NAME ORGANISATION COMMENT RESPONSE Bay Wind Energy... · project with increased scope would require...

Volume 3: Environmental Impact Assessment Report

Coastal & Environmental Services 171 Richards Bay Wind Energy Project

APPENDIX C-10: MINUTES OF THE PUBLIC MEETING HELD AT THE PROTEA HOTEL, EMPANGENI DURING THE EIAR PHASE.

NAME ORGANISATION COMMENT RESPONSE

Andrew Walshe

Son of neighbouring land owner

I request a photomontage of what the turbines will look like from my parents’ property.

CES will provide this.

Is later, further development likely.

This is at the discretion of the developer. However, a revised project with increased scope would require a new EIA or BA. You are within the setback area excluded due to the presence of the airport, therefore development closer to you is highly unlikely. In any case, if development were extended closer towards your parents’ homestead, the necessary noise impact setback line of 500 m would need to be adhered to as it has been for other dwellings within the project site.

What about the positioning of transmission lines?

The option 1 transmission station and line layout is most likely. Internal cables i.e. those between the turbines will be underground and therefore invisible. The substation will be located next to existing power lines, so this will not add to the “visual clutter” of the area.

John Phipson

Agricultural Consultant – Mzansi Agriculture

A major benefit of this project that I feel has been underemphasized is that this electricity generation system uses no water. KZN and South Africa face a severe water shortage by 2030. Our water shortage is far more frightening than our power shortage.

Lesley Naude

Reporter – Zululand Observer

How loud is 45 dB?

(The noise specialist present, Brett Williams, said that the fan of the laptop and projector – situated about 3 m from himself – was emitting sound at about 45 to 50 dB. He then stated that the ambient noise level in the area during the daytime, measured during the noise study, was above 45 dB). (John Phipson stated that she was speaking at about 65 dB). Modern turbines are more aerodynamic, efficient, and




quieter.

You spoke about environmental benefits that may occur as a result of proceeding with this project. Could you please elaborate on this?

Authorisation of the development by the Department of Environmental Affairs will contain conditions requiring alien plant removal and management efforts. The area over which this must be applied id not specified, but is assumed to be the project area. The potential for the developer to work along with Walking for Water, and alien management programme, is there. The bottom line is that this could open up funding, time and skills for rehabilitation.

How is the developer held accountable for the development by the public?

As part of the IPP programme: 2.5% of revenue from the development must go into a community trust.

How does the rental system work, in terms of the land on which the turbines are situated?

Developer enters a lease agreement with the landowner, and the landowners are paid an annual rental fee per turbine situated on land belonging to them.

Andrew Walshe

Son of neighbouring land owner

What about maintenance in the future: will there be a depot in the area and how much activity will there be on site.

There will be a site office with a small warehouse, which will hold certain parts and required consumables. No major parts on site. A team of up to 10 individuals may be required on site during the operation phase. The bigger impact of the development will not be direct employment but rather the increase in development potential in the area due to increased electricity supply. Eskom has to approve the supply of electricity to new developments.

Brett Williams

Noise specialist A big benefit of this project is the reduction of CO2 output in electricity production.

Fences in the Transvaal, that have lasted 2 generations, degraded within 20 years after the large coal fired power plants were built in those regions due to the hydrogen sulphide and other erosive chemicals in the rain.

Lesley Naude

Reporter – Zululand

How does Richards Bay benefit from electricity being produced

Eskom needs to approve the supply of electricity to any




Observer here? new, major development in this area. Most of South Africa’s electricity is produced up north, in Gauteng and Mpumalanga. Eskom loses some of the power that is transports over long distances, and this is unrecoverable. Eskom can only be paid for the electricity that it delivers to the consumer. Eskom is more likely to approve the supply of electricity to developments close to the source of that power’s generation. This means that having a wind farm in the Richards Bay area, makes providing electricity in the Richards Bay area more attractive to Eskom. Most countries of the world are developing towards decentralised power production. This development would make Richards Bay a net exporter of electricity.


Coastal & Environmental Services Richards Bay Wind Energy Project

174

APPENDIX C-11: COMMENTS AND REPSONSE REPORT AS IT STANDS ON 1 APRIL 2014 INCORPORATING COMMENTS SINCE THE START OF THE PROJECT–COPIES OF IMPORTANT CORRESPONDENCE RECEIVED HAS BEEN INCLUDED IN APPENDIX D. COMMENTS RECEIVED DURING SCOPING PHASE AND PUBLIC REVIEW OF THE OF THE FIRST DRAFT EIR AND EMPr

Name Issue Response

Land Use and Conservation

WESSA KZN Region Date of Receipt: 29 August 2011

Existing land use – During the operation of the facility what restrictions on the land use/activities will be imposed?

Agricultural activities, as they occur at present, will continue. The proposed project will not restrict any land use options such as agriculture which is deemed to be complementary. Agricultural activities on site consist mostly of sugar cane farming and timber plantations. In terms of the restrictions wind turbines may pose to aircraft, the necessary operating standards will be imposed on the wind farm which includes an authorization from CAA. These include a minimum distance between turbines, and specific lights installed on the turbine’s top that mark their location for high visibility.

Digby Cyrus (Head: Dept of Zoology and Coastal Research Unit of Zululand) Date of Receipt: 7 November 2011

Map 4.4 of the draft Scoping Report does not show the major ecological corridor that runs up from the Mhlathuze Estuary via the Mhlathuze River and Nsezi Stream through Lake Nsezi and Nseleni Game Reserve and beyond. This is in very close proximity to the eastern side of the proposed wind farm. The corridor has been recognised in all impact assessments related to Mhlathuze Municipality and the National Ports Authority.

The map referred to was created from a dataset created at a provincial scale. For this reason, high levels of accuracy cannot be expected at the local scale and for this reason this particular corridor was missed. The mapping division of Ezemvelo KZN Wildlife was informed of this and their response was that fine scale mapping of this area is due to occur at some point in the future, pending resources and funding. A request that any relevant conservation data that may be produced as a result of this EIA should be forwarded to the EKZNW was made. This corridor has been taken into consideration, and turbines and roads that were planned for construction on the eastern side of the N2 have been removed.


I think there is a need for you to look at the conservation proposals for the area, particularly to the east of the proposed site. There are major areas identified for conservation that are not shown on your maps or referred to in your document [The document being referred to is the draft Scoping Report].

The reason for the omission of these conservation expansion areas is the same as above i.e. that datasets were created at a provincial scale. Throughout the EIA process, Ezemvelo KZN Wildlife has been consulted and their input obtained. The only proposed conservation area is the corridor already mentioned, which has been taken into consideration. No development is planned within this area.



Felicity Elliot (Ezemvelo KZN Wildlife). Date of Receipt: 10 November 2011

The uMhlathuze Environmental Management Framework and Strategic Development Framework identifies the site to the south east of the N2 as a future nature reserve area, once rehabilitation has been undertaken.

Noted. This falls outside of the proposed wind farm project area

Felicity Elliot (Ezemvelo KZN Wildlife). Date of Receipt: 10 November 2011

The site to the south east of the N2 is further a proposed Offset area for the proposed expansion of the Richards Bay harbour.

Noted, but this is not within the project area.

