NEMA SECTION 24G EIA Report - GNEC · NEMA SECTION 24G EIA Report Section 24G Application Form for...

NEMA SECTION 24G EIA Report

Section 24G Application Form for the rectification of unlawful commencement or continuation of listed

activity/ies in terms of the:

National Environmental Management Act, 1998 (Act No. 107 of 1998), (“NEMA”);

Environment Conservation Act, 1989 (Act No. 73 of 1989) (“ECA”);

Specific Environmental Management Acts (“SEMAs”)

July 2012 Form Number: S24GEIAR/07/2012

Kindly note that:

1. This section 24G Environmental Impact Assessment (”EIA”) report must be completed for all section 24G

applications in terms of the above Acts, by an independent Environmental Assessment Practitioner (“EAP”).

2. This EIA report is current as of July 2012. It is the responsibility of the Applicant/EAP to ascertain whether

subsequent versions of the EIA report have been published or produced by the competent authority.

Contents:

Section A: Activity Information

Section B: Description of Receiving Environment

Section C: Public Participation Information

Section D: Need and Desirability

Section E: Alternatives

Section F: Preliminary Impact Assessment, Management, Mitigation and Monitoring

Section G: Assessment Methodologies and Criteria, Gaps in Knowledge, under laying Assumptions and

Uncertainties

Section H: Recommendations of the EAP

Section I: Motivation for response to an emergency

Section J: Appendices

3. An Independent EAP must be appointed to complete the section 24G EIA report on behalf of the applicant;

the declaration of independence must be completed by the independent EAP and submitted with this EIA

report. If a specialist report is required, the specialist will also be required to complete the declaration of

independence.

4. Two hard copies and one electronic copy (CD/DVD) of this report must be submitted.

5. The required information must be typed within the spaces provided. The sizes of the spaces provided are not

necessarily indicative of the amount of information to be provided. The space provided extend as each

space is filled with typing. A legible font type and size must be used when completing the report. The font size

should not be smaller than 10pt (e.g. Century Gothic 10). A digital copy of the Section EIA Report is available

on the Department’s website (details below).

6. The use of “not applicable” in the EIA report must be done with circumspection.

7. No faxed or e-mailed EIA reports will be accepted.

8. Unless protected by law, all information contained in and attached to this EIA report will become public

information on receipt by the competent authority. Upon request, any Interested and Affected Party (“I&AP”)

should be provided with the information contained in and attached to this EIA report. During any stage of the

application process, the information contained in and attached to it must be provided by the applicant /

EAP.

9. This EIA report must be submitted to the Department at the postal address given below or by delivery thereof

to the Registry Office of the Department. Unnecessary delays will be incurred should the application and

attached information not be submitted to the correct address.

NEMA SECTION 24G EIA REPORT

S24GEIAR/07/2012 2

10. PROCESS TO BE FOLLOWED:

a) A section 24G Application Form constitutes the initiation of the Section 24G application process. If you

have failed to submit an application form, you may not proceed with the compilation and submission of

this EIA report until such time that a section 24G application form has been submitted to the Department

and subsequently acknowledged.

b) Once the information requirements in respect of the application have been met, a draft EIA report,

which must include an Environmental Management Programme (“EMP”), must first be made available to

the I&APs, including all the relevant State Departments that administer laws relating to a matter

affecting the environment, for comment for a period of 40 (forty) calendar days. Unless otherwise

indicated by the Department, a commenting period of at least 21 (twenty-one) days must be provided

to I&APs, including the relevant State Departments, to comment on any additional information,

documentation or reports (including the final EIR), other than the draft EIR.

c) The draft EIA report must be submitted to the Department in order to meet the requirements of section

24O of the NEMA. The Department will notify the State Departments of the 40 (forty) day commenting

after receipt of the draft EIA report.

d) Upon submission of the final EIA report, the competent authority will reconsider the application and may

undertake a site inspection or request such additional information as the competent authority may

require from the Applicant/EAP.

e) The Department will consider the final EIA report/additional information (if required) to determine the

administrative fine (not exceeding R1 million) and inform the applicant accordingly. The fine must be

paid within 60 days from the date of the fine notice. The applicant is required to provide proof of

payment of the fine to the Department.

f) In accordance with section 24G(2), the competent authority will then:

direct the applicant to cease the activity, either wholly or in part, and to rehabilitate the environment

within such time and subject to such conditions as the Department may deem necessary; or

issue an environmental authorisation to the applicant subject to such conditions as the Department

may deem necessary.

11. Note, failure to comply with a directive calling for information to be submitted within a specified period may

result in the institution of appropriate legal action as is deemed necessary by this Department and as provided

for in the legislation.

12. A person failing to comply with a directive or contravening or failing to comply with a condition of

environmental authorisation is guilty of an offence and is liable on conviction to a penalty of a fine not

exceeding R5 million or to imprisonment for a period not exceeding ten years, or to both such fine and such

imprisonment.


S24GEIAR/07/2012 3

DEPARTMENTAL DETAILS DEPARTMENTAL REFERENCE NUMBER(S) (for official use)

Department of Environmental Affairs

and Development Planning,

Directorate: Environmental Compliance

& Enforcement,

Attention: Sub-directorate: Section 24G

Applications

Private Bag X9086

Cape Town, 8000

Registry Office

1st Floor Utilitas Building

1 Dorp Street, Cape Town

Queries should be directed to the Sub-

directorate: Section 24G Applications

at:

Tel: (021) 483-8019 Fax: (021) 483-4033

View the Department’s website on http://www.westerncape.gov.za/eadp for the latest version of the documents

DETAILS OF THE APPLICANT

Applicant Name: Mr. Marc Doms Contact Person Mr. Marc Doms

RSA Identity Number/

Passport Number: 7908025228088

Trading name (if any):

Company Registration Number:

Postal address: P.O. Box 400 Robertson Postal code: 6705

Telephone: ( ) Cell: 082 964 4761 E-mail: [email protected] Fax: ( )

DETAILS OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP)

Environmental Assessment

Practitioner (EAP): Guillaume Nel Environmental Consultants (GNEC)

Contact person: Guillaume Nel Postal address: P.O. Box 2632

Paarl Postal code: 7620 Telephone: (021) 870 1874 Cell: 072 157 1321

E-mail: [email protected] Fax: (021) 870 1873

EAP Qualifications

MSc En Man (PUK), B(Hons) EN Man (US), B Geography (US), Certificate- Environmental Law (PUK), Certificate – EIA (PUK), Certificate– EMS 14000 (PUK), Certificate– Air Quality Management (PUK), Certificate– Environmental Auditing (SABS). Guillaume Nel has fourteen years relevant experience as an Environmental Assessment Practitioner.

EAP Registrations/Associations SAATCA Certified Environmental Auditor, No. (EMA 375) (2003)

File Reference number (S24G)

File Reference number

(Enforcement), if applicable

File reference number (EIA), if

applicable:

File reference number (Waste), if

applicable:

File reference number (Other):

ENV number:

http://www.westerncape.gov.za/eadp


S24GEIAR/07/2012 4

SECTION A: ACTIVITY INFORMATION

1. PROJECT TITLE

SARATOGA WATER PIPELINE CONSTRUCTION AND REHABILITATION ON FARM PORTION 14 OF THE

FARM KLAAS VOOGDS RIVIER, FARM NO. 40, ROBERTSON, WESTERN CAPE

2. ACTIVITY DESCRIPTION

(Cross out the appropriate box “” and provide a description where required).

(a) Is/are the activity(ies) complete or is/are the activity(ies) still to be completed? Completed Incomplete

In July 2013 the client Mr. Marc Doms of Saratoga Farm purchased the farm Klaas Voogds Rivier (portion 4 of

farm 40) from owner Mr. Pat Busch. A 30% share in water use rights to the existing dam situated on Mr.

Busch’s farm (portion 14 of farm 40) was also purchased. An existing 110 mm pipeline from the dam was

offered to Mr. Doms, however this volume would not meet his future water requirement needs. A servitude

was then purchased from Mr. Busch for a 160 mm pipeline leading from the dam in close proximity to the

existing PVC 110 mm pipeline. The roughly 1.6 km 160 mm PVC pipeline was subsequently illegally

constructed in November 2013, within 32 meters from a watercourse (the Doring River) without environmental

authorization, legally required in terms of the National Environmental Management Act, (Act no. 107 of 1998).

This pipeline crossed the river in two places where it was suspended on wooden supports anchored by

concrete foundations. During an unexpected flooding event triggered by heavy rainfall in January 2014 the

Doring River flooded its banks and the 160 mm pipeline was severely damaged and some sections of the

original existing 110 mm pipeline was also damaged. This flood also modified the river channel by establishing

a new river course, along the alignment of the unauthorised pipeline and eroded the bank into the first row of

an adjacent vineyard. There was however no damage to the pipeline between the dam and where it meets the

river (the northern section). The Department of Environmental Affairs and Development Planning was notified

and a pre-compliance notice was issued to Mr. Doms in February 2016.

The illegally constructed pipeline’s construction is complete, although a replacement pipeline is required. A

preferred and an alternative new PVC pipeline route (± 0.9 km in length) has been proposed to replace the

damaged pipeline and to supply water to the agricultural fields. Both these newly proposed pipeline route will

attach to the existing 160 mm pipeline well above where the flood damage to the pipeline occurred (more than

32 m from the river). Both the preferred and alternative pipeline routes will follow the same route and be

placed underneath a planted pasture field towards the farm homestead. The preferred replacement route will

continue through the farm homestead underneath a gravel/dirt road towards the connecting point on Saratoga

farm. The alternative replacement route will bypass around the homestead, adjacent to indigenous vegetation

and a vineyard. The alternative route will merely bypass the homestead and then again join onto the same

dirt/gravel road as the preferred route where both routes will run towards the connecting point on Saratoga

underneath the gravel/dirt road. Both these potential replacement routes will have minimal environmental,

geographical and/or no impacts on any heritage resources of the farm, however it is foreseen that the

preferred route will have less environmental impacts. Both these routes will not be visually impairing as the

pipeline will be placed underground. Both these proposed replacement pipeline routes are expected not to

trigger any EIA regulations as they will be an estimated 900 m long and will be placed more than 32 m from a

watercourse. No rivers or wetlands were identified along these newly proposed routes.

Reshaping and rehabilitation of the river banks with indigenous vegetation is also recommended once

environmental authorization has been granted. During the flooding event parts of the pipeline were broken and

some segments remain within the watercourse and/or are entangled within the riverine vegetation. These

damaged pipes are still currently within the watercourse and will be removed and disposed of at the nearest


S24GEIAR/07/2012 5

licenced landfill site once authorization is given to remove them. This is because the pre-compliance notice

that was issued to Mr. Doms instructed all listed activates to cease immediately. It is recommended that

erosion protection measures, such as the reshaping of eroded banks and the installation of erosion protection

structures be implemented at the point where the pipeline crossed the river.

(b) Is/was the project a new development or an upgrade of an existing development? Also

indicate the date (e.g. 2 August 2010) when the activity commenced as well as the

original date of commencement if the application is an upgrade.

New Upgrade

The illegal construction of a water pipeline occurred in November 2013.

(c) Clearly describe the activity and associated infrastructure commenced with, indicating what has been completed and

what still has to be completed.

In July 2013 the client Mr. Marc Doms of Saratoga Farm purchased the farm Klaas Voogds Rivier (portion 4

of farm 40) from owner Mr. Pat Busch. A 30% share in water use rights to the existing dam situated on Mr.




existing PVC 110 mm pipeline. The roughly 1.6 km 160 mm PVC pipeline was subsequently illegally

constructed in November 2013, within 32 meters from a watercourse (the Doring River) without environmental

authorization, legally required in terms of the National Environmental Management Act, (Act no. 107 of 1998).

This pipeline crossed the river in two places where it was suspended on wooden supports anchored by

concrete foundations. During an unexpected flooding event triggered by heavy rainfall in January 2014 the

Doring River flooded its banks and the 160 mm pipeline was severely damaged and some sections of the

original existing 110 mm pipeline was also damaged. This flood also modified the river channel by

establishing a new river course, along the alignment of the unauthorised pipeline and eroded the bank into

the first row of an adjacent vineyard. There was however no damage to the pipeline between the dam and

where it meets the river (the northern section). The Department of Environmental Affairs and Development

Planning was notified and a pre-compliance notice was issued to Mr. Doms in February 2016.




attach to the existing 160 mm pipeline well above where the flood damage to the pipeline occurred (more

than 32 m from the river). Both the preferred and alternative pipeline routes will follow the same route and be













environmental authorization has been granted. During the flooding event parts of the pipeline were broken

and some segments remain within the watercourse and/or are entangled within the riverine vegetation. These





S24GEIAR/07/2012 6



(d) Please provide details of all components of the activity and attach diagrams (e.g. architectural drawings or perspectives,

engineering drawings, process flow charts etc.).

