and can be

reduced or avoided by implementing the appropriate mitigation measures, and will only have

an influence on the decision-making if not mitigated).

o High (the impact/risk will result in major alteration to the environment even with the

implementation of the appropriate mitigation measures and will have an influence on decision-

making)

o Very high (the impact/impact will result in very major alteration to the environment even with

the implementation on the appropriate mitigation measures and will have an influence on

decision-making i.e. the project cannot be authorised unless major changes to the engineering

design are carried out to reduce the significance rating).

• Status - Whether the impact/ risk on the overall environment will be positive, negative or neutral

o “+” (positive - environment overall will benefit from the impact/risk).

o “-“ (negative - environment overall will be adversely affected by the impact/risk).

o “o” (neutral - environment overall will not be affected).

• Confidence – The degree of confidence in predictions based on available information and

specialist knowledge

o Low

o Medium

o High

Impacts, mitigatory measures and the monitoring of impacts will then be collated into the EMPr and

these will include the following:

• Quantifiable standards for measuring and monitoring mitigatory measures and enhancements will

be set. This will include a programme for monitoring and reviewing the recommendations to ensure

their ongoing effectiveness.

• Identifying negative impacts and prescribing mitigation measures to avoid or reduce negative

impacts. Where no mitigatory measures are possible this will be stated.

• Positive impacts will be identified, and mitigation measures will be identified to potentially enhance

positive impacts where possible.

Management Actions and Monitoring of the Impacts:

• Where negative impacts are identified, mitigatory measures will be identified to avoid or reduce

negative impacts. Where no mitigatory measures are possible this will be stated.

• Where positive impacts are identified, mitigatory measures will be identified to potentially enhance

positive impacts.

The table below is to be used by specialists for the rating of impacts:

Table 1.1: Rating of impacts.

Nature of the Impact This should include a description of the proposed impact to indicate if the impact is a direct, indirect or a cumulative impact.

Extent Site specific, local, regional or national

Duration Temporary, short term, medium term, long term or permanent

Consequence /Intensity Extreme, High, medium or low

Probability Improbable, probable, highly probable, definite

Degree of Confidence Low, medium or High

Reversibility Reversible, Partially Reversible, Irreversible

Irreplaceable Loss of Resources

Replaceable, Partially Replaceable, Irreplaceable

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Status and Significance (without mitigation)

Low, medium or High indicating whether Positive (+), Negative (-) or Neutral (o)

Mitigation Overview of mitigatory measures to mitigate potentially negative impacts or enhance potential positive impacts indicating how this mitigatory measure impacts on the significance of the impact

Status and Significance (after mitigation)

Low, medium or High indicating whether the status of the impact is Positive (+), Negative (-) or Neutral (o)

Other aspects to be taken into consideration in the assessment of impact significance are:

• Impacts will be evaluated for the construction and operational phases of the project: o NOTE: No assessment of impacts during the decommissioning phase of the project is proposed.

The relevant guidelines and rehabilitation requirements applicable at that time will need to be applied.

• Impacts will be evaluated with and without mitigation in order to determine the effectiveness of mitigation measures on reducing the significance of a particular impact; and

• The impact evaluation will, where possible, take into consideration the cumulative effects associated with this and other projects which are either developed or in the process of being developed in the local area.

• The impact assessment will attempt to quantify the magnitude of potential impacts (direct and cumulative effects) and outline the rationale used. Where appropriate, National standards are to be used as a measure of the level of impact.

1. ISSUES RAISED BY INTERESTED AND AFFECTED PARTIES

List the main issues raised by interested and affected parties.

Project Announcement and Registration Phase

Comments were received form three (3) I&APs during the project announcement and registration

phase as follows:

EIA and Public Participation Process

1.) Mr. Rudi Herholdt (SRVM: Infrastructure Planning and Development) acknowledged receipt of

the emailed correspondence, notifying him of the Basic Assessment Process.

Licensing Requirements

1.) Ms. Babalwa Layini (Department of Agriculture, Forestry and Fisheries) acknowledged receipt

of correspondence, notifying of the Basic Assessment Process and indicated the requirement for

licensing if protected natural forest or tree species are disturbed by the proposed dam expansion.