WESSA KZN Region Date of Receipt: 13 June 2012

When considering the threats of climate change to our biodiversity, society and economy, WESSA is in full support of the wind energy programme as part of the carbon reducing energy programme for South Africa and in consideration WESSA advocates:

Installation in appropriate locations

The promotion of electricity efficiency

The promotion of “portable” energy sources

The investment, at homestead level, in renewable energy appliances and technologies.

Balancing of energy production versus positive and negative factors

The identification of species and or sets of species at risk in areas identified as having high wind resources

The use of existing data on migratory and other movements of wildlife to develop predictive models of risk

The need for more southern hemisphere research on the impact of bats on wind turbines.

Noted.

Neighbours Mr Clive Kelly Date of Receipt: 26 September 2012

Mr Florian Kroeber, I hereby withdraw my objection to the Richards Bay Wind Farm on condition that the assurances given by you in the attached certificate signed by you on the 9

th

of September 2012 are met.

Noted.

Agriculture The Department of Agriculture, Forestry and Fisheries.

With reference to your application on the above mentioned property, this Department wishes to inform you that it has objection against the proposed development.

Noted.



Date of Receipt: 15 March 2013

Civil Aviation Authority The South African Civil Aviation Authority. Date of Receipt: 24 June 2013

The Civil Aviation Authority therefore has no objections to the development of your proposal subject to the submission of the final turbine layout, where after the SACAA will provide conditions of approval with regard to marking conditions as per Civil Aviation Technical Standards.

Noted.

Procedural Comments


An objective of the EIA process is to investigate alternatives, fundamental and incremental, however in discussing Fundamental Alternatives the proposed Hluhluwe Energy Project, said to be under the same applicant, is mentioned and it is specifically said that it is mentioned for information purposes and is not being considered as an alternative. Authorisation is being sought for both sites. No alternative sites for the proposed Richards Bay / Empangeni site have been evaluated as required in the EIA process.

This is true. As well intentioned as this requirement of NEMA is, in many instances it is not practical in the real world. The developer, in obtaining finance from banks and investment institutions to fund the EIA and the many other expenses involved in developing a wind farm, has to have lease agreements and other arrangements in place with landowners involved in the application. As such, conducting an EIA for 2 potential project sites was not an option in this instance. The developers are only interested in siting the development here, not only due to the financial and contract constraints previously mentioned, but also due to the wind measurements obtained on site. However, multiple design alternatives in terms of access routes and turbine placement have been evaluated through an iterative process in an effort to reduce negative environmental impacts.

Specialist Studies

Danie Lubbe (Deputy Municipal Manager) uThungulu District Municipality Date of Receipt: 19 September 2011

The uThungulu District Municipality requests that the following potential issues are investigated during the EIA phase:

1. Aviation impacts 2. Socio-economic issues 3. Additional legislative requirements that need to be

confirmed are planning approval in terms of the KwaZulu Natal Planning and Development Act (Act No. 6 of 2008).

4. Consent from the National Department of Agriculture in terms of the Subdivision of Agricultural Land Act (Act No 70 of 1970).

1. The CAA has been consulted and does not object to project.

2. A socio-economic impact assessment has been conducted and the results are presented in this EIR.

3. The KZN Planning and Development Act will be obeyed. 4. There will be no subdivision of any existing land parcels.

DAFF has stated they have no objection to the project.

Mr Takalani Maswime (Case officer: DEA)

Has a geotechnical assessment been done? A preliminary geotechnical assessment has been conducted with results of that assessment included in the final EIR.



Date of Receipt:3 November 2011 (mentioned during site visit)

Mr Takalani Maswime (Case officer: DEA) Date of Receipt:3 November 2011 (mentioned during site visit)

A study [Ecological] must delineate wetland areas with appropriate buffers, and exclude these areas from development.

The Wetland Specialist Report has addressed this and no development is planned within these sensitive areas.


The EMPr will need to address turbine transport issues. A Transport Management Plan is included in the EMPr.


Here are some points to consider for inclusion in the Terms of Reference (ToR) of these [the avifauna and bat] investigations:

The height of the turbines is important: Lower turbines kill fewer bats (<60 m) than higher ones but are more of a problem for birds (they can fly below higher turbines).

Impact related to the number of turbines? Obviously a field of 300 will have more impact than 20.

The placement of the turbines: Are any of them along ridges/ linear landscape features such as ridges, tree lines, river beds etc. as bats & birds use these as flight pathways. The presence of these within the area that will be covered by turbines will greatly increase the risk to bats. Also, if they are arranged in a line there is more potential for collisions than if they are clustered or in a square.

What is the proximity to wetlands or other important habitats for birds and bats?

There will be a need for a 12 Month monitoring period for bats and birds and standard protocol, as endorsed by the EWT should be followed.

Are the people to be hired do the monitoring sufficiently qualified regarding these components (everyone is coming out of the woodwork these days claiming to be able to do bat or bird monitoring) and this monitoring

Point 1: Bio 3 has suggested as one of their mitigation

measures, that the lower tip of the turbine blades should be at least about 60 m above the ground and/or smaller rotor diameter turbines considered. This is to protect species which were recorded flying at a height of 60 meters during the long-term monitoring. Point 2: The latest proposed layout was downscaled to 31 turbines. Point 3: The proposed layout is scattered across the whole site extent rather than arranged in a line. A minimum interspace between turbines above 3 rotor diameters (approximately 300 meters) is observed. The sensitive areas mentioned (ridges, tree-lines, river beds) are all sensitive areas and have been designated as such. These areas, with a buffer of 200 meters, have been designated as sensitive and excluded from placement of turbines.. Point 4: There is a buffer of 200 meters around wetlands, indigenous vegetation, and intact riverine vegetation. Points 5 to 8: Noted. The 12 month bat monitoring programme (both data collection and report compilation) observed the relevant requirements and techniques prescribed within the local guidelines and international best practices.



must inform the turbine layout.

There are a lot of mollosid species in Natal and they are high flyers and thus vulnerable. Mollosid diversity is much higher in KZN than other provinces. This will also require appropriate expertise to identify them.

Fruit bats are not accounted for in any acoustic monitoring (they don’t use hi frequency echolocation, one species uses tongue clicks while the others only use vision) – this is much concern in KZN where there are a number of these species and they are more prevalent. So there is a need to do other forms of monitoring such as mist netting.

Felicity Elliot (Ezemvelo KZN Wildlife). Date of Receipt:10 November 2011

Richards Bay has local and regional corridors that are of importance, and must be taken into account. These include: (i) The link between Nseleni Nature Reserve and the Sanctuary Nature Reserve, and (ii) movement corridors between Crystal lakes and Lake Nsezi.

These conservation corridors have been considered and excluded from development.


All watercourses need to be assessed and not just wetlands, as these river systems provide local corridors and a number of ecosystem functions.

Noted, thank you. Watercourses are delineated and buffered as part of the wetland and ecological impact assessment, and as part of the bat pre-construction long term monitoring. If you review the sensitivity map supplied, you will see that water courses are appropriately buffered.


The visual and landscape impacts must also assess impacts on the night sky and the visual impacts with regards to Civil Aviation Association requirements, in particular in light of the Empangeni Airfield located to the south west of the site.

Noted, and is part of the VIA study that has been conducted. CAA requirements will be met in their entirety as this is crucial to any project hoping to fulfil the IPP PP technical qualification criteria.

KwaZulu Natal Department of Agriculture, Environmental Affairs and Rural Development. Date of Receipt: 16 November 2011

On page 54 of the draft Scoping Report it is mentioned that some specialist studies are not yet undertaken. In this regard the EAP must specify the scope and timeframes for the assessments.