Buildings YES NO

Provide brief description:

No buildings will be constructed.

Infrastructure (e.g. roads, power and water supply/ storage) YES NO


Water Supply:

A roughly 1.6 km long, 160 mm water supply pipeline was illegally constructed in November 2013, within 32

meters from a watercourse (the Doring River) without environmental authorization. During an unexpected

flooding event in January 2014 the Doring River flooded its banks and the 160 mm pipeline was severely

damaged. This flood also modified the river channel by establishing a new river course, along the alignment

of the unauthorised pipeline and eroded the bank into the first row of an adjacent vineyard. There was

however no damage to the pipeline between the dam and where it meets the river (the northern section).




attach to the existing 160 mm pipeline well above where the flood damage to the pipeline occurred (more

than 32 m from the river). Both the preferred and alternative pipeline routes will follow the same route and be













environmental authorization has been granted. During the flooding event parts of the pipeline were broken

and some segments remain within the watercourse and/or are entangled within the riverine vegetation. These






Processing activities (e.g. manufacturing, storage, distribution) YES No


Storage facilities for raw materials and products (e.g. volume and substances to be stored)

Provide brief description YES No

Storage and treatment facilities for solid waste and effluent generated by the project Yes No

Provide brief description


S24GEIAR/07/2012 7

(d) Other activities (e.g. water abstraction activities, crop planting activities) Yes No

Provide brief description

In July 2013 the client Mr. Marc Doms of Saratoga Farm purchased the farm Klaas Voogds Rivier (portion 4

of farm 40) from owner Mr. Pat Busch. A 30% share in water use rights to the existing dam situated on Mr.




existing 110 mm pipeline. The roughly 1.6 km 160 mm pipeline was subsequently illegally constructed in

November 2013, within 32 meters from a watercourse (the Doring River) without environmental authorization.

Water was however legally abstracted from the dam on Mr. Busch’s farm for a short period of time until the

pipeline was damaged.

3. PHYSICAL SIZE OF THE ACTIVITY

Indicate the physical spatial size of the activity as well as associated infrastructure (footprints): m2

Indicate the area that has been transformed / cleared to allow for the activity as well as associated

infrastructure:

Area disturbed by construction of a 1.6 km pipeline. Approx. 1600

m2

Total area:

Total area disturbed by construction of a 1.6 km pipeline. Approx. 1600

m2

4. SITE ACCESS

Was there an existing access road? YES No

If NO, what was the distance over which the new access road was built? m

Describe the type of access road constructed:

The access to the site where the pipeline was constructed was gained on from existing farm dirt/gravel roads

and over a pasture field.

Please Note: indicate the position of the access road on the site plan (See Section 5 below)

5. SITE PHOTOGRAPHS

Colour photographs of the site and its surroundings (taken of the site and from the site), both before (if available) and after the

activity commenced, with a description of each photograph, must be attached to this application. The vantage points from

which the photographs were taken must be indicated on the site plan, or locality plan as applicable. If available, please also

provide past and recent aerial photographs. It should be supplemented with additional photographs of relevant features on the

site. Date and source of photographs must be included. Photographs must be attached as an appendix to this form.

6. APPLICABLE LEGISLATION, POLICIES AND/OR GUIDELINES

Please list all legislation, policies and/or guidelines that were or are relevant to this activity.


S24GEIAR/07/2012 8

LEGISLATION ADMINISTERING AUTHORITY

TYPE

Permit/ license/

authorization/comment

DATE

(if already obtained):

In terms of sections 24 and 24D of the National Environmental Management Act, 1998 (EIA Regulations GN R. No. 982 [4 Dec 2014])

Department of Environmental Affairs and Development Planning (DEA&DP)

ENVIRONMENTAL AUTHORIZATION

Pending

In terms of section 38 of the National Heritage Resource Act No. 25 of 1999.

Heritage Western Cape (HWC)

Comment / Consent / Decision (ROD)

Received 30 May 2016

POLICY/ GUIDELINES ADMINISTERING AUTHORITY

Provincial Spatial Development Framework Western Cape Provincial Government

Spatial Development Framework 2014 Langeberg Municipality

Integrated Development Plan 2014 Langeberg Municipality

DEA&DP NEMA EIA Regulations Guideline & Information Document Series Guideline on Public Participation July 2006

Department of Environmental Affairs and Development Planning

DEA&DP NEMA EIA Regulations Guideline & Information Document Series Guidelines on specialist input


DEA&DP NEMA EIA Regulations Guideline & Information Document Series Guideline on Alternatives July 2006


DEA&DP Guideline for environmental decision-making by municipalities in the Western cape



S24GEIAR/07/2012 9

SECTION B: DESCRIPTION OF RECEIVING ENVIRONMENT

Site/Area Description

For linear activities (pipelines, etc) as well as activities that cover very large sites, it may be necessary to complete copies of 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. 1, 2, or 3):

1. GRADIENT OF THE SITE

Indicate the general gradient of the site(s) (cross out the appropriate box).

Flat Flatter than 1:10 1:10 – 1:5 Steeper than 1:5

2. LOCATION IN LANDSCAPE

Indicate the landform(s) that best describes the site (cross out (“”) the appropriate box(es).

Ridgeline Plateau Side slope of

hill/mountain

Closed

valley

Open

valley Plain

Undulating

plain/low hills Dune

Sea-

front Other

The site where the illegal construction of a 160 mm PVC pipeline occurred is located on Portion 14 of farm

No. 40, within a valley bottom and covers approximately 101.58 hectares (33°46'41.88" S19°59'41.54" E).

The farm is zoned agriculture and falls outside the urban edge of Robertson. A natural occurring semi-

permanent watercourse, the Doring River (a tributary of the Breede River), runs through the property. This

watercourse serves as a habitat for various terrestrial and aquatic flora and fauna that can be deemed as a

natural resource. It is expected that the newly proposed construction of the pipeline will have a minimal

impact on the watercourse. A freshwater ecological study and a botanical study have been conducted and the

results thereof are included in this Section 24G Environmental Impact Assessment Draft Report.

According to the 1:250 00 Geological Series Map 3319 (Worcester) the site is located over Shale of the

Noree Formation, Malmesbury group. The soils are accumulations of alluvium. There is a mountain range

adjacent to the farm, the Langeberg-Wes Mountain Catchment Protected Area, which will increase the

aesthetic appeal of the area and surrounding landscape and could be deemed a heritage resource, however

the adjacent natural vegetation will not be impacted upon by the proposed construction of the new pipeline

route. A notice of intent to develop has been submitted to Heritage Western Cape (HWC), and they have

issued a positive Record of Decision, to permit the proposed construction on the 30th of May 2016. This is

because the newly proposed route encompasses predominantly on pasture fields and an existing dirt/gravel

road. The farm is located within a valley meaning that it will not be very visible from afar. The farm is also

located at the end of a cul-de-sac road (Klaasvoogds wes road) meaning that little to no through traffic can be

expected.

3. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE

3.1 GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE (PRE-COMMENCEMENT)

Is the site(s) located on or near any of the following (cross out (“”) the appropriate boxes)?

Shallow water table (less than 1.5m deep) YES NO UNSURE

Seasonally wet soils (often close to water bodies) YES NO UNSURE

Unstable rocky slopes or steep slopes with loose soil YES NO UNSURE


S24GEIAR/07/2012 10

Dispersive soils (soils that dissolve in water) YES NO UNSURE

Soils with high clay content YES NO UNSURE

Any other unstable soil or geological feature YES NO UNSURE

An area sensitive to erosion YES NO UNSURE

3.2 GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE (POST-COMMENCEMENT)

Shallow water table (less than 1.5m deep) YES NO UNSURE

Seasonally wet soils (often close to water bodies) YES NO UNSURE

Unstable rocky slopes or steep slopes with loose soil YES NO UNSURE

Dispersive soils (soils that dissolve in water) YES NO UNSURE

Soils with high clay content YES NO UNSURE

Any other unstable soil or geological feature YES NO UNSURE

An area sensitive to erosion YES NO UNSURE

If any of the answers to the above are “YES” or “unsure”, specialist input may be requested by the Department.

(Information in respect of the above will often be available at the planning sections of local authorities. Where it does not exists,

the 1:50 000 scale Regional Geotechnical Maps prepared by Geological Survey may also be used).

The pipeline was constructed parallel to the Doring River in the floodplain. This pipeline crossed the river in two

places where it was suspended on wooden supports anchored by concrete foundations. During an unexpected

flooding event triggered by heavy rainfall in January 2014 the Doring River flooded its banks and the 160 mm

pipeline was severely damaged. This flood also modified the river channel by establishing a new river course,

along the alignment of the unauthorised pipeline and eroded the bank into the first row of an adjacent vineyard.

This will require reshaping and rehabilitation of the river banks with appropriate indigenous vegetation to stabilize

them and to reduce possible further erosion. It is recommended that erosion protection measures, such as the

reshaping of eroded banks and the installation of erosion protection structures be implemented at the point

where the pipeline crossed the river. The proposed alternative route for a new pipeline does not occur on

unstable soil as it will be places underneath an existing dirt/gravel road.

4. SURFACE WATER

4.1 SURFACE WATER (PRE-COMMENCEMENT)

Indicate the surface water present on and or adjacent to the site and alternative sites (cross out (“”) the appropriate boxes)?

Perennial River YES NO UNSURE

Non-Perennial River YES NO UNSURE

Permanent Wetland YES NO UNSURE

Seasonal Wetland YES NO UNSURE

Artificial Wetland YES NO UNSURE

Estuarine / Lagoonal wetland YES NO UNSURE

The perceived reference state of the site according to FCG is as follows. Prior to agricultural development within

the area, on portion 14 of farm 40 Klaas Voogds Rivier, the Doring River would have been less confined than it

currently is. It would most likely have been characterised by having multiple channels or would have been a


S24GEIAR/07/2012 11

mobile channel that periodically shifted its position across the valley floor. This is in contrast to the present-day

situation of a single channel running along the western edge property. The original reference state cannot be

confirmed as the oldest dated aerial photographs dates back to 1966 and by this time the Doring River valley

had already been developed by agriculture and the river was confined to a single channel. A Present Ecological

State (PES) assessments was completed by FCG for the presumed ecological state of the river before the illegal

construction of the pipeline. This pre-pipeline PES indicated that the instream component of the Doring River

was rated to be “largely modified” (PES Class D, Freshwater Ecology Impact Assessment Appendix 1), and the

riparian zone was rated to be “moderately to largely modified” (PES Class C/D Freshwater Ecology Impact

Assessment Appendix 1). This impacts on the instream component is believed to be due to an altered flow

regime from water abstraction from the feeder dam and also because of the modification of the river bed,

channel and banks that resulted from previous agricultural practices. The impacts on the riparian zone is

believed to be due to channel modification, a decrease in indigenous vegetation within the riparian zone and an

increase in alien vegetation.

4.2 SURFACE WATER (POST-COMMENCEMENT)

Indicate the surface water present on and or adjacent to the site and alternative sites (cross out (“”) the appropriate boxes)?