Protection of Agricultural Resources

1.) Mr. Gcinile Dumse (Dept. Agriculture, Land Reform & Rural Development (DALRRD): LUSM)

recommended measures to be employed to protect agricultural resources including soil

management practices, control of alien invasive vegetation and the protection of wetlands and

rivers.

Review of the Consultation Basic Assessment Report

Comments were received form one (1) I&AP during the review of the Consultation Basic

Assessment Report as follows:


1.) Ms. Jayshree Govender requested to be deregister for the project database

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Response from the practitioner to the issues raised by the interested and affected parties (A full response must be given in the Comments and Response Report that must be attached to this report):

Project Announcement and Registration Phase


1.) Noted

Licensing Requirements

1.) No natural forest or protected tree species have been identified within the proposed dam

expansion footprint.

Protection of Agricultural Resources 1.) The mitigation measures recommended by the commentator have been included in the Draft Construction EMPr and Operational EMPr, where applicable. This includes the development of a soil erosion plan and a weed control management plan (alien invasive plants management plan). The proposed dam expansion is located more than 500 metres from the Sundays River and no other natural water resources are located in close proximity to the proposed expanded dam. These natural resources are therefore not anticipated to be disturbed by the proposed expansion. Review of the Consultation Basic Assessment Report EIA and Public Participation Process

1.) Ms Jayshree Govender was subsequently removed from the project database.

2. IMPACTS THAT MAY RESULT FROM THE PLANNING AND DESIGN, CONSTRUCTION, OPERATIONAL, DECOMMISSIONING AND CLOSURE PHASES AS WELL AS PROPOSED MANAGEMENT OF IDENTIFIED IMPACTS AND PROPOSED MITIGATION MEASURES

List the potential direct, indirect and cumulative property/activity/design/technology/operational alternative related impacts (as appropriate) that are likely to occur as a result of the planning and design phase, construction phase, operational phase, decommissioning and closure phase, including impacts relating to the choice of site/activity/technology alternatives as well as the mitigation measures that may eliminate or reduce the potential impacts listed.

1. CONSTRUCTION PHASE

DIRECT IMPACTS:

➢ Demolition and upgrading of existing farm (earth wall) dam

No natural wetland habitat will be lost. However, as the dam walls are removed or adjusted, a large volume of water could be released.

Extent: Local Duration: Short-term Intensity: Low Probability: Probable Reversibility: N/A Irreplaceable Loss of Resources: No Degree of Confidence: High Status and Significance of Impact (no mitigation): Low Negative (-) Mitigation

• Any water currently within the dam should be removed/ utilised so that no/ little water leaves as the wall is removed. This would limit large volumes of water being lost and reduce the potential for erosion.

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Significance and Status (with mitigation): Low Positive (+)

➢ Dust generation during the construction phase

During construction, it is anticipated that some degree of dust pollution will be generated from construction activities, as the site will require levelling and earth moving activities. Soils will be largely bare and unconsolidated and thus vulnerable to erosion by wind and water. Vehicular and pedestrian movement over loose ground and unpaved roads may generate dust. Dust may also be generated from soil stockpiles on site.

Extent: Local Duration: Temporary Intensity: Medium Probability: Highly Probable Reversibility: Reversible Irreplaceable Loss of Resources: Partially Replaceable Degree of Confidence: High Status and Significance of Impact (no mitigation): Medium Negative (-) Mitigation

• Limit disturbance outside the construction footprints.

• Erosion protection measures to be placed on disturbed areas in case of heavy rainfall events during construction.

• Topsoil to be removed and stockpiled separately.

• Topsoil and soil stockpiles must be covered, wetted or otherwise stabilised to prevent wind erosion and dust generation.

• A water cart must be employed on windy days to wet soils that would be prone to wind erosion to limit dust generation.

• The earthen dam walls must be scarified horizontally after completion of construction, to loosen compacted soil and to reduce downslope erosion and then seeded with an appropriate grass seed mix. Such a seed mix should include indigenous grass seed and/or seed that will germinate timeously and achieve a good cover, that is available from local sources (i.e. farmers co-op).