All specialist studies are conducted at the beginning of the EIA phase. The ToRs for these studies are influenced by comments received during the Scoping Phase. These have now been completed.

KwaZulu Natal Department of Agriculture, Environmental Affairs and Rural Development. Date of Receipt: 16 November

A geotechnical study must be included in the final Scoping Report since the construction of each wind turbine will involve the excavation of approximately 500m

3 of substrate.

A preliminary geotechnical study was conducted during the EIA phase and the report is submitted with the final EIR.



2011


A meteorological study must be featured in the final Scoping Report so as to assess the feasibility of the proposed wind energy project and to ascertain that the weather climate is conductive for this proposed project.

A met mast is currently installed on site and is collecting meteorological data since May 2011. A second wind mast was subsequently installed to improve data collection quality. Wind resources are suitable for the development of a wind farm.

The Bat Interest Group of KZN Date of Receipt: 11 June 2012

The East coast of Africa has a large, ecologically and economically important bat population: nearly all coastal areas in KZN are highly dependent on bats for their continued environmental sustainability. It is thus the bat group’s opinion that horizontal axis wind turbines are a dangerous technology to use in these areas and need to be treated with extreme caution. Because bats are volant, locally migratory, and sometimes long distance migratory, the ecological footprint of one turbine can be massive. Bats are very slow breeders (usually one young a year) and decimated populations do not recover easily. Bat group data also shows that bats do not always use the same flight and migratory paths every year. For these reasons we would have preferred to see two years pre-construction monitoring and agree that the precautionary principle needs to be applied. We also agree with the comment in section 14.6 of the report that the final layout and turbine design should only be finalised after long-term monitoring is complete. Mitigation measures could include using vertical axis turbines (although the interaction between fruit bats and vertical axis turbines is completely unknown) and limiting operation to full daylight hours. Failing this, having a cut-in speed of 5.5 m/s airspeed would alleviate some of the damage to the bat populations of KwaZulu-Natal. Hoping these comments will help in your decision-making.

Comment noted. A full year’s pre-construction monitoring has now been completed, and mitigation measures proposed. The latest proposed layout has been informed by the 12 month bird and bat monitoring programmes and followed the mitigation measures recommended within the EIR. .


An additional issue which has not been addressed is:

Noise Impacts – Receptors other than human

This is an interesting point. However, no studies have been done on this though, in any South African wind farm EIAs that we are aware of and applicable guidelines do not specify this need.



Noise has been considered only from the perspective of potential impacts on nearby residents i.e. within range of the human ear. The impacts of vibration and ground infrasound on ground dwelling fauna such as snakes and other reptiles have not been considered.

Infrastructure Development Mz Lungelo Moroka and Mr Muzi Mdamba (KZN Department of Agriculture, Environmental Affairs and Rural Development). Date of Receipt:3 November 2011 (mentioned during site visit)

A road connecting Richards Bay and Ulundi is due to be constructed. Check if this is relevant to the project.

The KZN Department of Transport and SANRAL have provided comment for this development and have not mentioned this as being relevant.

The South African National Roads Agency Limited Date of Receipt:11 November 2011

SANRAL applies a National Roads Reserve restriction of 500m on the positioning of turbines. Should this not be possible, it can be relaxed with proper motivation. Noted.

The South African National Roads Agency Limited Date of Receipt:11 November 2011

Access to the sites to be developed cannot be from the National Road and must be from roads which ultimately join the national road at grade separated intersections. No access off minor roads will be considered within a distance of 160 m from any ramp terminal.

Noted. It is not anticipated that this requirement will be infringed upon as ready access to the suite exists from feeder roads.


The Department is aware of the approved Honey Farm housing development in proximity to the proposed wind farm site. The EAP must investigate how the proposed project could potentially conflict with this housing development. The Honey Farm housing development is not going ahead.


The EAP must investigate the proximity of the proposed road from uLundi to Richards Bay and how it will conflict with the development.

SANRAL is involved in this EIA. None of their comments have referred to this proposed road.

KwaZulu Natal Department of Transport.

1. The Department has no objection to the project. 2. A detailed scale development plan must be submitted to this

Noted.



Date of Receipt:12 March 2012

department for comment in terms of the Kwazulu Natal Provincial Roads Act No 4 of 2001. 3. In terms of section 13 of the Kwazulu Natal Provincial Roads Act No 4 of 2001, no buildings or structures whatsoever, other than a fence, a hedge or a wall, which does not rise higher than 2.1 metres above the surface of the land on which it stands, shall be erected on land within a distance of 30m as measured from the centre line of the existing constructed roadway of main road 453. 4. The road reserve boundary shall be determined in consultation with this Department’s Road Information Services. 5. The applicants attention is drawn to the relevant stormwater clause contained section 12 of the Kwazulu Natal Provincial Roads Act No 4 of 2001 and section 5 of the Roads Regulations wherein it is advised that the disposal of stormwater emanating from the road reserve through the layout, or any stormwater emanating from the layout through the road reserve will be undertaken in consultation with and to the satisfaction of this Departments Cost Centre Manager, Hluhluwe, during the development of the property concerned. 6. The access point to main road 453 is to be positioned and constructed in consultation with and to the satisfaction of this department’s Cost Centre Manager, Hluhluwe, to a type “B3” blacktop standard. 7. A safe sight distance shall be maintained at all times by cutting of grass or other vegetation on either side of the access. 8. Adequate parking facilities must be provided within the facility itself. 9. All costs incurred, as a result of these developments, shall be borne entirely by the developer. 10. A letter of compliance with the above requirements shall be lodged with the minister prior to the issuing of a certificate contemplated by the KwaZulu Natal Provincial Roads Act No. 4 of 2001. Such requirements shall be undertaken prior to the commencement of any development. 11. As the property concerned is also affected by national route 2-30, the matter must, in terms of the National Roads Act No 7 of 1998, be referred by you to the Regional Manager Kwazulu Natal, South African National Roads Agency Limited, PO Box 100410, Scotsville, 3209, for his consideration and recommendations.



General

AMAFA (Heritage) KwaZulu Natal (2 Letters dated 30 August and 30 October)

Based on the results of Mr Johnny Van Schalkwyk’s heritage study, we have no objection to the project. You are however required to adhere to the following conditions: 1. AMAFA should be contacted if any heritage objects are identified during earthmoving activities and all development should cease until further notice. 2. No structures older than 60 years or parts thereof are allowed to be demolished, altered or extended without a permit form AMAFA. 3. No activities are allowed within 50m of a site which contains rock art. 4. Amafa should be contacted if any graves are identified during construction and the following procedure is to be followed. - Stop construction. - Report the graves to the nearest police station. - Report to Amafa to investigate.

Noted, conditions will be included in EMPr.


Interaction with the Department of Agriculture and the Department of Water Affairs is critical. Our ability to authorise projects has highly dependant on their in-put. Other important players are WESSA and Eskom.

We have received comment from the Department of Agriculture. We have conducted a wetland specialist report. The developer has received a General Authorisation from the Department of Water Affairs. WESSA has been consulted since the beginning of the EIA and comment has been received. Eskom has indicated the availability of connection options to the main grid.


If cables are crossing the N2, SANRAL must be consulted. No cables will cross the N2.