Perennial River YES NO UNSURE

Non-Perennial River YES NO UNSURE

Permanent Wetland YES NO UNSURE

Seasonal Wetland YES NO UNSURE

Artificial Wetland YES NO UNSURE

Estuarine / Lagoonal wetland YES NO UNSURE

The roughly 1.6 km 160 mm PVC pipeline was subsequently illegally constructed in November 2013, in parts

parallel and within 32 m of a natural occurring watercourse (the Doring River) without environmental

authorization. This pipeline crossed the river in two places where it was suspended on wooden supports

anchored by concrete foundations. The present state (assessed by FCG on 12 May 2016, 2 years after the

pipeline construction) of the Doring River was rated to be marginally better than the pre-impact state in terms of

the instream component of the river (PES Class C/D – “moderately to largely modified”), although marginally

worse in terms of the riparian component (PES Class D – “largely modified”). This improvement in the state of

the instream component of the river after the January 2014 flood is because the river established a new flow-

path, along the line where the unauthorised water pipeline had been placed from where it crossed the river. This

new river course bypassed the section of the river channel that was clearly an original diversion due to

agricultural activities in the valley according to the FCG. This new river course and river bed currently has a

more natural substrate of cobbles compared to the narrow densely vegetated old bypass route (which adjoined

the Doring River at nearly a 90 degree angle), further improving the new river course’s instream component. The

reason for the slightly poorer ecological condition of the riparian zone after the construction of the pipeline and

subsequently the January 2014 flood was due to an increase in the degree of channel modification and,

especially, increased bank erosion. The erosion that occurred on the Doring River bank, particularly where the

pipeline crossed the river, is considered to be significantly greater than the natural levels of erosion that would

have been observed during naturally-occurring flood events. This erosion will however be rectifiable with

appropriate bank reshaping and rehabilitation. The Ecological Importance and Sensitivity (EIS) of Doring River

was also assessed by FCG and indicated that the overall EIS rating of this system is of low-to-moderate

importance and sensitivity.


S24GEIAR/07/2012 12

5. VEGETATION AND/OR GROUNDCOVER

Please note: The Department may request specialist input/studies depending on the nature of the biodiversity occurring on the

site and potential impact(s) of the activity/ies. To assist with the identification of the biodiversity occurring on site and the

ecosystem status consult http://bgis.sanbi.org or [email protected]. Information is also available on compact disc (“cd”) from

the Biodiversity-GIS Unit, Ph (021) 799 8698. This information may be updated from time to time and it is the applicant/ EAP’s

responsibility to ensure that the latest version is used. A map of the relevant biodiversity information (including an indication of

the habitat conditions as per (b) below) and must be provided as an overlay map to the property/site plan as an appendix to

this form.

5.1 VEGETATION AND/OR GROUNDCOVER (PRE-COMMENCEMENT)

Cross out (“”) the block and describe (where applicable) the vegetation types / groundcover present on the site before

commencement of the activity.

Indigenous Vegetation - good

condition

Indigenous Vegetation with

scattered aliens X Indigenous Vegetation with heavy

alien infestation

Describe the vegetation type above:

Describe the vegetation type

above:

The vegetation type of the construction area is listed as FRs8 Breede Shale Renosterveld according to Mucina,L. & Rutherford, M.C.(eds) 2006. A more recent classification of this vegetation was undertaken by Helme (2007) who referred to it as Klaasvoogds Thicket Renosterveld. The riparian vegetation has been significantly altered due to the presence of alien species such as Populus (invasive cat. 2), Salix (Weeping willow), Kikuyu grass (Pennistetum) (cat. 1b) etc.

There is no true Breede Shale Renosterveld vegetation present on site. No threatened plant species or species of conservation concern were found on the site. The site has been transformed due to farming activities. The absence of this vegetation type was confirmed by a botanical specialist.


Provide ecosystem status for above:



Breede Shale Renosterveld vegetation type is listed to be Vulnerable

Indigenous Vegetation in an

ecological corridor or along a soil

boundary / interface

Veld dominated by alien species

Distinctive soil conditions (e.g. Sand over

shale, quartz patches, limestone, alluvial

deposits, termitaria etc.) – describe

Bare soil

Building or other structure

Sport field

Other (describe below) Cultivated land Paved surface

http://bgis.sanbi.org/

mailto:[email protected]


S24GEIAR/07/2012 13

(a) Highlight the applicable pre-commencement biodiversity planning categories of all areas on site and indicate the reason(s)

provided in the biodiversity plan for the selection of the specific area as part of the specific category.

Systematic Biodiversity Planning Category If CBA or ESA, indicate the reason(s) for its selection in biodiversity

plan

Critical

Biodiversity

Area

(CBA)

Ecological

Support

Area (ESA)

Other

Natural

Area (ONA)

No Natural

Area

Remaining

(NNR)

A portion of the site falls within an ESA as the pipeline was

constructed in close proximity to the Doring River. There is

no true Breede Shale Renosterveld vegetation present on

site. No threatened plant species or species of conservation

concern were found on the site. The absence of this

vegetation type was confirmed by a botanical specialist.

There are also large amounts of alien species present on the

site.

The site does not fall or impact on any Critical Biodiversity

Areas.

(b) Highlight and describe the habitat condition on site.

Habitat Condition

Percentage of

habitat condition

class (adding up

to 100%)

Description and additional Comments and Observations

(including additional insight into condition, e.g. poor land management

practises, presence of quarries, grazing/harvesting regimes etc).

Natural

10% Acacia thicket (Vachellia karoo) typical of riparian thicket (azonal

vegetation) in the river valley on the south of the Langeberg. This

vegetation is not threatened.

Near Natural

(includes areas with low

to moderate level of alien

invasive plants)

0%

Degraded

(includes areas heavily

invaded by alien plants)

20% The riparian vegetation has been significantly altered due to the

presence of alien species such as Populus (invasive cat. 2), Salix

(Weeping willow), Kikuyu grass (Pennistetum) (cat. 1b) etc.

Transformed

(includes cultivation,

dams, urban, plantation,

roads, etc)

70% There is no true Breede Shale Renosterveld vegetation present on

site. The area has largely been utilized for agricultural purposes with

the surrounding area being dominated by pasture fields and

vineyards. The absence of this vegetation type was confirmed by a

botanical specialist.

(c) Complete the table to indicate:

(i) the type of vegetation, including its ecosystem status, that was previously present on the site; and

(ii) whether an aquatic ecosystem was previously present on site.

Terrestrial Ecosystems Aquatic Ecosystems

Ecosystem threat status as per the National

Environmental Management: Biodiversity Act

(Act No. 10 of 2004)

Critical Wetland (including rivers,

depressions, channelled

and unchanneled

wetlands, flats, seeps

pans, and artificial

wetlands)

Estuary Coastline Endangered

Vulnerable

Least

Threatened YES NO UNSURE YES NO YES NO


S24GEIAR/07/2012 14

(d) Please provide a description of the vegetation type and/or aquatic ecosystem present on site, including any important

biodiversity features/information identified on site (e.g. threatened species and special habitats)

The majority of the illegally constructed pipeline occurred within the FRs8 Breede Shale Renosterveld (VU)

vegetation type, according to Mucina,L. & Rutherford, M.C.(eds) 2006. A more recent classification of this

vegetation was undertaken by Helme (2007) who referred to it as Klaasvoogds Thicket Renosterveld. The

riparian vegetation has been significantly altered due to the presence of alien species such as Populus

canescens (invasive cat. 2), Salix babylonica (Weeping willow), Acacia saligna (Port Jackson Willow), Senna

didymibotrya (Peanut butter cassia), Solanum sisymbriifolium (Sticky nightshade), Arundo donax (Spanish reed)

Cirsium vulgare (Spear thistle) and Kikuyu grass (Pennistetum clandestinum) (cat. 1b). There is no true Breede

Shale Renosterveld vegetation present on site. No threatened plant species or species of conservation concern

were found on the site. The site has been transformed due to farming activities. The absence of this vegetation

type was confirmed by a botanical specialist, Dr Dave McDonald of Bergwind Botanical Surveys and Tours. This

botanical assessment also noted that the vegetation on the banks of the Doring River around the site has been

strongly influenced by invasive species and this is a contributing factor to the instability of the soils and played a

role in the flood damage as a result. Where not invaded by alien species Acacia thicket (Vachellia karoo) typical

of riparian thicket (azonal vegetation) is present in the river valley on the south of the Langeberg. This vegetation

is not threatened.

The perceived reference state of the site according to FCG is as follows. Prior to agricultural development within

the area, on portion 14 of farm 40 Klaas Voogds Rivier, the Doring River would have been less confined than it

currently is. It would most likely have been characterised by having multiple channels or would have been a

mobile channel that periodically shifted its position across the valley floor. This is in contrast to the present-day

situation of a single channel running along the western edge property. The original reference state cannot be

confirmed as the oldest dated aerial photographs dates back to 1966 and by this time the Doring River valley had

already been developed by agriculture and the river was confined to a single channel. A Present Ecological State

(PES) assessments was completed by FCG for the presumed ecological state of the river before the illegal

construction of the pipeline. This pre-pipeline PES indicated that the instream component of the Doring River was

rated to be “largely modified” (PES Class D, Freshwater Ecology Impact Assessment Appendix 1), and the

riparian zone was rated to be “moderately to largely modified” (PES Class C/D Freshwater Ecology Impact

Assessment Appendix 1). This impacts on the instream component is believed to be due to an altered flow

regime from water abstraction from the feeder dam and also because of the modification of the river bed, channel

and banks that resulted from previous agricultural practices. The impacts on the riparian zone is believed to be

due to channel modification, a decrease in indigenous vegetation within the riparian zone and an increase in

alien vegetation.

The mountain range adjacent to the farm, the Langeberg-Wes Mountain Catchment Protected Area, is

predominantly made up of FRs8 Breede Shale Renosterveld (VU) and FFh4 Breede Shale Fynbos (VU),

although this vegetation was not disturbed by the construction of the pipeline.

5.2 VEGETATION AND/OR GROUNDCOVER (POST-COMMENCEMENT)

Cross out (“”) the block and describe (where required) the vegetation types / groundcover present on the site after

commencement of the activity.

Indigenous Vegetation - good

condition

Indigenous Vegetation with

scattered aliens X Indigenous Vegetation with heavy

alien infestation


S24GEIAR/07/2012 15


Describe the vegetation type

above:

The vegetation type of the construction area is listed as FRs8 Breede Shale Renosterveld according to Mucina,L. & Rutherford, M.C.(eds) 2006. A more recent classification of this vegetation was undertaken by Helme (2007) who referred to it as Klaasvoogds Thicket Renosterveld. The riparian vegetation has been significantly altered due to the presence of alien species such as Populus (invasive cat. 2), Salix (Weeping willow) Kikuyu grass (Pennistetum) (cat. 1b) etc.


There is no true Breede Shale Renosterveld vegetation present on site. No threatened plant species or species of conservation concern were found on the site. The site has been transformed due to farming activities. The absence of this vegetation type was confirmed by a botanical specialist.

A small portion (± 50 m) of the proposed preferred and alternative replacement pipeline route is mapped as the Breede Alluvium Renosterveld threatened ecosystem. This vegetation type also no longer occurs here due to the current presence of a planted pasture field and a farm homestead.



Provide Ecosystem status for above:

FRs8 Breede Shale Renosterveld vegetation type is listed to be Vulnerable. Breede Alluvium Renosterveld threatened ecosystem is listed as Vulnerable.

Indigenous Vegetation in an

ecological corridor or along a soil

boundary / interface

Veld dominated by alien species

Distinctive soil conditions (e.g. Sand over

shale, quartz patches, limestone, alluvial

deposits, termitaria etc.) – describe

Bare soil

Building or other structure

Sport field

Other (describe below) Cultivated land Paved surface


S24GEIAR/07/2012 16

(a) Highlight and describe the post-construction habitat condition on site.

Habitat Condition

Percentage of

habitat condition

class (adding up

to 100%)

Description and additional Comments and Observations

(including additional insight into condition, e.g. poor land management

practises, presence of quarries, grazing/harvesting regimes etc).

Natural

10% Acacia thicket (Vachellia karoo) typical of riparian thicket (azonal

vegetation) in the river valley on the south of the Langeberg. This

vegetation is not threatened.

Near Natural

(includes areas with low

to moderate level of alien

invasive plants)

0%

Degraded

(includes areas heavily

invaded by alien plants)

15% The riparian vegetation has been significantly altered due to the

presence of alien species such as Populus (invasive cat. 2), Salix

(Weeping willow), Kikuyu grass (Pennistetum) (cat. 1b) etc.

Transformed

(includes cultivation,

dams, urban, plantation,

roads, etc)

75% There is no true Breede Shale Renosterveld vegetation present on

site. The area has largely been utilized for agricultural purposes with

the surrounding area being dominated by pasture fields and

vineyards. The absence of this vegetation type was confirmed by a

botanical specialist.

The site was also altered by erosion from the flooding event that

took place not long after the construction of the pipeline. A proposed

preferred and alternative new route for a replacement pipeline will

result in minimal impacts on the environment as it will be

constructed in a pasture field and underneath an existing road, all of

which have been previously transformed.