• Appropriate measures to be implemented to stabilise the dam overflow to minimise risk of erosion in the unlikely event of an overflow occurring.

• Compile and implement an Environmental Management Programme which includes erosion protection measures.

• Erosion to be monitored and included in audit reporting by an Environmental Control Officer during construction.

Significance and Status (with mitigation): Low Negative (-)

➢ Noise and disturbance during the construction phase

Some level of noise and disturbance is anticipated during the construction activities, which is mostly unavoidable but can be mitigated.

Extent: Local Duration: Temporary Intensity: Medium Probability: Definite Reversibility: Reversible Irreplaceable Loss of Resources: N/A Degree of Confidence: High Status and Significance of Impact (no mitigation): Medium Negative (-) Mitigation

• Limit activities, as far as possible, to working hours (i.e. 7am-6pm weekdays).

• Encourage personnel to not make unnecessary noise.

• No loud music to be played on site.

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• Signage with the contact details of the responsible person must be provided at the site, for residents with complaints in this regard.

• A complaints register must be kept to document complaints and the corrective action taken. Significance and Status (with mitigation): Very Low Negative (-)

➢ Impact on Provincial Roads

The proximity of the proposed expanded dam to the road which runs adjacent to the property boundary may result in an impact on the road, possibly causing seepage and thus influencing the road structure. The increased activity by heavy vehicles during the construction phase may damage the road surface. However, it is anticipated that the earth moving equipment and machinery will be stored on site for the duration of the Construction Phase.

Extent: Local Duration: Temporary Intensity: Medium Probability: Improbable Reversibility: Reversible Irreplaceable Loss of Resources: Replaceable Degree of Confidence: High Status and Significance of Impact (no mitigation): Medium Negative (-) Mitigation

• Keep construction and earth-moving vehicles on site during construction phase. Significance and Status (with mitigation): Very Low Negative (-)

➢ Temporary employment and skills development opportunities will be created during the construction phase

Extent: Local Duration: Short-term Intensity: High Probability: Definite Reversibility: Irreversible Irreplaceable Loss of Resources: N/A Degree of Confidence: High Status and Significance of Impact (no mitigation): Low Positive (+) Mitigation

• Local labour must be sourced as far as possible, to maximise the economic benefits for the local community.

Significance and Status (with mitigation): Low Positive (+)

➢ Runaway bush fires during the construction phase

Extent: Local Duration: Short-term Intensity: High Probability: Probable Reversibility: Partially Irreversible Irreplaceable Loss of Resources: Partially Replaceable Degree of Confidence: High Status and Significance of Impact (no mitigation): High Negative (-) Mitigation

• At the site, exotic tree and shrub species must be eradicated and all litter removed.

• No open fires should be allowed on the site, except in a designated controlled area.

• No fires to be left unattended.

• Suitable firefighting equipment should be available on site. Significance and Status (with mitigation): Low Negative (-)

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➢ Generation of waste during the construction phase

The generation of waste is anticipated to be limited to litter by construction personnel.

Extent: Site specific Duration: Temporary Intensity: Medium Probability: Probable Reversibility: Reversible Irreplaceable Loss of Resources: Replaceable Degree of Confidence: High Status and Significance of Impact (no mitigation): Medium Negative (-) Mitigation

• No waste from construction or otherwise, may be disposed of on site.

• No construction phase waste to be stockpiled on site.

• All waste may be temporarily sorted at site before being suitably disposed of at an appropriately licensed and registered waste disposal facility.

• Collection of waste to be contracted to an approved contractor and disposed of at an appropriately licenced site. Safe disposal certificate to be obtained and kept as a record.

• Hazardous waste generated at the site should be disposed of at a suitably licensed hazardous waste disposal facility.

• Adequate litter drums or other suitable containers must be located on site and emptied on a weekly basis at a minimum and waste disposed of at an appropriately licensed waste disposal facility

• Appropriate ablutions facilities to be provided on site. If portable toilets are utilised these must be emptied timeously.