Mz Lungelo Moroka and Mr Muzi Ndlamba (KZN Department of Agriculture, Environmental Affairs and Rural Development). Date of Receipt:3 November

Has meteorological data been collected? Yes, there is a met mast on site that has been there since May 2011. A second met mast was subsequently installed to improve data collection quality.



2011 (mentioned during site visit)

Mz Lungelo Moroka and Mr Muzi Ndlamba (KZN Department of Agriculture, Environmental Affairs and Rural Development). Date of Receipt:3 November 2011 (mentioned during site visit)

Find out what the borders of the Nseleni Nature Reserve are from KZN Wildlife. Consider this, and it’s buffer zones, in your assessments.

This has been done – all maps showing protected areas delineate the Nseleni Nature Reserve.


Comments from this Departments Land Use section must be obtained with regard to the transformation of high potential agricultural land as the proposed development will be located within the sugar cane fields.

This had been done.

Lize Shaw (Environmental Specialist – Zululand and Ntonjaneni Area) Date of Receipt:18 June 2012

What is the fire risk for the plantations across the N2? In terms of fire hazard, this is indeed a possibility. Turbines cannot be constructed within approximately 250 metres of a boundary property, and considering the maximum possible height of a turbine (blade tip height) is 200 m we feel the chance of fires are small. In any case, a small team on-site wind farm employees will be present during the operation phase and will be appropriately trained to handle this threat.

COMMENTS RECEIVED DURING PUBLIC REVIEW OF THE OF THE DRAFT AMENDED EIR AND EMPr

Name Issue Response

Bat Impact Assessment and Mitigation Measures

Kate McEwan of Natural Scientific Services Comment received on 24 March 2014

1. It is very unorthodox that the developer commissioned a second parallel study when they did not like the mitigation measures presented by the first specialist appointed.

2. If both studies are to be presented, it is important that

the true mitigation measures recommended by both specialists are presented, not just the one specialist’s, so that the DEA can make a truly informed decision. I

1. Please note that the reason for this decision was that with the help of the first results from the bat monitoring campaign the Applicant have been made aware that the wind farm site has an active bat population. The Applicant states that at the same time it became apparent that South African bat specialists lack experience with operational wind farm sites located in areas with active bat population and that NSS interim reports were being overcautious and not objective



specifically raise objection and draw attention to the following part of the EIAR report: Page XVII of the draft EIAR Executive Summary says: “The bird and bat assessments have been informed by a full 12 months of preconstruction monitoring which has informed the final layout for the WEF. The studies are supportive of the wind farm, assuming that mitigation measures suggested as per Table 8-4 are implemented. If the project is to proceed it will need to take cognisance of all findings and recommendations in this report, as well as any that may be issued as a condition of authorisation in an EA.” This is not true. NSS as the first specialist and having been on site for approximately 18 months of monitoring only supports the project if the mitigation measures we recommended are adhered to, not the mitigation measures in Table 8-4 of the EIAR. The mitigation measures recommended in table 8-4 are not nearly sufficient.

3. Figure 8.2: Bat Sensitive Areas. Where have these

areas come from? These are not the areas we identified. There are several wetlands and flight paths that have been omitted.

4. Figure 8.4: Wetland Sensitive Areas. These are not all

the wetlands.

5. How does CES have the expertise or the right to select and choose which parts of the specialist studies to use and which to omit?

enough. To ensure that the best possible expertise would be employed, the project opted to seek the capability of an international and more experienced team (refer to applicant’s letter in Appendix D). NSS was consulted to work with Bio3 to produce 1 report to which NSS declined. Bio3 was appointed in October 2012, long time prior to conclusion of 12 month monitoring and receipt of NSS mitigation measures.

2. Firstly, CES concedes that this sentence could be

misleading. Thankfully this mistake was picked up in the draft. CES will therefore present both sets of mitigation measures, present a comparative analysis, and allow the Department of Environmental Affairs to make the decision on the measures to be applied. CES do not have the expertise to decide which mitigation measures are appropriate, as both sets of mitigation measures were compiled by bat specialists. CES does however seek to take a balanced approach to the monitoring and different mitigation measures proposed. It must be understood that it is therefore within the applicant’s rights, as well as being methodologically sound, that 2 competent experts can present different requirements in terms of the mitigation measures that should be applied. Ultimately it is for the decisonmaker (DEA) to determine which measures should be applied.

3. These are the sensitive areas identified by Bio3, whose methodology for determining sensitive areas was different from those of NSS.

4. The wetlands shown were delineated by Scherman Colloty and Associates. We therefore consider them to be complete.

5. We do not. But we need to use our best judgement as the EAP, and balance multiple demands. We propose to present all the facts to the DEA, and allow them to make an informed decision on the most appropriate mitigation measures to be applied.

Department of Agriculture and The KwaZulu Natal Department of Agriculture and Noted.



Environmental Affairs – KwaZulu Natal Received: 24 March 2014

Environmental Affairs is satisfied that the report as submitted for comments is in line with the requirements of the NEMA EIA regulations 2010 and should be acceptable and should be acceptable by the authority after consideration of all other comments or relevant information.

Department of Economic Development and Tourism. Liesel Bieres, Chairperson of the KZN Renewable Energy Workgroup Received: 20 March 2014

I am writing this letter as the Chairperson of the KZN Renewable Energy Working Group, which has been set up by the Premier of Kwa Zulu Natal. The purpose of this work group is to co-ordinate and stimulate renewable energy development and activity within the Kwa-Zulu Natal. As provincial government we have set a renewable energy target of installing 5000MW of renewable energy in Kwa-Zulu Natal by 2030. This Richard’s Bay Wind Farm presents an opportunity to make a significant contribution to meeting our renewable energy targets within the province. We therefore have been and will continue to fully support this project and hope to see its implementation in the very near future. The location of Richard’s Bay is also favourable to us as this is a node, which has a concentration of some of the biggest energy users within the province. It is also an area which is known for its air pollutants and therefore requires clean energy and “green projects” to attract new investment into the area. Continuous work is also being undertaken around the Richard’s Bay IDZ to attract new industry, therefore reliable power supply in the area is of crucial importance and so the installation of wind to add to the energy mix is ideal in our view.

Noted.

uThungulu District Municipality Acting Deputy Municipal Manager: Planning and Economic Development

UThungulu supports renewable energy projects as they conform to climate change standards and are a good strategy to reduce green-house gas emissions. Therefore, uThungulu has no objection to the project, provided the following has been done:

Authorisation from the bats group has been obtained

Authorisation from the avifauna group has been obtained

The project adheres to the mitigation measures as indicated in the report

Frequent monitoring needs to be conducted during the project operation and monitoring reports be submitted to the relevant authorities

By references made to "Bat Group" and "Avifauna Group", the UDM in all probability imply "the Bat and Avifauna authorities". In which case this would refer to Ezemvelo KZN Wildlife who has been a key role player in informing the EIA process thus far on biodiversity impacts.



Other than this, the project is not anticipated to have a significant impact on the environment.

Kate Richardson of the Bat Interest Group of KZN Comment received 11 June 2012

1. In general, with one major exception, the reports are a very good overview of the current state of knowledge of the bat populations in the area. The authors admit that the few nights available in the field for the preliminary surveys were completely inadequate for determining what bat species are present in the area and the bat group agrees. Many bat species are locally migrant and fly wherever there is food: on any given night a particular species can be present in an area and then absent for some time. In any impact assessment it must be remembered that turbines impact not only bats resident in the area but also those migrating through the area and those using the area as a flyway from roosts to feeding grounds.