(b) How have the vegetation and/or aquatic ecosystem(s) present on site (including any important biodiversity features

identified on site (e.g. threatened species and special habitats)) been affected by the commencement of the listed

activity(ies)?


vegetation type, according to Mucina,L. & Rutherford, M.C.(eds) 2006. A more recent classification of this

vegetation was undertaken by Helme (2007) who referred to it as Klaasvoogds Thicket Renosterveld. The

riparian vegetation has been significantly altered due to the presence of alien species such as Populus


didymibotrya (Peanut butter cassia), Solanum sisymbriifolium (Sticky nightshade), Arundo donax (Spanish

reed) Cirsium vulgare (Spear thistle) and Kikuyu grass (Pennistetum clandestinum) (cat. 1b). There is no true

Breede Shale Renosterveld vegetation present on site. No threatened plant species or species of

conservation concern were found on the site. The site has been transformed due to farming activities. The

absence of this vegetation type was confirmed by a botanical specialist, Dr Dave McDonald. This botanical

assessment also noted that the vegetation on the banks of the Doring River around the site has been strongly

influenced by invasive species and this is a contributing factor to the instability of the soils and played a role in

the flood damage as a result.




anchored by concrete foundations. This watercourse serves as a habitat for various terrestrial and aquatic flora

and fauna that can be deemed a natural resource. A freshwater ecological assessment was also conducted to

determine the impact of the pipeline on the aquatic diversity of the Doring River by the Dean Ollis of the

Freshwater Consulting Group (FCG). The present state (assessed by FCG on 12 May 2016, 2 years after the


S24GEIAR/07/2012 17

pipeline construction) of the Doring River was rated to be marginally better than the pre-impact state in terms of

the instream component of the river (PES Class C/D – “moderately to largely modified”), although marginally


the instream component of the river after the January 2014 flood is because the river established a new flow-

path, along the line where the unauthorised water pipeline had been placed from where it crossed the river.

This new river course bypassed the section of the river channel that was clearly an original diversion due to

agricultural activities in the valley according to the FCG. This new river course and river bed currently has a

more natural substrate of cobbles compared to the narrow densely vegetated old bypass route (which adjoined

the Doring River at nearly a 90 degree angle), further improving the new river course’s instream component.

The reason for the slightly poorer ecological condition of the riparian zone after the construction of the pipeline

and subsequently the January 2014 flood was due to an increase in the degree of channel modification and,

especially, increased bank erosion. The erosion that occurred on the Doring River bank, particularly where the

pipeline crossed the river, is considered to be significantly greater than the natural levels of erosion that would

have been observed during naturally-occurring flood events. This erosion will however be rectifiable with

appropriate bank reshaping and rehabilitation. The Ecological Importance and Sensitivity (EIS) of Doring River

was also assessed by FCG and indicated that the overall EIS rating of this system is of low-to-moderate

importance and sensitivity.

This freshwater study also indicated that the flood-related damage to the Doring River was not attributable to

the unauthorised water pipeline construction. This is evident from the magnitude of damage caused by the

flood, which extends well beyond the reach of the river that could have been affected by the pipeline and was

clearly a major flood event, which would have resulted in extensive erosion-related damage along the Doring

River whether the unauthorised pipeline had been present or not. However flood-related ecological impacts

were exacerbated by the presence of the unauthorised pipeline, in particular, more intensive bank erosion

occurred at the point where the pipeline crossed the river. The excavation of a trench for the pipeline alongside

the Doring River would also have facilitated the modification of the channel that resulted in a new river course.

The overall significance of these impacts was rated by FCG to be low-to-medium without rectification and would

become low with rectification. The negative impacts associated with the flood-related modifications to the river

must, however, be weighed up against the positive impact of the improvement of the instream habitat within the

new channel.

A proposed preferred new route for a replacement pipeline will result in minimal impacts and will not further

impact on the surrounding vegetation. This is because the newly proposed routes encompasses predominantly

on pasture fields and an existing dirt/gravel road. No rivers or wetlands were identified along these newly

proposed routes. A small portion (± 50 m) of the proposed preferred and alternative replacement pipeline route

is mapped as the Breede Alluvium Renosterveld threatened ecosystem. This vegetation type also no longer

occurs here due to the current presence of a planted pasture field and a farm homestead. Reshaping and

rehabilitation of the river banks with indigenous vegetation is also recommended once environmental

authorization has been granted.

5.3 VEGETATION / GROUNDCOVER MANAGEMENT

(a) Describe any mitigation/management measures that were adopted and the adequacy of these:

The FCG recommended that no rectification measures are necessary to restore the instream habitat because

the modification of the river course has been a positive impact. This new river course will (and has already

begun to) stabilise itself over time. For the localised bank erosion that occurred at the point where the

unauthorised pipeline crossed the Doring River, rectification is recommended by the FCG. This should be

done by bank reshaping and rehabilitation in the areas indicated in the figure below by FCG. Guillaume Nel

Environmental Consultants should be consulted to design and oversee the implementation of the reshaping

and rehabilitation. It is in the opinion of the EAP that reshaping and rehabilitation of the river banks with


S24GEIAR/07/2012 18

indigenous vegetation should also be undertaken once environmental authorization is granted. The banks will

need to be reshaped to a 45 degree angle to reduce erosion. Existing rocks from the river bed should be

utilized to stabilize the banks where necessary. Hydroseeding and replanting of indigenous appropriate

riparian vegetation must then take place to establish the banks.

Figure 8 from the FCG report: Recent Google Earth image of Farm Klaas Voogds Rivier (from March 2016) showing the recommended

locations for the implementation of erosion protection measures.

It is suggested that these rehabilitation activities be conducted in accordance with the attached Environmental

Management Programme (EMP) and River Maintenance Management Plan (RMMP). A RMMP for the entire

Klaasvoogds-oos and Klaasvoogds-wes rivers has been conducted by the Southern Waters Ecological

Research and Consultants cc., and our RMMP and EMP is in line with this report. The RMMP includes the

repair of infrastructure, including where pipelines have been damaged due to flood events, as well as

sediment reworking to repair river berms and banks. Method statements and activity mitigation measures for

each of these activities have been included as part of this RMMP.

The riparian vegetation has been significantly altered due to the presence of alien species such as Populus



reed) Cirsium vulgare (Spear thistle) and Kikuyu grass (Pennistetum clandestinum) (cat. 1b). This alien

vegetation on the banks of the Doring River would have contributed to the instability of the soils which could

likely have led to the flood damage as a result. It is therefore important that alien clearing within the

watercourse and the river catchment area be strictly implemented.


S24GEIAR/07/2012 19

6. LAND USE OF THE SITE (PRE-COMMENCEMENT)

Please note: The Department may request specialist input/studies depending on the nature of the land use character of the

area and potential impact(s) of the activity/ies.

Untransformed area Low density

residential

Medium density

residential

High density

residential Informal residential

Retail Commercial &

warehousing Light industrial Medium industrial Heavy industrial

Power station Office/consulting

room

Military or police

base/station/compound

Casino/entertainment

complex

Tourism &

Hospitality facility

Open cast mine Underground

mine Spoil heap or slimes dam

Quarry, sand or

borrow pit Dam or reservoir

Hospital/medical center School Tertiary education facility Church Old age home

Sewage treatment plant Train station or

shunting yard Railway line

Major road (4 lanes or

more) Airport

Harbour Sport facilities Golf course Polo fields Filling station

Landfill or waste treatment site Plantation Agriculture River, stream or

wetland

Nature

conservation area

Mountain, koppie or ridge Museum Historical building Graveyard Archeological site

Other land uses (describe):

An existing 110 mm pipeline was present. The construction of a 160 mm followed

this pipeline route.

(a) Please provide a description.

The land use of the surrounding farms are predominantly for agricultural purposes. They include the farming of

wine grapes, Blueberries under tunnels, Olives, Pomegranates, Stone fruit, Citrus fruit and pasture fields. The

farm is located within a valley meaning that it will not be very visible from afar. The surrounding mountain

range adjacent to the farm, the Langeberg-Wes Mountain Catchment Protected Area, is predominantly made

up of FRs8 Breede Shale Renosterveld (VU) and FFh4 Breede Shale Fynbos (VU), although will not be

affected by the construction. The illegal pipeline was constructed parallel and adjacent to a natural occurring

semi-permanent watercourse. This watercourse serves as a habitat for various terrestrial and aquatic flora and

fauna that can be deemed as a natural resource. There is a dam on Mr. Busch’s farm supplying the water to

the pipeline however the pipeline was not damaged near to this point. The new replacement pipeline will be

proposed to be connected approximately 200m from the dam and run underneath a gravel road where it

previously diverted into a pasture field and then to continue along an existing gravel road towards the current

connecting point on the border between portion 14 and portion 4 of farm 40, Klaas Voogds Rivier. The farm is

also located at the end of a cul-de-sac road (Klaasvoogds wes road) meaning that little to no through traffic

can be expected.


S24GEIAR/07/2012 20

7. LAND USE CHARACTER OF SURROUNDING AREA (PRE-COMMENCEMENT)

Cross out (“”) the block that reflects the past land uses and/or prominent features that occur/red within +/- 500m radius of the

site and neighbouring properties if these are located beyond 500m of the site. Please note: The Department may request

specialist input/studies depending on the nature of the land use character of the area and impact(s) of the activity/ies.


residential

Medium density

residential

High density


Retail Commercial &



room

Military or police



complex

Tourism &




Quarry, sand or


Hospital/medical center School Tertiary education

facility Church Old age home




more) Airport

Harbour

Sport facilities Golf course Polo fields Filling station


wetland

Nature

conservation area

Mountain, koppie or ridge Museum Historical building Graveyard Archaeological

site

Other land uses (describe): Residential associated with Agricultural

8. LAND USE CHARACTER OF SURROUNDING AREA (POST-COMMENCEMENT)

Cross out (“”) the block that reflects the current land uses and/or prominent features that occur(s) within +/- 500m radius of the

site and neighbouring properties if these are located beyond 500m of the site. Please note: The Department may request

specialist input/studies depending on the nature of the land use character of the area and impact(s) of the activity/ies.


residential

Medium density

residential

High density


Retail Commercial &



room

Military or police



complex

Tourism &




Quarry, sand or


Hospital/medical center School Tertiary education

facility Church Old age home




more) Airport

Harbour

Sport facilities Golf course Polo fields Filling station


wetland

Nature

conservation area

Mountain, koppie or ridge Museum Historical building Graveyard Archaeological

site

Other land uses (describe): Residential associated with Agricultural


S24GEIAR/07/2012 21

SECTION C: PUBLIC PARTICIPATION

Please highlight the appropriate box to indicate whether the specific requirement will be undertaken or whether deviation from

such a requirement has been requested.

Has any public participation been done prior to this application, which the Applicant/EAP feels can

be considered to have fulfilled the requirements outlined in the NEMA EIA Regulations, 2010? YES NO

Please provide a description.

No Public Participation process for the EA process has yet been undertaken.

Which State Departments were consulted?


Details of Public Participation to be conducted in terms of the NEMA EIA Regulations, 2010:

1. Will all potential interested and affected parties be notified of the application by –

(a) fixing a notice board 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 to be undertaken; and YES NO DEVIATION

(ii) any alternative site mentioned in the application; YES NO DEVIATION

(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; YES NO DEVIATION

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

where the activity is to be undertaken; YES NO DEVIATION

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

and to any alternative site where the activity is to be undertaken; YES NO DEVIATION

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

any organisation of ratepayers that represent the community in the area; YES NO DEVIATION

(v) the municipality which has jurisdiction in the area; YES NO DEVIATION

(vi) any organ of state having jurisdiction in respect of any aspect of the activity; and YES NO DEVIATION

(vii) any other party as required by the competent authority; YES NO DEVIATION

(c) placing an advertisement in -

(i) one local newspaper; and YES NO DEVIATION

(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; YE S NO DEVIATION

(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.

YE S NO DEVIATION

2. What other Public Participation will be done?

The public participation includes:

Fixing of Notice boards around and at the site of activity.

Registered letters will be sent to all relevant I&AP’s.

Background information documents (BID) will be given to members of the community around the site

of activity.

A hard copy of the Draft Section 24G EIA Report will be made available at the Robertson public

librarie.

An Advertisement to invite the public to comment will be placed in the Breederivier Gazette (Local

Newspaper)

This Draft Section 24G EIA Report will be made available for comment from 12th July 2016 to the 15th

August 2016.