• Environmental Officer to perform frequent audits in the waste storage area. Significance and Status (with mitigation): Very Low Negative (-)

➢ Generation of hazardous waste during the construction phase

Small amounts of hazardous waste such as oil, grease, or chemicals may be generated on site. These will be stored in a secure facility on site until it can be disposed of at an appropriately licensed hazardous waste disposal facility.

Extent: Site specific Duration: Temporary Intensity: Low Probability: Probable Reversibility: Reversible Irreplaceable Loss of Resources: Replaceable Degree of Confidence: High Status and Significance of Impact (no mitigation): Medium Negative (-) Mitigation

• Hazardous waste from construction activities to be separated and stored in acceptable receptacles and disposed to appropriately licenced site.

• Hazardous waste to be classified, Safety Data Sheets to be compiled and waste manifest to record the generation, transporting and disposal of the waste.

• Initial waste classification to be performed on all hazardous waste generated.

• Environmental Officer to perform frequent audits in the waste storage area.

• Monthly waste disposal record must be kept of all waste disposed.

• Spill response plans and equipment should be available to deal with emergency situations that can arise during the management of waste.

• All staff should be trained in the correct handling, storage and disposal of hazardous wastes. Significance and Status (with mitigation): Very Low Negative (-)

➢ Generation of sanitation waste during the construction phase

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Extent: Site specific Duration: Temporary Intensity: Medium Probability: Highly Probable Reversibility: Reversible Irreplaceable Loss of Resources: N/A Degree of Confidence: High Status and Significance of Impact (no mitigation): Medium Negative (-) Mitigation

• Suitable potable sanitation facilities must be provided and maintained for the construction personnel during the Construction Phase.

• Ensure weekly maintenance of sanitation facilities.

• Enter into a contract agreement with a service provider to regularly collect and dispose of sanitary waste at an authorized sewerage treatment works.

Significance and Status (with mitigation): Neutral (0) ➢ The exposure of significant archaeological or palaeontological heritage remains during

the construction phase

Extent: Site specific Duration: Permanent Intensity: Medium Probability: Improbable Reversibility: Irreversible Irreplaceable Loss of Resources: Irreplaceable Degree of Confidence: High Status and Significance of Impact (no mitigation): High Negative (-) Mitigation

• In the event of such finds being uncovered, (during any phase of construction work), it must be reported to the archaeologist / palaeontologist at the Albany Museum (Tel. 046 6222312) or to the Eastern Cape Provincial Heritage Resources Authority (Tel. 043 6422811) immediately. All work must stop to allow a systematic and professional investigation. Sufficient time should be allowed to remove/ collect such material (Possible archaeological sites that maybe found in the area is appended to this EMP Report as Appendix One).

• The developer must finance the costs should additional studies be required as outlined above. The onus is also on the developer to ensure that this agreement is honoured in accordance with the National Heritage Act No. 25 of 1999.

Significance and Status (with mitigation): Neutral (0) INDIRECT IMPACTS:

➢ General health and safety risks associated with the construction personnel activities on site

With construction activities and the associated personnel comes potential on-site risks such as fires and waste generation or pollution.

Extent: Local Duration: Short-term Intensity: Medium Probability: Probable Reversibility: Reversible Irreplaceable Loss of Resources: N/A Degree of Confidence: High Status and Significance of Impact (no mitigation): Medium Negative (-) Mitigation

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• Construction personnel must not be allowed to light fires on site.

• Construction personnel may not stay on site after working hours or set up temporary residences.

• Ablution facilities must be provided to construction personnel to prevent ablutions being performed in public.

• Litter bins must be provided at the construction footprint for waste generated by construction personnel.

• Litter bins must be emptied on a weekly basis at a minimum and waste disposed of at an appropriately licensed waste disposal facility.