2. The major lack in the reports is that, although it is

mentioned (figure 15.1 both reports), there is very little consideration of the possible impact of turbines on fruit bats, specifically Epomophorus wahlbergi and Rousettus aegyptiaca. Fruit bats of the sub-order Pteropodiformes do not echolocate (although Rousettus has a basic echolocation it is not used during foraging) and are thus not detectable by bat detector. Fruit bats can be detected with infra-red binoculars or by sight but there is little published on methods of determining their foraging behaviour.

3. Unfortunately there are no published records of fruit bat

interactions with turbines because the sub-order does not occur in northern America and Europe where nearly all research into turbine impacts has been done. Fruit bats are slow flyers and would certainly not be able to avoid the blades or turbulence of a wind turbine. The bat group considers this to be a major weakness in trying to establish wind turbines on the east coast of Africa: fruit bats are vital for healthy forests and their loss could impact on the sustainability of the biodiversity of the region.

1. The reader should be aware that these comments apply to one of the earlier drafts (prior to completion of full 12 months) of the bat monitoring reports, and therefore some of these comments are not applicable to the final monitoring report.

2. Noted. Mist netting and harp trapping was performed to

account for non-echolocating species.

3. This concern is repeated in the letter submitted in response to the final monitoring report, and will be more comprehensively answered there.

4. Noted.

5. Noted.

6. A similar concern is repeated in in the letter submitted in response to the final monitoring report, and will be more comprehensively answered there.



A few minor comments on the report:

4. In Figure 3.1 (wing shapes and foraging habitats) Epomops franqueti is listed but it does not occur in South Africa, the figure was presumably meant to include the common and important Epomophorus wahlbergi.

5. It would be helpful if the report used SI measurements

throughout. On the bottom of page 5 lengths and speeds are in both metres and feet, and in kilometres and miles per hour. There are a few instances of spelling mistakes in the scientific names of bats (e.g. Glauconycteris variegata is spelled wrong throughout),

Final comments

6. The East coast of Africa has a large, ecologically and economically important bat population: nearly all coastal areas in KZN are highly dependent on bats for their continued environmental sustainability. It is thus the bat group’s opinion that horizontal axis wind turbines are a dangerous technology to use in these areas and need to be treated with extreme caution. Because bats are volant, locally migratory, and sometimes long distance migratory, the ecological footprint of one turbine can be massive. Bats are very slow breeders (usually one young a year) and decimated populations do not recover easily. Bat group data also shows that bats do not always use the same flight and migratory paths every year. For these reasons we would have preferred to see two years pre-construction monitoring and agree that the precautionary principle needs to be applied. We also agree with the comment in section 14.6 of the report that the final layout and turbine design should only be finalised after long-term monitoring is complete. Mitigation measures could include using vertical axis turbines (although the interaction between fruit bats and vertical axis turbines is completely unknown) and limiting operation to full daylight hours. Failing this, having a cut-in speed of 5.5 m/s airspeed would



alleviate some of the damage to the bat populations of KwaZulu-Natal.

Ms Wendy White

1. I am writing in my personal capacity to express my concern and disquiet at what appears to be a major and possibly deliberate omission from the above report.

2. Section 7: Impact Assessment: at first reading appears

to give equal weight to the findings and recommendations of the two Bat Specialist reports by NSS and BIO3 however I note with extreme concern the none of the Mitigation and Management recommendations from the NSS report have been included in the above EIAR report.

3. This is of extreme concern in view of the fact that the

NSS report states categorically “Due to the sensitivity of this site for bats, unless the developer adopts all the of the NSS recommendations, NSS recommends that the Richards Bay WEF is a No-Go project. There are some proven mitigation measures that can be applied to reduce the significance to Medium. NSS will only support this project if such measures are adhered to”

4. Since the mitigation measures proposed by NSS are on

the whole more stringent than those proposed by Bio3. The report as it stands can in no way be considered as complete and a basis upon which the relevant authorities may apply their minds.

5. I request that this report should be immediately

withdrawn and reissued with the inclusion of proposed NSS Mitigation and Management measures and a further period of comment allowed.

6. Secondly; as a bat specialist I am aware that no other

country in the world would consider placing a Wind Energy Facility in an area with such high bat diversity and numbers. If this WEF is to go ahead then it should be under the most stringent mitigation measures possible.

1. It is essential that the reader refer to the applicant’s correspondence contained in Appendix D as to why an alternative specialist opinion on the mitigation measures was sought and developed – mainly due to the applicant’s contention that Bio3 has more experience in developing mitigation measures for operational wind farm facilities in other countries compared to NSS’s experience in the same. It is stated in the reporting that NSS will only support the project if its defined mitigation measures are utilised as specified in their specialist report – this is clear in the Draft Revised EIR as well as the Final Revised EIR (this report). There is therefore no deliberate misrepresentation of NSS mitigation measures or any attempt to conflate these with Bio3’s. Bio3’s mitigation measures were presented as new information (in the Draft Revised EIR) in this instance, and therefore required presentation thereof to the public and stakeholders in the Draft Revised EIR. However, the public participation period for the Draft Revised EIR has revealed that NSS feels that the Bio3 mitigation measures are inadequate in NSS’s opinion. CES therefore propose to present a comparison of the full suite of mitigation measures proposed by both sets of specialists to the DEA, and allow it to use its judgement in making a decision on the best suited.

2. The NSS mitigation measures are contained in the specialist report and volume and reference accordingly made to these in all EIR reports to date. The applicant is of the opinion that the Bio3 mitigation measures are adequate, while still allowing the development of a viable wind farm, and the proposed 3 year operational monitoring regime will allow for the appropriate measurement of potential project induced impacts or mortalities on bat populations in the project area. Please note that some of the measures suggested by NSS are adhered or similar to Bio3 recommendations (e.g. minimum space in-between turbines, relocation of turbines from high sensitivity areas, no borrowing of fill



7. The BIO3 report section 2.2.2. states that “average wind speeds were generally low, averaging 7m/s”. Many scientific reports cited by both experts have established that at wind speeds below 6.5m/s maximum bat casualties will be experienced. As I understand it wind turbines start generating electricity at wind speeds of 4 to 5 metres per second and reach maximum power output at around 15 metres/second. The wind speed at which most turbines achieve their rated output is 12 metres/second. Thus for the greater part of the year this WEF will be physically unable to produce the projected output of 108MW. Obviously with such low average wind speeds this projected WEF can be considered as marginal at best, the stringent bat mitigation measures necessary to protect this bat “hotspot” will most likely render the project financially unviable and will very likely be vigorously resisted by the developers. The object of all Renewable Energy Systems is to produce electric power at minimum risk and damage to the environment. It therefore makes no sense to allow construction of a WEF that, due to low average wind speeds, will rarely produce its designed capacity of electricity output. The proposed facility can be expected though to cause unacceptable and possibly unsustainable bat mortalities, largely due to the WEF having to operate for a greater proportion of the year at less than optimum capability. There are many areas of this country with far higher and more constant wind speeds than this site. Such areas also have far lower bat populations and can contribute far more than this proposed site to the national energy requirements. Such areas in the Eastern and Western Cape, Free State and the Karoo can produce electricity without the undoubted damage to the environment that will be caused by this proposed facility.