S24GEIAR/07/2012 22

Please note:

A list of all the potential interested and affected parties, including the organs of State must be opened,

maintained and made available to any person requesting access to the register, in writing.

All comments of interested and affected parties on the Application Form and Additional Information must be

recorded, responded to and included in the Comments and Responses Report attached as Appendix F to the

report. The Comments and Responses Report must also include a description of the Public Participation

Process followed.

The minutes of any meetings held by the EAP with interested and affected parties and other role players which

record the views of the participants must also be submitted as part of the public participation information to

be attached to the additional information/Environmental Impact Report as Appendix F.

Proof of all the notices given as indicated, as well as of notice to the interested and affected parties of the

availability of the draft Environmental Impact Report/Additional Information must be submitted as part of the

public participation information to be attached to the report as Appendix F.

Please be advised that the draft Environmental Impact Report/Additional Information must first be submitted

to the Department where after it must be made available to the public and all State Departments that

administer laws relating to a matter affecting the environment for comment for a period of 40 days. The

applicant/EAP is required to inform this Department in writing upon submission of the draft Environmental

Impact Report/Additional Information to the relevant State Departments. Upon receipt of this confirmation, this

Department will in accordance with Section 24 O (2) & (3) of the NEMA inform the relevant State Departments

of the commencement date of the 40 day commenting period or 60 days in the case of the Department of

Water Affairs for waste management activities which also require a license in terms of the National Water Act,

1998 (Act No. 36 of 1998). Please be further advised that a commenting period of 21 days will apply to all

requests for comment on any information, documentation or reports (including the final Environmental Impact

Report/Additional Information) other than the draft report, unless an alternative commenting period is

specified by this Department.

3. Provide a list of all the state departments that has been / will be consulted:

Department of Agriculture

Breede-Gouritz Catchement Management Agency

Cape Winelands District Municipality

Langeberg Municipality

CapeNature



S24GEIAR/07/2012 23

SECTION D: NEED AND DESIRABILITY

Please Note: Before completing this section, first consult this Department’s Guideline on Need and Desirability (October 2011f)

available on the Department’s website (http://www.capegateway.gov.za/eadp).

1. Was the activity permitted in terms of the property’s land use rights at the time

of commencement? YES NO Please explain

The current land use of the property has been assigned to Agricultural Zone 1. The construction of the pipeline

and subsequently the new construction of a replacement pipeline will promote agriculture on the farm as an

important economic resource and complies with the principles of the land use zoning scheme.

2. Was the activity in line with the following?

(a) Provincial Spatial Development Framework (PSDF) YES NO Please explain

The construction of the illegal pipeline and subsequently the new construction of a replacement pipeline would

allow for more effective utilization of the current agricultural environment by providing water to previously

unirrigated areas. This will lead to short and long term job creation opportunities, which will provide a much

needed economic injection into the local community. If the newly proposed replacement pipeline is constructed

in a sensitive manner, it will lead to long term contribution to local economic development in the district and

complies with the principles of sustainable development, one of the principles of the WCSDF. Another of the

key concerns of the Western Cape Spatial Development Framework (WCSDF) is food security and to promote

sustainable agriculture. The construction of the pipeline and subsequently the new construction of a

replacement pipeline, if done in a sensitive manner, will also help build the local food security of this country.

(b) Urban edge / Edge of Built environment for the area YES NO Please explain

The development on Portion 14 of Farm 40 is situated outside the Robertson Urban Edge.

(c) Integrated Development Plan and Spatial Development Framework of the

Local Municipality (e.g. would the approval of this application have

compromised the integrity of the existing approved and credible municipal

IDP and SDF?).

YES NO Please explain

The construction of the 160mm pipeline is not entirely in line with the IDP of the Langeberg Municipality.

However it does comply with the strategic objective to promote economic development within the municipal

area, by creating jobs in the agricultural segment. It is in our opinion that the construction of the pipeline

complies with the principles contained in the WCSDF. The Langeberg Municipality’s draft final Spatial

Development Framework (SDF) of 2014 confirms that the Agricultural industry is Langeberg Municipality’s

most important economic and employment sectors. Langeberg is fortunate in that its agricultural resources are

mostly intensive, comprising vineyards, orchards and pastures (all present on Mr. Doms, Saratoga farm).

Together with the magnificent scenery these resources and agricultural activities, especially wine-making form

the basis of its vibrant tourism industry. Agricultural resources should therefore be retained and improved and

not converted in the Langeberg region.

(d) Approved Structure Plan of the Municipality YES NO Please explain

The construction of the 160mm pipeline is not entirely in line with the IDP of the Langeberg Municipality.

However it does comply with the strategic objective to promote economic development within the municipal

area, by creating jobs in the agricultural segment. It is in our opinion that the construction of the pipeline

complies with the principles contained in the Western Cape Spatial Development Framework (WCSDF).

(e) An Environmental Management Framework (EMF) adopted by the Department

(e.g. Would the approval of this application have compromised the integrity of the

existing environmental management priorities for the area and if so, can it be

justified in terms of sustainability considerations?)


This assessment process being followed in this Section 24G Environmental Impact Assessment Draft Report

conforms to the principles of the Environmental Management Framework Regulations as this study takes into

http://www.capegateway.gov.za/eadp


S24GEIAR/07/2012 24

consideration the full impacts upon the biophysical and socio-cultural systems. The process attempts to

identify all potential impacts as well as identify practical means by which the developer can develop the

necessary mitigation measures to manage these impacts. The EIA process is structured in a way to identify

environmental risks, social-economic conditions, lessen community conflict by actively promoting public

participation, propose the means to minimise adverse environmental affects and inform all relevant

government decision makers. The impact assessment will ensure that all environmental assessments are

integrated into all aspects of the proposed project’s life cycle, construction/operation and decommissioning.

The EIA process identified all possible impacts. These impacts were evaluated to determine the actual impact

on the environment. The triple bottom approach was taken whereby the socio, economic and environmental

impacts were assessed. This also ensured that Section 2(3) of NEMA was adhered to. Section 2(4) of NEMA

was further taken into consideration to ensure that ecosystems and loss of biological diversity are avoided, or,

where they cannot be altogether avoided, are minimised and remedied.

The construction of the illegal pipeline could have impacted upon indigenous vegetation although a botanical

assessment, performed by Dr Dave McDonald, indicated that there is no true Breede Shale Renosterveld

vegetation present on site and that the pipeline would have only minimally impacted upon this vegetation.

There is also a significant amount of alien invasive vegetation on site that would have contributed to the

instability of the soils which could likely have led to the erosion of the river bank as a result. The indigenous

vegetation has largely been transformed due to agricultural activities. Reshaping of the eroded river banks and

rehabilitating them with appropriate indigenous vegetation is recommended to mitigate the effects of the illegal

pipeline construction and to reduce any further erosion and damage. This will be enforced according to the

attached EMP and RMMP.

A full public participation as per Section 54 is being undertaken as part of this application to invite all interested

and affected parties to participate in providing meaningful comments regarding the construction of the pipeline.

(f) Any other Plans (e.g. Guide Plan) YES NO Please explain

3. Was the land use (associated with the activity for which rectification is sought)

considered within the timeframe intended by the existing approved Spatial

Development Framework (SDF) agreed to by the relevant environmental

authority (i.e. was the development in line with the projects and programmes

identified as priorities within the relevant IDP)?


The construction of the illegal pipeline and subsequently the new construction of a replacement pipeline would

allow for more effective utilization of the current agricultural environment by providing water to previously

unirrigated areas. This will lead to short and long term job creation opportunities, which will provide a much

needed economic injection into the local community, fitting into the timeframes of increased job creation as a

long term SDF goal. If the newly proposed replacement pipeline is constructed in a sensitive manner, it will

lead to long term contribution to local economic development in the district and complies with the principles of

sustainable development, one of the principles of the WCSDF. Another of the key concerns of the Western

Cape Spatial Development Framework (WCSDF) is food security and to promote sustainable agriculture. The

construction of the pipeline and subsequently the new construction of a replacement pipeline, if done in a

sensitive manner, will also help build the local food security of this country

4. Should development, or if applicable, expansion of the town/area concerned

in terms of this land use (associated with the activity being applied for) have

occured here when activities commenced?


The site where the illegal construction of the 160 mm pipeline occurred was on a privately owned farm ± 10 km

from the town of Robertson and ± 8.4 km from Ashton. It therefore falls well outside the urban edge and is

therefore not identified as an area of urban growth demands according to the Langeberg Municipality’s SDF.


S24GEIAR/07/2012 25

5. Did the community/area need the activity and the associated land use

concerned (was it a societal priority)? (This refers to the strategic as well as

local level (e.g. development is a national priority, but within a specific local

context it could be inappropriate.)


The site where the illegal construction of the 160 mm pipeline occurred was on a privately owned farm ± 10 km

from the town of Robertson and ± 8.4 km from Ashton. The community/area did not need the associated land

use concerned as it was on private land not with public access. The construction of the pipeline will be used

for irrigation of agricultural fields, allowing for a more effective utilization of the current land parcel situated in

an agricultural environment. This will create short and long term job opportunities, providing a much needed

economic injection into the local community.

6. Were the necessary services with adequate capacity available (at the time of

commencement), or was additional capacity created to cater for the

development? (Confirmation by the relevant Municipality in this regard must

be attached to the Application Form / additional information as an

appendix, where applicable.)


The construction and maintenance of the pipeline will not require any municipal services as the pipeline is

gravity fed from the dam on Mr. Busch’s farm. A 30% share in water use rights to the existing dam situated on

Mr. Busch’s farm (portion 14 of farm 40) was purchased. The farm however does have the necessary services

from Eskom (see Addendum D, for recent electricity and water bill).

7. Is/was this development provided for in the infrastructure planning of the

municipality, and if not what was/will the implication be on the infrastructure

planning of the municipality (priority and placement of services and

opportunity costs)? (Comment by the relevant Municipality in this regard must

be attached to the Application Form / additional information as an

appendix, where applicable.)


The construction and maintenance of the pipeline will not require any municipal services as the pipeline is

gravity fed from the dam on Mr. Busch’s farm. A 30% share in water use rights to the existing dam situated on

Mr. Busch’s farm (portion 14 of farm 40) was purchased. The farm however does have the necessary services

from Eskom (see Addendum D, for recent electricity and water bill).

8. Was this project part of a national programme to address an issue of national

concern or importance? YES NO Please explain

N/A

9. Did location factors favour this land use (associated with the activity applied

for) at this place? (This relates to the contextualisation of the land use on this

site within its broader context.)


The development of the water pipeline on Portion 14 of Farm 40 is situated in an area historically dominated

by agricultural land use. The area can be defined as part of the Western Cape’s agricultural hub. The pipeline

was constructed on a farm between Robertson and Ashton, and situated on a site with a history of agricultural

use. It is therefore considered compatible with the surrounding land use and not expected to impact on

Cultural and Historic aspects.

10. How did/does the activity or the land use associated with the activity applied

for, impact on sensitive natural and cultural areas (built and rural/natural

environment)?



vegetation type, according to Mucina,L. & Rutherford, M.C.(eds) 2006. The riparian vegetation has been

significantly altered due to the presence of alien species such as Populus canescens (invasive cat. 2), Salix

babylonica (Weeping willow), Acacia saligna (Port Jackson Willow), Senna didymibotrya (Peanut butter

cassia), Solanum sisymbriifolium (sticky nightshade), Arundo donax (Spanish reed) Cirsium vulgare (Spear

thistle) and Kikuyu grass (Pennistetum clandestinum) (cat. 1b). A botanical assessment, performed by Dr

Dave McDonald, indicated that there is no true Breede Shale Renosterveld vegetation present on site. No

threatened plant species or species of conservation concern were found on the site. The site has been


S24GEIAR/07/2012 26

transformed due to farming activities. The vegetation on the banks of the Doring River around the site has

been strongly influenced by invasive species and this is a contributing factor to the instability of the soils and

played a role in the flood damage as a result.




anchored by concrete foundations. This watercourse serves as a habitat for various terrestrial and aquatic

flora and fauna that can be deemed a natural resource. A freshwater ecological assessment was also

conducted to determine the impact of the pipeline on the aquatic diversity of the Doring River by the Dean Ollis

of the Freshwater Consulting Group (FCG). The present state (assessed by FCG on 12 May 2016, 2 years

after the pipeline construction) of the Doring River was rated to be marginally better than the pre-impact state

in terms of the instream component of the river (PES Class C/D – “moderately to largely modified”), although

marginally worse in terms of the riparian component (PES Class D – “largely modified”). This improvement in

the state of the instream component of the river after the January 2014 flood is because the river established a

new flow-path, along the line where the unauthorised water pipeline had been placed from where it crossed

the river. This new river course bypassed the section of the river channel that was clearly an original diversion

due to agricultural activities in the valley according to the FCG. This new river course and river bed currently

has a more natural substrate of cobbles compared to the narrow densely vegetated old bypass route (which

adjoined the Doring River at nearly a 90 degree angle), further improving the new river course’s instream

component. The reason for the slightly poorer ecological condition of the riparian zone after the construction of

the pipeline and subsequently the January 2014 flood was due to an increase in the degree of channel

modification and, especially, increased bank erosion. The erosion that occurred on the Doring River bank,

particularly where the pipeline crossed the river, is considered to be significantly greater than the natural levels

of erosion that would have been observed during naturally-occurring flood events. This erosion will however be

rectifiable with appropriate bank reshaping and rehabilitation. The Ecological Importance and Sensitivity (EIS)

of Doring River was also assessed by FCG and indicated that the overall EIS rating of this system is of low-to-

moderate importance and sensitivity.