Significance and Status (with mitigation): Low Negative (-) ➢ Risk to human health and safety due to open excavations and earth moving machinery

during the construction phase

Extent: Site Specific Duration: Short-term Intensity: High Probability: Definite Reversibility: Reversible Irreplaceable Loss of Resources: N/A Degree of Confidence: High Status and Significance of Impact (no mitigation): High Negative (-) Mitigation

• All footprints, excavations, storage areas, materials lay-down areas, stockpile area, and labourers rest areas must be clearly demarcated or fenced off before any construction activities commence on site.

• All activities must be limited to the demarcated area.

• Open excavations must be kept free of water.

• Access to the site must be controlled.

• Entry points and access routes to the site must be clearly marked and traffic limited to those areas as far as possible.

• Speed travelled by vehicles must be kept to a minimum and speed limits enforced.

• Conduct a safety reminder talk with personnel prior to commencement of construction.

Significance and Status (with mitigation): Very Low Negative (-)

CUMULATIVE IMPACTS:

None Anticipated 2. OPERATIONAL PHASE

DIRECT IMPACTS:

➢ Loss of agricultural land

The proposed expansion will result in the loss of ~2.1ha of land that is zoned for agriculture. However, the proposed dam expansion will increase the applicant’s irrigation water supply security and thus support the existing agricultural activities on the farm.

Extent: Site Specific Duration: Permanent Intensity: Low Probability: Definite Reversibility: Irreversible Irreplaceable Loss of Resources: Partially Replaceable Degree of Confidence: Medium Status and Significance of Impact (no mitigation): Very Low Negative (-) Mitigation

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• No mitigation is proposed.

Significance and Status (with mitigation): Very Low Negative (-) ➢ Increase in size of dam walls (inundated habitat) and water surface area

An increase in the potential aquatic habitat would occur due to an increase in available emergent habitat. This would result in the creation of reedbeds (Phragmites) as is typically seen within the region.

Extent: Local Duration: Long-term Intensity: Low Probability: Probable Reversibility: Reversible Irreplaceable Loss of Resources: No Degree of Confidence: High Status and Significance of Impact (no mitigation): Low (Positive) Mitigation

• Habitat will return over a period and no intervention is required.

• Removal of alien invasive species on and around the dam should be conducted annually.

Significance and Status (with mitigation): Low (Positive) ➢ Erosion of dam walls

Erosion of dam walls could lead to downstream sedimentation and possible failure of the wall itself.

Extent: Local Duration: Short-term Intensity: Low Probability: Probable Reversibility: Reversible Irreplaceable Loss of Resources: No Degree of Confidence: High Status and Significance of Impact (no mitigation): Low (Negative) Mitigation

• The walls must be inspected on a regular basis (quarterly or after heavy rainfall events) and any erosion must be rectified immediately through fill and compaction of disturbed areas.

• The walls should also be vegetated during the construction phase, using local grass species to assist with erosion protection.

Significance and Status (with mitigation): Low (Positive) ➢ Noise of the pumping infrastructure during the operational phase

Some noise may be created by the pumping infrastructure during irrigation. Given that there is an existing dam, it is unlikely that this existing impact will increase significantly.

Extent: Local Duration: Permanent Intensity: Low Probability: Definite Reversibility: Reversible Irreplaceable Loss of Resources: N/A Degree of Confidence: High Status and Significance of Impact (no mitigation): Very Low Negative (-) Mitigation

• Limit pumping activities, as far as possible, to working hours (i.e. 7am-6pm weekdays).

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Significance and Status (with mitigation): Very Low Negative (-) to Neutral (0) CUMULATIVE IMPACTS:

None anticipated. 3. NO-GO ALTERNATIVE

DIRECT IMPACTS:

➢ Not securing irrigation water supply for future agricultural activities

The farm is currently under cultivation with citrus orchards. Should an emergency situation arise where there is no access to LSRWUA canal water for a period, this could have severe consequences on the applicant’s ability to sufficiently irrigate the orchards with the result that the trees could die or not produce sufficient fruit.

Extent: Local Duration: Permanent Intensity: Low Probability: Definite Reversibility: Reversible Irreplaceable Loss of Resources: N/A Degree of Confidence: High Status and Significance of Impact (no mitigation): High Negative (-) Mitigation

• Expand the dam so as to have an emergency back-up supply of about 1 months’ capacity to prevent the potential financial losses associated with insufficient irrigation water supply to the existing orchards.