8. Sir it is my firm opinion that this proposed Wind Energy

Facility should be declared No-Go.

material from no-go areas, post-construction monitoring reports to be submitted to the SABAAP, etc.).

3. That is NSS opinion, and has, and will be, presented as such in the Final Revised EIR (this document). As noted above their insistence on these being the basis for mitigation for their support is noted and reiterated.

4. The Final Revised EIR (this report) indicates where all proposed mitigation measures - as has been the case to date in the specialist reporting and volume - along with the caveat statement regarding NSS support for the project on adoption of their specified mitigation measures only. NSS proposed mitigation measures are more stringent on curtailment, but the Bio3 measures are more stringent on turbine design specifications (minimum height clearance), on construction period restrictions (schedule limitations and procedural protocols) and prose an exhaustive and detailed 3 year long operational monitoring regime to accurately identify high risk (mortality inducing) turbines that would then refine the curtailment mitigation measures – as is appropriate and applicable. The NSS curtailment measures proposed for turbine clusters from the commencement of operation for a yearlong period cannot by definition identify, or confirm, that potentially high risk turbines are in fact resulting in higher mortality levels if they are curtailed from night time operation. However, this in itself cannot demonstrate that the NSS identified high risk turbines are in fact more likely to result in higher mortalities if these mortalities cannot be demonstrated in the curtailment led monitoring programme put forward by NSS - and this is a fundamental flaw in their curtailment led mitigation and monitoring strategy – potentially high risk turbines cannot be monitored for mortalities as a result of these being idle in high risk (night time) periods. This cannot allow for the accurate monitoring of these potentially high risk turbines, as it cannot by design allow for an accurate and verifiable mortality count monitoring.



5. The Revised Final EIR will be available for review after final submission to DEA for further IAP comment and this will be communicated to them at the appropriate time – in accordance with the EIA regulations.

6. The Bio 3 mitigation measures are stringent, however they differ from NSS mitigation measures in the following major respects:

a. Bio 3 does not propose turbine curtailment unless a year’s worth of operational data on fatalities indicates that this is required (although Bio3 propose blade feathering below 3m/s).

b. Bio 3’s identification of sensitive areas is less severe than that determined by NSS.

c. NSS does not suggest any restriction on blade tip clearance from ground level and/or rotor diameter. NSS does not suggest any construction schedule restrictions (namely during breeding and birth season)

7. The statement that the wind resource for this project is inferior to those of other areas in the country is not correct. The project developer has measured the wind on site for more than 2 years. The projected energy yield resulting from the prevailing wind regime on side are in line with successful wind projects in other parts of South Africa. While lower cumulative impacts than other sites in other provinces, lower implementation costs (due to grid and seaport proximity) and a heavily transformed landscape (power lines, agriculture activities, etc.) were key factors for this site identification,, please also note that wind speed increases with height (opposing to bat activity in the site) thus hub height speed is higher than those 7m/s below mentioned and the site low altitude favours wind energy production due to higher air density when comparing with usual higher sites (anyway, no wind farm is able to operate at rated capacity at greater part of the year so that is far from being a necessary condition for viability. Appropriate mitigation measures



to protect the local bat population are identified and will be implemented.

8. Noted. However, Ms White was part of the specialist

NSS team contracted to conduct the yearlong pre-construction monitoring. Despite NSS statements that their proposed mitigation measures are suitable, and are required to be implemented in full for them to support the project, Ms White is now on record stating that the project should not proceed at all - which is at odds with the NSS statements in this regard.

National Council of SPCAs Sr. Ainsley Hay, Manager, Wildlife Protection Unit Received: 25 March 2014

The National Council of SPCAs (NSPCA) is the oldest and largest animal welfare organisation in South Africa. The NSPCA wishes to express its deep concern about the threat to the Bat population and other wildlife as result of the planned installation of wind turbines in the Richards Bay/ Empangeni area. We are aware that local scientists have concluded studies that prove that there is a serious threat to the bat population should these turbines be installed. Not only does this have biodiversity implications, but additional Animal Welfare implications as the Bats that are killed by these turbines die an extremely inhumane death. We wish to make it clear that should these turbines be installed and cause any death of these animals in contravention of the Animals Protection Act No 71 of 1962, we will not hesitate to take legal action against those involved. The National Council of SPCAs vehemently opposes the proposed development of these wind turbines. We trust that you will act in the best interest of our biodiversity, heritage and animal welfare.

It is not clear from the SPCA’s submission that they have actually reviewed the relevant reports. In response to this, it can only be said that mitigation measures are proposed which will minimise bat fatalities. The tone of this letter suggests that no effort is being made to protect bats, which is incorrect. There has been no consideration of the reasonableness of the 2 sets of mitigation measures proposed, and we hope that the final EIR will clear up this misunderstanding. It is also not clear whether this is a nationally accepted and advanced position as put forward by the SPCA - or is pertinent to the project under consideration only.

Eskom Ravi Moonsamy Received: 20 March 2014

This letter serves to acknowledge that Eskom has received an application by Astrum Energy (Pty) Ltd for the connection of the Richards Bay Wind Farm for up to 108 MWs of wind generation to the Eskom network. Eskom fully supports all applications related to the Department of Energy’s renewable energy bid program and as such, this application. Eskom have already issued a cost estimate letter indicating the cost and scope of work related to connecting the generation to the Eskom grid.

Noted



The proposed wind farm is located in an area of very high electricity demand and will improve system energy losses and will contribute to grid capacity. Due to the high level of industrialisation in the area, Eskom has significant electricity infrastructure installed already.

Kate Richardson of the Bat Interest Group of KZN Comment received 20 March 2014

1. We are of the opinion that your report proves our contention that the area is a high sensitivity area for bats and that the wind farm should not go ahead unless the turbines are switched off for all the hours of dusk, darkness and dawn.

2. The bat surveys were competent and the results show

what we could have expected. However bats do not occur in the same areas at the same time every year: they go where the food is most abundant and thus can show large movements throughout coastal areas over several years (personal experience). Mitigation suggested (p. 108) to avoid placing infrastructure in areas where high bat activity has been recorded has little chance of succeeding unless it can be predicted where insect abundance will be in future. In this Africa differs from Europe where bats are often more affected by seasonal changes in the temperate climate instead of the decade-long fluctuations experienced by much of

our fauna. While we appreciate the attempt to save bats

by delineating high-use foraging areas, the report misses a major argument. Bats “forage across all habitat types” (p. 98): this is not a case of lesser numbers of bats foraging in some habitats but one bat will forage across less sensitive habitat (often while flying between its roost site and/or foraging areas) and then spend more time in the high foraging areas where insects are more abundant. Protecting the high-forage area has no relevance if the bat is killed while on its way there. We therefore claim that no area is safe to put turbines: the cumulative impacts may have devastating consequences on bat numbers.