The overall significance of these impacts was rated by FCG to be low-to-medium without rectification and

would become low with rectification. The negative impacts associated with the flood-related modifications to

the river must, however, be weighed up against the positive impact of the improvement of the instream habitat

within the new channel.

A notice of intent to develop has been submitted to HWC, and they have issued a positive Record of Decision,

to permit the proposed construction on the 30th of May 2016, whereby no cultural or heritage resources is

believed to be impacted upon.

11. How did/does the development impact on people’s health and wellbeing

(e.g. in terms of noise, odours, visual character and sense of place, etc)? YES NO Please explain

No noise and odour impacts occurred during the construction of the water pipeline as these activities were

only temporary in nature. The visual character of the site was only minimally altered because the pipeline was

installed underneath the ground. The visual impact is thus considered to be not significant. The visual aspect

of the site was however altered as a result of a flooding event in January 2014 that caused erosion of the river


S24GEIAR/07/2012 27

banks. Mr. Karl Reinecke (Southers Waters Ecological Research and Consulting cc), the freshwater

consultants that have prepared a River Maintenance and Management Plan for the entire Klaasvoogds river

area. He was consulted for a site visit on the 6th of October 2014 to assess the erosion damage and to discuss

potential causes thereof and rehabilitation measures. Mr. Reinecke indicated that it would however be

impossible to attribute the reasons or cause for the flood damage without having been present at the time of

the flood. The construction of the water pipeline is not expected to alter the sense of place and character of the

site, as it fits into the current land use being utilized for agriculture.

12. Did/does the proposed activity or the land use associated with the activity

applied for, result in unacceptable opportunity costs? YES NO Please explain

The construction of the water pipeline, in addition, allows for a more effective utilization of the current dormant

land parcel situated in an agricultural environment which will, with the short and long term job creation

opportunities, provide a much needed economic injection into the local community.

13. What were the cumulative impacts (positive and negative) of the land use

associated with the activity applied for? YES NO Please explain

The cumulative negative effect of the construction of the pipeline was the likely transformation of a portion of

riverine vegetation and Breede Shale Renosterveld vegetation type. The botanical assessment, performed

by Dr Dave McDonald, indicated that there is no true Breede Shale Renosterveld vegetation present on site

and that the pipeline would have only minimally impacted upon this vegetation. This assessment also indicated

that alien vegetation is present on the banks of the Doring River and would have contributed to the instability

of the soils which could likely have led to the flood damage as a result. No threatened plant species or species

of conservation concern were found on the site. The vegetation was therefore not in a pristine state and the

impact on the indigenous vegetation would have been minimal. The site was however transformed due to

agricultural purposes. Very little temporally visual and noise impacts associated with the construction of the

pipeline would have however also have added to the cumulative impact. The visual aspect of the site was

however altered as a result of a flooding event in January 2014 that caused erosion of the river banks. Mr. Karl

Reinecke (Southers Waters Ecological Research and Consulting cc), the freshwater consultants that have

prepared a River Maintenance and Management Plan for the entire Klaasvoogds river area. He was consulted

for a site visit on the 6th of October 2014 to assess the erosion damage and to discuss potential causes thereof

and rehabilitation measures. Mr. Reinecke indicated that it would however be impossible to attribute the

reasons or cause for the flood damage without having been present at the time of the flood.

The cumulative positive impacts were the short and long term job opportunities that were created by the

construction and the subsequent operation of the farming activities that would have been established as a

result of the construction of the pipeline. This pipeline will allow Mr. Doms to further expand on the agricultural

activities on his farm, potentially leading to additional job creation and financial injection in the local

community.

14. Is/was the development the best practicable environmental option for this

land/site? YES NO Please explain

The construction of the pipeline on portion 14 of farm 40 is situated in an area historically dominated by

agricultural land use. The area can be defined as part of the Western Cape’s agricultural hub and is located

between Robertson and Ashton. It is therefore considered compatible with the surrounding land use and not

expected to impact on Cultural and Historic aspects. However, during the site visit conducted on the 6th of

October 2014 the previous pipeline route (that was destroyed in the flood) was assessed in terms of its viability

in order to replace the 160 mm pipeline along the same route. It was the opinion of both GNEC and Mr. Karl

Reinecke that this route is not a viable option as any possible future flooding could result in the same

detrimental outcome. The costs for constructing such a pipeline is very high and it would be a significant risk to

replace the pipeline along the same route. It is the contention of GNEC that this route should never have been

deemed a viable option in terms of environmental impact.


S24GEIAR/07/2012 28

17. Please describe how the general objectives of Integrated Environmental Management as set out in section 23 of NEMA

were taken into account:

The Impact Assessment process conforms to the principles of Integrated Environmental Management (IEM).

The process attempts to identify all potential impacts as well as identify practical means by which the

developer can develop the necessary mitigation measures to manage these impacts. The EIA process is

structured in a way to identify environmental risks, social-economic conditions, lessen community conflict by

actively promoting public participation, propose the means to minimise adverse environmental affects and

inform all relevant government decision makers.

The impact assessment will ensure that all environmental assessments are integrated into all aspects of the

proposed project’s life cycle, construction/operation and decommissioning. The EIA process identified all

possible impacts. These impacts were evaluated to determine the actual impact on the environment. The triple

bottom approach was taken whereby the socio, economic and environmental impacts were assessed. This

also ensured that Section 2(3) of NEMA was adhered to. Section 2(4) of NEMA was further taken into

consideration to ensure that ecosystems and loss of biological diversity are avoided, or, where they cannot be

altogether avoided, are minimised and remedied.

The construction of the illegal pipeline has impacted upon indigenous vegetation although the site has

previously been transformed due to agricultural activities. Reshaping of the eroded river banks and

rehabilitating them with appropriate indigenous vegetation is recommended to mitigate the effects of the illegal

pipeline construction and to reduce any further erosion and damage. This will be enforced according to the

attached EMP and RMMP.

It is not foreseen that any National or Cultural heritage resources were disturbed by the construction or will be

disturbed by the proposed replacement pipeline. Heritage Western Cape have issued a positive Record of

Decision, to permit the proposed construction on the 30th of May 2016, whereby no cultural or heritage

resources is believed to be impacted upon.



The preferred replacement and alternative route for a new 160 mm pipeline is said to have minimal impacts on

the environment and is thus considered to be the best practicable environmental option. A positive Record of

Decision, to permit the proposed construction of the new pipeline was granted from HWC on the 30th of May

2016, whereby no cultural or heritage resources is believed to be impacted upon.

15. What are/were the benefits to society in general and to the local communities? Please explain

The cumulative positive impacts were the short and long term job opportunities that were created by the

construction and the subsequent operation of the farming activities that would have been established as a

result of the construction of the pipeline. This pipeline will allow Mr. Doms to further expand on the agricultural

activities on his farm, potentially leading to additional job creation and financial injection in the local

community. At current the farm provides employment to 40 permanent and 200 seasonal employees, all of

which are previously disadvantaged individuals.

16. Any other need and desirability considerations related to the activity? Please explain

N/A


S24GEIAR/07/2012 29

18. Please describe how the principles of environmental management as set out in section 2 of NEMA were taken into

account:

The EIA process identified all possible impacts. These impacts were evaluated to determine the actual impact

on the environment. The triple bottom approach was taken whereby socio, economic and environmental

impacts were assessed. This ensured that Section 2(3) of NEMA was adhered to.

Section 2(4) of NEMA was further taken into consideration to ensure that ecosystems and loss of biological

diversity are avoided, or, where they cannot be avoided, are minimised and remedied. This is to ensure that

development is socially, environmentally and economically sustainable.

This 24G Environmental Impact Assessment Report will be conducted in such a way as to ensure that further

degradation of the environment is avoided by enforcing the attached EMP and RMMP. Rehabilitation as a

mitigation measure is recommended to restore the riverine vegetation into a once again ecologically stable

and suitable state.

It is not foreseen that any National or Cultural heritage resources were disturbed by the construction or will be

disturbed by the proposed replacement pipeline. Cultural and heritage resource impacts were assessed and

deemed to be insignificant by Heritage Western Cape, whereby they issued a positive Record of Decision, to

permit the proposed construction on the 30th of May 2016.



1. SOCIO-ECONOMIC CONTEXT

1.1 SOCIO-ECONOMIC CONTEXT (PRE-COMMENCEMENT) Describe the pre-commencement social and economic characteristics of the community in order to provide baseline

information.




offered to Mr. Doms, however this volume would not meet his future water requirement needs. A servitude was

then purchased from Mr. Busch for a 160 mm pipeline leading from the dam in close proximity to the existing

110 mm pipeline. The roughly 1.6 km 160 mm pipeline was subsequently illegally constructed in November

2013. This pipeline crossed the river in two places where it was suspended on wooden supports anchored by

concrete foundations. During an unexpected flooding event in January 2014 the Doring River flooded its banks

and the 160 mm pipeline was severely damaged and some sections of the original existing 110 mm pipeline

was also damaged. This flood also modified the river channel by establishing a new river course, along the

alignment of the unauthorised pipeline and eroded the bank into the first row of an adjacent vineyard. There

was however no damage to the pipeline between the dam and where it meets the river (the northern section).

The Department of Environmental Affairs and Development Planning was notified and a pre-compliance notice

was issued to Mr. Doms in February 2016.

Saratoga farm is a fully functioning farm specializing in growing blueberries and provides employment for 40

permanent and 200 seasonal staff, all of which are previously disadvantaged individuals. The pipeline was

initially installed to provide water to a portion of these Blueberry orchards on the farm. Due to the increased

demand for speciality fruit such as blueberries, a need has arisen for more growing facilities, where the

industry shows tremendous growth of about 30% per annum in South Africa. The climatic conditions within the

area are also optimally suited towards the growing of Blueberries, resulting in good yields. The farming of

berries has a very high labour requirement due to the fact that the berries can only be picked by hand and

cannot be picked by machine. This therefore provides large employment opportunities to previously

disadvantaged individuals. This pipeline will allow Mr. Doms to further expand on the agricultural activities on

his farm, potentially leading to additional job creation and financial injection in the local community.


S24GEIAR/07/2012 30

1.2 SOCIO-ECONOMIC CONTEXT (POST-COMMENCEMENT) Describe the post commencement social and economic characteristics of the community in order to determine any change.

Where differences between pre- and post-commencement exist, state which are as a result of the activity(ies) for which

rectification is being applied for.

The 160mm water pipeline was constructed alongside an existing 110 mm pipeline in November 2013, it

was not in service for long before it was severely damaged in a flood event in January 2014. The benefits to

the agricultural fields that it fed would therefore not have been immediately apparent. This newly proposed

replacement pipeline will however facilitate the expansion the farm and result in an increased production

yield that would lead to local economic growth. This increase in production and economic growth will also

lead to an increase in job creation. Saratoga farm is a fully functioning farm specializing in growing

blueberries and provides employment for 40 permanent and 200 seasonal staff, all of which are previously

disadvantaged individuals. This pipeline could support further future expansion of the agricultural activities

on Saratoga farm, potentially leading to additional job creation and financial injection in the local community.