Significance and Status (with mitigation): Neutral (0) INDIRECT IMPACTS:

➢ Non-realisation of job creation and skills development for the local community

Extent: Local Duration: Permanent Intensity: Low Probability: Definite Reversibility: Reversible Irreplaceable Loss of Resources: N/A Degree of Confidence: High Status and Significance of Impact (no mitigation): High Negative (-) Mitigation

• None Proposed

Significance and Status (with mitigation): High Negative (-)

CUMULATIVE IMPACTS:

None anticipated. 3. ENVIRONMENTAL IMPACT STATEMENT

Taking the assessment of potential impacts into account, please provide an environmental impact statement that summarises the impact that the proposed activity and its alternatives may have on the environment after the management and mitigation of impacts have been taken into account, with specific reference to types of impact, duration of impacts, likelihood of potential impacts actually occurring and the significance of impacts.

Alternative A (preferred alternative)

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The proposed expansion of the existing farm dam is anticipated to have an overall LOW NEGATIVE

impact on the receiving environment during the construction phases, if all the recommended

mitigation measures are applied. In the operational phase, the overall impact is VERY LOW

NEGATIVE to NEUTRAL.

Ecological impacts are not anticipated to be significant, as the site is largely modified, and the

Sundays River and riparian habitat is located ~550m from the proposed dam expansion footprint.

However, with the application of the proposed mitigation measures it has been rated as a LOW

NEGATIVE impact, which has a less than 50% chance of occurring. An increase in the potential

aquatic habitat would occur due to an increase in available emergent habitat associated with the

expanded dam (larger water surface area). This impact has been rated as a LOW POSITIVE.

Socio-economic impacts which have been identified, which include the generation of noise and dust,

as well as health and safety impacts, can also be mitigated to LOW or VERY LOW NEGATIVE.

Heritage impacts can be mitigated to NEUTRAL during the construction phase if the ECO and/ or

construction foreman are informed of the types of heritage artefacts which could be uncovered

during vegetation clearing and excavations and what action is to be taken should heritage material

be uncovered.

The application of the proposed mitigation and design measures, as recommended by the

respective specialists, to be effectively managed in order to reduce the identified potential impacts

so as to not have a detrimental effect on the receiving environment.

In addition, some positive impacts have also been predicted. These include the creation of a number

of additional employment opportunities and associated economic growth for the local community

(rated as LOW POSITIVE), as well as the possible increase of aquatic habitat due to an increase

in available emergent habitat associated with the expanded dam (larger water surface area). This

impact has been rated as a LOW POSITIVE.

No-Go Alternative (compulsory)

The No-Go alternative will result in the potential employment and skills development opportunities

for the local community not being realised. In turn, the potential opportunity for economic growth in

the community will be lost. The securing of irrigation water supply for current agricultural activities

will also not be realised. These consequential impacts are regarded as HIGH NEGATIVE.

SECTION E: RECOMMENDATIONS OF PRACTITIONER

Is the information contained in this report and the documentation attached hereto sufficient to make a

decision in respect of the activity applied for (in the view of the environmental assessment practitioner)? YES NO

Is an EMPr attached? YES NO

The EMPr must be attached as Appendix F.

If “NO”, indicate the aspects that should be assessed further as part of a Scoping and EIA process before a decision can

be made (list the aspects that require further assessment):

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If “YES”, please list any recommended conditions, including mitigation measures that should be considered for inclusion in any authorisation that may be granted by the competent authority in respect of the application:

All mitigation measures included in the impact section should be considered for inclusion in the

Environmental Authorisation, should one be granted.

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SECTION F: APPENDICES

The following appendixes must be attached as appropriate:

Appendix A: Site plan(s)

Appendix B: Photographs

Appendix C: Facility illustration(s)

Appendix D: Specialist reports

Appendix E: Comments and responses report

Appendix F: Environmental Management Programme (EMPr)

Appendix G: Other information

FINAL BASIC ASSESSMENT REPORT - publicprocess.co.za

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