3. Both bat reports and the agricultural report deal only

very vaguely with the ecosystem services provided by

1. Both the NSS and Bio 3 studies conclude that the area is a high sensitive area for bats. The applicant is of the opinion that NSS stipulations that turbines be switched off during darkness is quite drastic, and would need at least some operational phase monitoring data to be recorded (indicating high mortality rates in these instances) to support such a measure. As such, their view is that curtailing certain turbines at night in high sensitive areas cannot actually indicate if these would, or will be, responsible for bat mortalities. In short it cannot be determined if certain turbines, or clusters of turbines do in fact potentially result in higher mortalities than other turbines or clusters if these are in fact curtailed for night time operations. It stands to reason that the full impacts of these turbines or clusters cannot be adequately monitored if they are curtailed at times of potential high bat movements in the project area. The Bio3 mitigation measures call for 3 years of operational phase monitoring, and that adaptive mitigation measures are applied as mortality data is collected. NSS mitigation measures call for an operation curtailment program to be implemented for the first year of operation, whereby 3 cut-in speeds and different timing is experimented with, to determine the best operating conditions for the wind farm that NSS feels reduce mortalities. As noted above, this approach cannot determine if curtailed turbines are in fact responsible for mortalities, or are a higher risk therefore, if these turbines are not operational during higher rick (dark) periods.

2. Sensitive areas were delineated based on NSS and

Bio3‘s knowledge and expertise, and on a thorough analysis of the pre-construction monitoring data. The SABAAP’s recommendations in terms of suggested



bats. p.50 The agricultural impact report has no mention of the impact of bats on the sugar cane pest Eldana. Although discussed on p. 78 by NSS (please correct the area studied by Bohmann et al. 2011 – it was conducted in north-eastern Swaziland, an area very similar to the study site) there is no attempt by the agricultural report to quantify potential damage to the crop by the loss of bats. Noer et al. 2012 has shown that bats choose to forage over cane and may be very important predator species. This is a serious omission and could change the socio-economic profile of the area if sugar cane farming became non-viable. Bats forage over cane when Eldana is most abundant (usually when cane is knee high): the areas which have shown high bat activity might therefore have no relevance in future as the highest bat activity will probably shift as crops mature and are replanted.

4. There is no attempt to quantify the potential increase in malaria in northern KZN and Mozambique caused by removing a portion of the tens of thousands of Miniopterid bats which migrate along the KZN coast. Miniopterus species are bats which would probably be highly affected by wind turbines. Gonsalves et al. 2013 have shown that bats move to wherever mosquitoes are abundant and mosquito abundance can have large impacts on the diets of bats.

5. Fruit bats are known to be involved in pollination and seed spreading of many tree species in Africa: up to 95% of tropical rain forest trees: their effect on coastal forest in KZN is unknown but we think it may be very high too. Our rehabilitation programme deals every year with fruit bats which have been blown into buildings and power lines. It is extremely unlikely that they could avoid turbine blades or the strong draft produced by them (p. 81). The only mitigation measure suggested for fruit bats is “conduct an operations phase monitoring programme” (p. 108). Which leaves us to wonder, what then happens if fruit bats are killed? Apologise? Once bat populations are decimated they may take decades

buffer areas were also considered.

3. Ecosystem services will only be lost if the local bat population is significantly reduced in number – by the facility or other unrelated external factors. CES cannot accept therefore that bat dependent ecosystem services will be lost to the extent that Ms Richardson postulates. The contention that sugarcane farming will become unviable in the area as a result of wind farm induced mortalities is at best tenuous, based on minimal credible research or opinion, and cannot be demonstrated in a project level specific EIA study either way, owing to the length of time and detail a study of this sort would have to encompass. CES does not accept that this is a serious omission.

4. This issue/objection is, in the opinion of CES, more tenuous than the above described point. CES contends that as for the above mentioned point the potential impacts (or not) is unquantifiable at a project level EIA. Accordingly, CES does not deem this to be a potential impact that bears recognition and assessment in this EIA process but is best suited to an ongoing and comprehensive research effort – if in fact it is deemed to be a valid avenue of academic enquiry.

5. If the operation phase monitoring programme indicates bat mortality that is too high, it will be necessary to implement measures to reduce this mortality - such as night time curtailment of high risk turbines or clusters in areas of high – or comparatively high - mortality. It will be an on-going, adaptive process. The Bio 3 report suggests that mortality reports are prepared regularly and submitted to the SABAAP for consideration. The review by all these experts should definitely allow the determination of a number that is “too high”. On page 63 of NSS’ long term monitoring report, they make an attempt to predict sustainable mortality rates. They admit that they have had to make many assumptions in their calculations, but estimate that population losses of anything greater than 15 or 20 % would lead to



to recover, if they ever do, and their ecosystem services are lost. We have seen a large and worrying drop in fruit bat numbers in northern KZN over the last few years – this might be caused by the continual destruction of coastal forests but might indicate an as-yet unknown infection. The “double whammy” of this unknown and a wind farm might be too much for the species. In all these cases there is no attempt to gauge what level of bat mortality is acceptable. We disagree that moderately significant impact can be tolerated: the bat fauna in coastal KZN has a large impact on the environment and moderately significant impact may be unsustainable in environmental terms (p. xi) and on long-term population trends. Please could you give an actual number to “high” mortality (EMP p. 41)? Similarly, can you give an indication of what you mean by “measures to … compensate” potential impacts (EMP p.44)?

6. (p. 80) A post-construction bat monitoring programme

will only be of use if the wind farm operators are willing to shut the turbines off completely if too many bats are killed. A personal comment in a meeting with a wind farm developer and EAP was that they would do no such thing as it would impact on the money obtained from selling electricity and “so, bats will die”. It didn’t increase our confidence in mitigation measures. Can you confirm that complete shut-down might be an option?

7. While we appreciate the attempt to save some bats by

asking for feathering blades and cut-in speeds of 3 m/s (p. 110), we disagree that a cut-in speed of 3m/s is adequate protection. Arnett et al. 2013 also discusses the incidence of kill of their Mexican Free-tailed bats, a species very similar to our Tadarida. We think a cut-in speed of 5 m/s is more likely to be beneficial.

8. No attempt has been made to quantify the impact the noise of the turbine operation will have on the bat populations (p. 50).

population declines year on year.

6. If operation phase monitoring reveals unsustainable/unacceptable losses, then appropriate curtailment would have to be implemented. With regard to developer/EAP comments on mitigation CES denies that no action would be taken if operational monitoring indicates high mortalities. CES does concede that the EAP opinion that mortalities are likely, or definitely, going to occur was made at said meeting, but this is the international experience for operational facilities with high bat presence.

7. This is definitely something that would need to be confirmed by post-construction monitoring. At this point the applicant is not ready to implement cut-in speeds that the future might reveal to be unnecessary. Please note that additional Mitigation efforts have been additionally recommended and these shall be read all together (e.g. keeping a certain rotor clearance area from ground to tip level and/or limiting the rotor dimensions).

8. This has not been a requirement in contemporary EIA studies for wind energy facilities as set out by the DEA requirements for specialist assessment, neither is it required in terms of the SABAAP guidelines.

9. Noted. This is made clear in the reporting that barotrauma is the main cause of mortality as opposed to direct collision.

10. Noted.

11. Noted as a hypotheses.

12. Noted.

13. Both NSS and Bio 3 reports indicate that the area is a bat sensitive area. If the decision as to whether the project should proceed depended only on the bat



9. p. xi Bats are not generally killed by direct impact with

turbines but by barotrauma from the area of low pressure caused by the turbine blades (correct on p. xv). From personal knowledge of how fruit bats fly we assume they would be unable to cope with the strong drafts produced by turbine blades.

10. p. 43 Bat activity being higher in spring and summer

months is not usually caused by food being available but by pregnant and lactating females having higher energy requirements (and thus needing to hunt more) and by the influx of juvenile bats into the population.