The construction costs of such a pipeline can be significant and would have led to a short term economic

boost in the local economy.

2. HISTORICAL AND CULTURAL ASPECTS

(a) Please be advised that if section 38 of the National Heritage Resources Act, 1999 (Act No. 25 of 1999), is applicable to your

development, then you are requested to furnish this Department with written comment from Heritage Western Cape as part

of your public participation process. Section 38 of the Act states as follows: “38. (1) Subject to the provisions of subsections

(7), (8) and (9), any person who intends to undertake a development categorised as-

(a) the construction of a road, wall, power line, pipeline, canal or other similar form of linear development or barrier

exceeding 300m in length;

(b) the construction of a bridge or similar structure exceeding 50m in length;

I any development or other activity which will change the character of a site-

(i) exceeding 5 000 m2 in extent; or

(ii) involving three or more existing erven or subdivisions thereof; or

(iii) involving three or more erven or divisions thereof which have been consolidated within the past five years; or

(iv) the costs of which will exceed a sum set in terms of regulations by SAHRA or a provincial heritage resources

authority;

(d) the re-zoning of a site exceeding 10 000 m2 in extent; or

(e) any other category of development provided for in regulations by SAHRA or a provincial heritage resources

authority,

must at the very earliest stages of initiating such a development, notify the responsible heritage resources authority and

furnish it with details regarding the location, nature and extent of the proposed development.”

(b) The impact on any national estate referred to in section 3(2), excluding the national estate contemplated in section

3(2)(i)(vi) and (vii), of the National Heritage Resources Act, 1999 (Act No. 25 of 1999), must also be investigated, assessed

and evaluated. Section 3(2) states as follows: “3(2) Without limiting the generality of subsection (1), the national estate may

include—

(a) places, buildings, structures and equipment of cultural significance;

(b) places to which oral traditions are attached or which are associated with living heritage;

(c) historical settlements and townscapes;

(d) landscapes and natural features of cultural significance;

(e) geological sites of scientific or cultural importance;

(f) archaeological and palaeontological sites;

(g) graves and burial grounds, including—

(i) ancestral graves;

(ii) royal graves and graves of traditional leaders;

(iii) graves of victims of conflict;

(iv) graves of individuals designated by the Minister by notice in the Gazette;

(v) historical graves and cemeteries; and

(vi) other human remains which are not covered in terms of the Human Tissue Act, 1983 (Act No. 65 of 1983);

(h) sites of significance relating to the history of slavery in South Africa;

(i) movable objects, including—

(i) objects recovered from the soil or waters of South Africa, including archaeological and palaeontological objects

and material, meteorites and rare geological specimens;

(ii) objects to which oral traditions are attached or which are associated with living heritage;

(iii) ethnographic art and objects;

(iv) military objects;

(v) objects of decorative or fine art;

(vi) objects of scientific or technological interest; and


S24GEIAR/07/2012 31

(vii) books, records, documents, photographic positives and negatives, graphic, film or video material or sound

recordings, excluding those that are public records as defined in section 1(xiv) of the National Archives of South Africa

Act, 1996 (Act No. 43 of 1996).”

Is section 38 of the National Heritage Resources Act, 1999, applicable to the development? YES NO

UNCERTAIN

If YES, explain:

The illegal construction of a 160 mm pipeline exceeds 300 m in length (is approximately

1300m). A Notice of Intent to Develop (NID) has been submitted to Heritage Western Cape

(HWC).

Heritage Western Cape have issued a positive Record of Decision, to permit the proposed

construction on the 30th of May 2016, whereby no cultural or heritage resources is believed

to be impacted upon. If any heritage resources, including archaeological material,

palaeontological material, graves or human remains are encountered, work must cease

immediately and must be reported to HWC.

Did/does the development impact on any national estate referred to in section 3(2) of the

National Heritage Resources Act, 1999?

YES NO

UNCERTAIN

If YES, explain:

Was any building or structure older than 60 years affected in any way? YES NO UNCERTAIN

If YES, explain:

Please Note: If uncertain, the Department may request that specialist input be provided.


S24GEIAR/07/2012 32

SECTION E: ALTERNATIVES

Please Note: Before completing this section, first consult this Department’s Guideline on Alternatives (October 2011) available on

the Department’s website (http://www.capegateway.gov.za/eadp).

“Alternatives”, in relation to a activity, means different means of meeting the general purposes and requirements of the activity,

which may include alternatives to –

(a) the property on which, or location where, it is to undertake the activity/the activity was undertaken;

(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.

The NEMA prescribes that the procedures for the investigation, assessment and communication of the (potential) consequences

or impacts of activities on the environment must, inter alia, with respect to every application for environmental authorisation –

ensure that the general objectives of integrated environmental management laid down in NEMA and the National

Environmental Management Principles set out in NEMA are taken into account; and

include an investigation of the potential consequences or impacts of the alternatives to the activity on the environment

and assessment of the significance of those potential consequences or impacts, including the option of not implementing

the activity.

The general objective of integrated environmental management is, inter alia, to “identify, predict and evaluate the actual and

potential impact on the environment, socio-economic conditions and cultural heritage, the risks and consequences and

alternatives and options for mitigation of activities, with a view to minimising negative impacts, maximising benefits, and

promoting compliance with the principles of environmental management” set out in NEMA.

1. In the sections below, please provide a description of any considered alternatives and alternatives that were found to be

feasible and reasonable.

Please note:

Detailed written proof of the investigation of alternatives must be provided and motivation if no reasonable or feasible

alternatives exist.

Alternatives considered for a Section 24G application are used to determine if the development was the best practicable

alternative (environmenally, socially, economically) for the property.

(a) Property and location/site alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise

positive impacts, or detailed motivation if no reasonable or feasible alternatives exist:

Mr. Marc Doms of Saratoga Farm purchased the farm Klaas Voogds Rivier (portion 4 of farm 40) from owner

Mr. Pat Busch. A 30% share in water use rights to the existing dam situated on Mr. Busch’s farm (portion 14 of

farm 40) and a servitude for a 160 mm pipeline leading from the dam in close proximity to the existing PVC

110 mm pipeline was also purchased. A 160 mm PVC pipeline was subsequently illegally installed in

November 2013 (triggering EIA Regulations) and was severely damaged by a flood in January 2014.

Saratoga farm is a fully functioning farm specializing in the growing of blueberries and provides employment

for 40 permanent and 200 seasonal staff, all of which are previously disadvantaged individuals. The illegally

constructed pipeline was initially installed to provide water to a portion of these Blueberry orchards on the

farm. Due to the increased demand for speciality fruit such as blueberries, a need has arisen for more growing

facilities, where the industry shows tremendous growth of about 30% per annum in South Africa. The climatic

conditions within the area are also optimally suited towards the growing of Blueberries, resulting in good

yields. The farming of berries has a very high labour requirement due to the fact that the berries can only be

picked by hand and cannot be picked by machine. This therefore provides large employment opportunities to

previously disadvantaged individuals. It is the opinion of both GNEC and Mr. Karl Reinecke (Southers Waters

Ecological Research and Consulting cc) that the route where the pipeline was initially installed was not a

viable option as possible future flooding could result in the same detrimental outcome, and this route should

never have been deemed a viable option in terms of environmental impact. A replacement pipeline route is

therefore required to provide water to these agricultural fields, which will have a positive socio-economic

impact and not result in further negative impacts on the physical environment.



S24GEIAR/07/2012 33

A preferred and an alternative new PVC pipeline route (± 0.9 km in length) has been proposed to replace the

damaged pipeline and to supply water to the agricultural fields (see map in Addendum B). Both these newly

proposed pipeline route will attach to the existing 160 mm pipeline well above where the flood damage to the

pipeline occurred (more than 32 m from the river), proposed to be connected approximately 200m from the

dam. Both the preferred and alternative pipeline routes will follow the same route and be placed underneath a

planted pasture field towards the farm homestead. The preferred replacement route will continue through the

farm homestead underneath a gravel/dirt road towards the connecting point on Saratoga farm. The alternative

replacement route will bypass around the homestead, adjacent to indigenous vegetation and a vineyard. The

alternative route will merely bypass the homestead and then again join onto the same dirt/gravel road as the

preferred route where both routes will run towards the connecting point on Saratoga underneath the gravel/dirt

road. Both these potential replacement routes will have minimal environmental, geographical and/or no

impacts on any heritage resources of the farm, however it is foreseen that the preferred route will have less

environmental impacts. Both these routes will not be visually impairing as the pipeline will be placed

underground. Both these proposed replacement pipeline routes are expected not to trigger any EIA regulations

as they will be an estimated 900 m long and will be placed more than 32 m from a watercourse. No rivers or

wetlands were identified along these newly proposed routes.

A small portion (± 50 m) of the proposed preferred and alternative replacement pipeline route is mapped as

the Breede Alluvium Renosterveld threatened ecosystem. However, the botanical assessment also

indicated this vegetation type no longer occurs here due to the current presence of a planted pasture field and

a farm homestead. Reshaping, rehabilitation with appropriate indigenous vegetation and the installation of

erosion protection structures on the river banks are also recommended once environmental authorization has

been granted. No rivers or wetlands were identified along these newly proposed routes.

(b) Activity alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive impacts, or

detailed motivation if no reasonable or feasible alternatives exist:

The construction activity for the preferred and the alternative replacement pipeline route will be the same as

the original illegal activity (to construct a pipeline to transfer water), however both these proposed replacement

pipeline routes are expected not to trigger any EIA regulations as they will be an estimated 900 m long and will

be placed more than 32 m from a watercourse. No rivers or wetlands were identified along these newly

proposed routes. A small portion (± 50 m) of the proposed preferred and alternative replacement pipeline route

is mapped as the Breede Alluvium Renosterveld threatened ecosystem. However, the botanical assessment

also indicated this vegetation type no longer occurs here due to the current presence of a planted pasture field

and a farm homestead. Reshaping, rehabilitation with appropriate indigenous vegetation and the installation of


been granted.

(c) Design or layout alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive

impacts, or detailed motivation if no reasonable or feasible alternatives exist:

The construction activity for the preferred and the alternative replacement pipeline route will have an altered

design/layout. This is because both GNEC and Mr. Karl Reinecke (Southers Waters Ecological Research and

Consulting cc) propose that the route where the pipeline was initially installed was not a viable option as

possible future flooding could result in the same detrimental outcome, and this route should never have been

deemed a viable option in terms of environmental impact. A replacement pipeline route is therefore required to

provide water to these agricultural fields, which will have a positive socio-economic impact and not result in

further negative impacts on the physical environment.




pipeline occurred (more than 32 m from the river). Both the preferred and alternative pipeline routes will follow


S24GEIAR/07/2012 34

the same route and be placed underneath a planted pasture field towards the farm homestead. The preferred

replacement route will continue through the farm homestead underneath a gravel/dirt road towards the

connecting point on Saratoga farm. The alternative replacement route will bypass around the homestead,

adjacent to indigenous vegetation and a vineyard. The alternative route will merely bypass the homestead and

then again join onto the same dirt/gravel road as the preferred route where both routes will run towards the

connecting point on Saratoga underneath the gravel/dirt road. Both these potential replacement routes will

have minimal environmental, geographical and/or no impacts on any heritage resources of the farm, however

it is foreseen that the preferred route will have less environmental impacts. They are also not expected to


watercourse. Both these routes will not be visually impairing as the pipeline will be placed underground. No

rivers or wetlands were identified along these newly proposed routes.






been granted. No rivers or wetlands were identified along these newly proposed routes.

(d) Technology alternatives (e.g. to reduce resource demand and resource use efficiency) to avoid negative impacts, mitigate

unavoidable negative impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives

exist:

The EAP is not aware of any alternatives that were considered feasible prior to undertaking the said activities.

(e) Operational alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive impacts,

or detailed motivation if no reasonable or feasible alternatives exist:


(f) The option of ceasing the activity (the refusal of the activity(ies) and/or rehabilitation of the site):


Mr. Pat Busch. A 30% share in water use rights to the existing dam situated on Mr. Busch’s farm (portion 14 of

farm 40) and a servitude for a 160 mm pipeline leading from the dam in close proximity to the existing PVC

110 mm pipeline was also purchased. A 160 mm PVC pipeline was subsequently illegally installed in

November 2013 (triggering EIA Regulations) and was severely damaged by a flood in January 2014.