11. p. 80 While red lights should attract less insects and

thus less insect-eating bats, they might attract fruit bats.

12. p. 109 A critical period for most of our bats is the time when inexperienced juveniles are first flying, January to March in most cases, although this can extend to May in some years.

13. We are thus still of the opinion that because of the

potential damage to the bat populations and the environment, coastal KwaZulu-Natal is an inappropriate area for a wind farm. We can find nowhere else in the world which would responsibly permit a wind farm in such an area of high bat sensitivity. We disagree that with proper mitigation (except complete shut-down of the turbines during the hours of twilight and darkness) the impacts on bat populations can be reduced, and we strongly believe that a precautionary approach should be taken: wind farms should not be permitted until we have enough knowledge to say for certain that they will not damage our bat populations and the environments they support.

sensitivity of the area, it would be an easy decision for the authorities to make. The point is that, the project is implementing mitigation measures that have been determined by a competent team of bat specialists to be adequate – albeit with the per review specialist (Bio3) and NSS having strong differences in opinion as to what is suitable or commensurate. They both stress that mitigation will be adaptive process, involving rational decisions made based on actual operation phase data. The competing mitigation measures proposed are fair on their own respective merits, balancing the projects’ need to generate power, and the KZN Bat Association’s need to protect bat species. As its stands it is not sure how impacts of turbines on bat populations are proposed to be measured and monitored until there is information available from operational facilities that adequately informs opinion and consensus of these facilities’ impacts on resident or migrant bat populations.



APPENDIX C-12: REGISTER OF INTERESTED AND AFFECTED PARTIES AS AT 1 APRIL 2014.

Name Association Telephone Fax Cell Email Postal address

LANDOWNER

Mr Richard Russel Addison

The Umhlathuzi Valley Sugar Company 035 772 2544 082 452 8316 [email protected]

PO Box 511, Empangeni, 3880

Mr Patrick Addison 035 792 0040 082 457 8009 [email protected]


Alfred James Dowe Golden Mile Farm 035 787 0915 082 805 2099 [email protected]


David H McIlrath McIlrath & Son (PTY) LTD 035 792 0223 073 974 1811 [email protected]


Pieter Swanepoel 082 550 7260

[email protected]; [email protected] ; [email protected]

PO Box 11054, Centurion, 0046

Billy and Greg Nelson

082 335 6250 [email protected]

Surrounding Neighbours

Roy Davidson 035 792 0041 [email protected]

PO Box 1, Richards Bay, 3900

Mondi Forests Lize Shaw - Environmental Specialist - Mondi 035 902 2111 [email protected]


Mr Lucas Mjadu Phambili Farm 083 882 6846 [email protected]

PO Box 628, Esikhawini, 3887

Mr CJ Hammar Nsongweni Farm 082 898 6080 Suite 71, Private Bag X20004, Empangeni, 3880

Mr Cleo Mdumgofe 071 689 2791 PO Box 4915, Empangeni, 3880

Mr Jefferey Zulu 071 472 0293 PO Box 89, Empangeni, 3880

SA Sugar Research Institute Farm

035 792 0137 PO Box 2456, Empangeni, 3880

Mr Clive Kelly 035 772 1911 [email protected]


Jill Tayfield 035 792 0030 082 448 8841 [email protected]

Alan Davidson 031 301 3559 [email protected]

Neville Dixon 035 792 0049 073 044 1494 [email protected]

Canefields B&B 035 792 0031 [email protected]

Melody Vorster Herb Basket B&B 083 659 5642 [email protected]

Matthew Vorster Son of Melody Vorster matthew.vorster@dimensio

mailto:[email protected]





mailto:[email protected];


















ndata.com

Ken Walshe 035 792 0065 / 031 566 2889


Tally-Ho B&B 083 783 3105 [email protected]

Paul Bell 035 907 9111 [email protected]


Pierre Vivian Delvaux

Ensureu Inv South Africa (Pty) Ltd 035 772 6076 083 417 1155 [email protected]

Assistant of Mr Delvaux [email protected]

Bernadette Geach 035 772 7272 083 273 7774 [email protected]


Moopen Neelamega

Corpclo 148 CC 083 787 0276 [email protected]

PO Box 7368, Empangeni Rail, 3910

Brett McMurray Honey Farm 083 415 1772 [email protected]


Coenraad Frederik Van der Merwe

Tharita Wrede 012 667 1579 [email protected]

PO Box 8002, Centurion, 0046

AUTHORITIES

National

South African Civil Aviation Authority Private Bag X73, Halfway House, 1685

Director: Environmental Impact Evaluation

Department of Environmental Affairs Private Bag X447, Pretoria, 0001

Ms Mashudu Marubini (Delegate of the Minister Act 70 of 1970)

Department of Agriculture, Forestry & Fisheries 012 319 7619 [email protected]

Private Bag X120, Pretoria, 0001

Ms Thoko Buthelezi (Agrilang Liason Office)

Department of Agriculture, Forestry & Fisheries 012 319 7634 [email protected]

Private Bag X120, Pretoria, 0001

Ms Mokgadi Modise Department of Energy Private Bag X19, Arcadia, 0007

Cas Landman The South African National Roads Agency Soc Limited

033 392 8100 033 386 3365

PO Box 100410, Scottsville, 3209

Provincial

Zama Mbanjwa Department of Agriculture, Environmental Affairs and Rural Development KZN


Private Bag X1048, Richards Bay, 3900

Muzi Mdamba KZN Deprtment of Agriculture, Environmental Affairs and Rural Development

035 780 6844 035 780




















0662

Lungelo Moroka KZN Deprtment of Agriculture, Environmental Affairs and Rural Development

[email protected]

Department of Agriculture 033 355 9613/528

033 355 9614

Private Bag X9059, Pietermaritzburg, 3200

The Manager Kwazulu Natal Agricultural Union 033 342 9393/4 033 345 7141

PO Box 100123, Scottsville, 3209

The Deputy Director General

Kwazulu Natal Dept of Transport 033 342 4082 033 342 3962


The Land Claims Commisioner 033 342 6955


The Regional Director

Kwazulu Natal Department of Environmental Health

033 394 1901 033 394 4744


The Director Development Administration Inland Region 033 355 6421 Private Bag X9018, Pietermaritzburg, 3200

Barry Marshall Director: AMAFA KZN 035 870 2051 [email protected]

The Director Heritage Kwa-Zulu Natal 033 394 6543

PO Box 2685, Pietermaritzburg, 3200

uThungulu DM

Danie Lubbe uThungulu DM 035 799 2500 083 627 0871


Hennie Smit (Chief planner)

uThungulu DM 035 799 2603 [email protected]


Ms Nkosingiphile Khuluse

Uthungulu DM Environmental Management 035 799 2500 [email protected]

Frans Van Der Walt Chairman: uThungulu Strategic Development Committee

035 753 4184/5 035 753 4185

[email protected]

PO Box 10376, Meerensee, 3901

uMhlathuze LM

uMhlathuze Central Registry

[email protected]

Sharin Govender Projects Manager Environmental Planning RB 035 907 5174 035 907 5426

[email protected]

Mr Morton Du Preez

uMhlathuze Water 035 902 1109 035 902 1109



J Harvey Water Services Councillor: uMhlathuze Local Municipality Department of Water Affairs


Private Bag 1004,Richards Bay, 3900











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