Saratoga farm is a fully functioning farm specializing in the growing of blueberries and provides employment

for 40 permanent and 200 seasonal staff, all of which are previously disadvantaged individuals. The illegally

constructed pipeline was initially installed to provide water to a portion of these Blueberry orchards on the

farm. Due to the increased demand for speciality fruit such as blueberries, a need has arisen for more growing

facilities, where the industry shows tremendous growth of about 30% per annum in South Africa. The climatic

conditions within the area are also optimally suited towards the growing of Blueberries, resulting in good

yields. The farming of berries has a very high labour requirement due to the fact that the berries can only be

picked by hand and cannot be picked by machine. This therefore provides large employment opportunities to

previously disadvantaged individuals. It is the opinion of the EAP that the refusal to replace the pipeline with a

suitable alternative route is not the outcome, as the pipeline will ultimately provide water to agricultural land

that will in turn create job opportunities. Both these potential replacement routes will have minimal

environmental, geographical and/or no impacts on any heritage resources of the farm, however it is foreseen

that the preferred route will have less environmental impacts. They are also not expected to trigger any EIA

regulations as they will be an estimated 900 m long and will be placed more than 32 m from a watercourse.

Both these routes will not be visually impairing as the pipeline will be placed underground.


S24GEIAR/07/2012 35

(g) Other alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive impacts, or

detailed motivation if no reasonable or feasible alternatives exist:


(h) Please provide a summary of the alternatives investigated and the outcomes of such investigation:

Please note: If no feasible and reasonable alternatives exist, the description and proof of the investigation of alternatives,

together with motivation of why no feasible or reasonable alternatives exist, must be provided.




pipeline occurred (more than 32 m from the river). Both the preferred and alternative pipeline routes will follow

the same route and be placed underneath a planted pasture field towards the farm homestead. The preferred

replacement route will continue through the farm homestead underneath a gravel/dirt road towards the

connecting point on Saratoga farm. The alternative replacement route will bypass around the homestead,

adjacent to indigenous vegetation and a vineyard. The alternative route will merely bypass the homestead and

then again join onto the same dirt/gravel road as the preferred route where both routes will run towards the

connecting point on Saratoga underneath the gravel/dirt road. Both these potential replacement routes will

have minimal environmental, geographical and/or no impacts on any heritage resources of the farm, however

it is foreseen that the preferred route will have less environmental impacts. Both these routes will not be

visually impairing as the pipeline will be placed underground. Both these proposed replacement pipeline routes

are expected not to trigger any EIA regulations as they will be 900 m long and will be placed more than 32 m

from a watercourse. No rivers or wetlands were identified along these newly proposed routes.


S24GEIAR/07/2012 36

SECTION F: PRELIMINARY IMPACT ASSESSMENT, MANAGEMENT,

MITIGATION AND MONITORING MEASURES

Please note, the impacts identified below refer to general impacts commonly associated with

development activities. The list below is not exhaustive and may need to be supplemented. Where

required, please append the information on any additional impacts to this application.

Please note: The information in this section must be duplicated for all the feasible and reasonable alternatives (where relevant).

1. PLEASE DESCRIBE THE MANNER IN WHICH THE DEVELOPMENT HAS IMPACTED ON THE

FOLLOWING ASPECTS:

(a) Geographical and physical aspects:


Mr. Pat Busch. An existing 110 mm water pipeline was offered to Mr. Doms, however this volume would not

meet his future water requirement needs. A 30% share in water use rights to the existing dam situated on Mr.

Busch’s farm (portion 14 of farm 40) and a servitude for a 160 mm pipeline leading from the dam in close

proximity to the existing PVC 110 mm pipeline was also purchased. A 160 mm PVC pipeline was subsequently

illegally installed in November 2013, within 32 meters from a watercourse (the Doring River) without

environmental authorization. This pipeline crossed the river in two places where it was suspended on wooden

supports anchored by concrete foundations. During an unexpected flooding event in January 2014 the Doring

River flooded its banks and the 160 mm pipeline was severely damaged and some sections of the original

existing 110 mm pipeline was also damaged. This flood also modified the river channel by establishing a new

river course, along the alignment of the unauthorised pipeline and eroded the bank into the first row of an

adjacent vineyard, changing the geographical and physical aspects of the property. There was however no

damage to the pipeline or the physical aspect of the property between the dam and where it meets the river

(the northern section).

As a method of restoring the damaged pipeline we propose a preferred and an alternative new pipeline route

(± 0.9 km in length) to replace the damaged pipeline and to supply water to Mr. Doms agricultural fields. These

replacement routes have been selected as they will provide a positive socio-economic impact and not result in

further negative impacts on the physical environment. Reshaping of the eroded river banks, rehabilitation with

appropriate indigenous vegetation and the installation of erosion protection structures on the river banks are

recommended to mitigate the effects of the illegal pipeline and to reduce any further erosion and damage. This

will be enforced according to the attached EMP and RMMP. No rivers or wetlands were identified along these

newly proposed routes.

(b) Biological aspects:

Has the development impacted on critical biodiversity areas (CBAs) or ecological support areas (CSAs)? YES NO

If yes, please describe:

A portion of the site falls within an Ecological Support Area (ESA) as the pipeline was constructed in close

proximity to the Doring River. There is no true Breede Shale Renosterveld vegetation present on site. No

threatened plant species or species of conservation concern were found on the site. The absence of this

vegetation type was confirmed by a botanical specialist. The present ecological state (PES) (assessed by FCG

on 12 May 2016, 2 years after the pipeline construction) of the Doring River was rated by FCG to be

marginally better than the pre-impact state in terms of the instream component of the river (PES Class C/D –

“moderately to largely modified”), although marginally worse in terms of the riparian component (PES Class D

– “largely modified”).


S24GEIAR/07/2012 37

The overall significance of the impacts of the pipeline constructing was rated by FCG to be low-to-medium

without rectification and would become low with rectification. The negative impacts associated with the flood-

related modifications to the river must, however, be weighed up against the positive impact of the improvement

of the instream habitat within the new channel.






been granted. No rivers or wetlands were identified along these newly proposed routes. This will be enforced

according to the attached EMP and RMMP.

Has the development impacted on terrestrial vegetation, or aquatic ecosystems (wetlands, estuaries or the

coastline)? YES NO


It may be possible that the construction of the pipeline impacted on the FRs8 Breede Shale Renosterveld

vegetation type as this is the dominant vegetation type that occurred where the pipeline was installed. Large

majority of this pipeline was however installed underground on land that has previously been transformed due

to agricultural (planted pasture field, gravel/dirt road and along the edge of a vineyard). There is however no

true Breede Shale Renosterveld vegetation present on site. No threatened plant species or species of

conservation concern were found on the site. The absence of this vegetation type was confirmed by a

botanical specialist, Dr Dave McDonald. This botanical assessment also noted that the vegetation on the

banks of the Doring River around the site has been strongly influenced by invasive species and this is a

contributing factor to the instability of the soils and played a role in the flood damage as a result. Where not

invaded by alien species Acacia thicket (Vachellia karoo) typical of riparian thicket (azonal vegetation) is

present in the river valley on the south of the Langeberg. This vegetation is not threatened.




anchored by concrete foundations. This watercourse serves as a habitat for various terrestrial and aquatic

flora and fauna that can be deemed a natural resource. A freshwater ecological assessment was also

conducted to determine the impact of the pipeline on the aquatic diversity of the Doring River by the Dean Ollis

of the Freshwater Consulting Group (FCG). The present state (assessed by FCG on 12 May 2016, 2 years

after the pipeline construction) of the Doring River was rated to be marginally better than the pre-impact state

in terms of the instream component of the river (PES Class C/D – “moderately to largely modified”), although

marginally worse in terms of the riparian component (PES Class D – “largely modified”). This improvement in

the state of the instream component of the river after the January 2014 flood is because the river established a

new flow-path, along the line where the unauthorised water pipeline had been placed from where it crossed

the river. This new river course bypassed the section of the river channel that was clearly an original diversion

due to agricultural activities in the valley according to the FCG. This new river course and river bed currently

has a more natural substrate of cobbles compared to the narrow densely vegetated old bypass route (which

adjoined the Doring River at nearly a 90 degree angle), further improving the new river course’s instream

component. The reason for the slightly poorer ecological condition of the riparian zone after the construction of

the pipeline and subsequently the January 2014 flood was due to an increase in the degree of channel

modification and, especially, increased bank erosion. The erosion that occurred on the Doring River bank,

particularly where the pipeline crossed the river, is considered to be significantly greater than the natural levels

of erosion that would have been observed during naturally occurring flood events. This erosion will however be

rectifiable with appropriate bank reshaping and rehabilitation.


S24GEIAR/07/2012 38

The Ecological Importance and Sensitivity (EIS) of Doring River was also assessed by FCG and indicated that

the overall EIS rating of this system is of low-to-moderate importance and sensitivity.













Has the development impacted on any populations of threatened plant or animal species, and/or on any

habitat that may contain a unique signature of plant or animal species? YES NO


The construction of the illegal pipeline would have possibly impacted the FRs8 Breede Shale Renosterveld

vegetation type that historically occurs in the area and which consists of the following endemic taxa:

Low shrubs: Aspathalus macrocarpa, Cliffortia varians,Lotononis rigida.

Succulent shrubs: Acrodon purpureostylus, Drosanthemum aureopurpureum, D. hallii, Lampranthus hurlingii.

Geophytic herb: Babiana villosa, Freesia fuctata, Ixia vanzijliae, I. vinacea, Moraea incurve, M. radians.

However please note that the site where the 160mm pipeline was constructed is located in an already

transformed agricultural area, and in a large part is laid parallel to an existing 110mm pipeline. Previous land

use has already transformed the property though agricultural practices. No threatened plant species or species

of conservation concern were found on the site. The absence of this vegetation type was confirmed by a

botanical specialist, Dr Dave McDonald. This botanical assessment also noted that the vegetation on the

banks of the Doring River around the site has been strongly influenced by invasive species and this is a

contributing factor to the instability of the soils and played a role in the flood damage as a result. Where not


present in the river valley on the south of the Langeberg. This vegetation is not threatened.






been granted. No rivers or wetlands were identified along these newly proposed routes. This will be enforced

according to the attached EMP and RMMP.

Please describe the manner in which any other biological aspects were impacted:

A vineyard and a planted pasture (perennial) field’s vegetation was also damaged by the river eroding and

changing its course.

(c) Socio-Economic aspects:

What was the capital value of the activity on completion? R

What is the (expected) yearly income or contribution to the economy that is/will be generated by or as a

result of the activity?

R

Has/will the activity contributed to service infrastructure? YES NO

How many new employment opportunities were/will be created in the construction phase of the activity?


S24GEIAR/07/2012 39

What was the value of the employment opportunities during the construction phase? R

What percentage of this accrued to previously disadvantaged individuals? %

How was this ensured and monitored (please explain):

Not Known at this stage

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

of the activity?

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

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

How was/will this be ensured and monitored (please explain):

Not Known at this stage

Any other information related to the manner in which the socio-economic aspects was/will be impacted:

This newly proposed replacement pipeline will however facilitate the expansion the farm and result in an

increased production yield that would lead to local economic growth. This increase in production and

economic growth will also lead to an increase in job creation. Saratoga farm is a fully functioning farm

specializing in growing blueberries and provides employment for 40 permanent and 200 seasonal staff, all of

which are previously disadvantaged individuals. This pipeline could support further future expansion of the

agricultural activities on Saratoga farm, potentially leading to additional job creation and financial injection in

the local community. The construction costs of such a pipeline can be significant and would have led to a short

term economic boost in the local economy.

(d) Cultural and historic aspects:

The illegal construction of a 160mm pipeline on Portion 14 of Farm 40 is situated in an area historically

dominated by agricultural land use. It is therefore highly unlikely that the construction of this illegal pipeline

would have unearthed any archaeological sites of importance being predominantly on agricultural land. The

potential impact to the surrounding environment and any heritage recourses is deemed to be minimal in nature

for the newly proposed preferred and alternative replacement pipeline route as this new pipeline will be buried

underground in a pasture field and underneath an existing gravel/dirt road. It will therefore not be visually

impairing to negatively affect the aesthetic aspect of the surrounding environment. A notice of intent to develop

has been submitted to Heritage Western Cape, and they have issued a positive Record of Decision, to permit

the proposed construction on the 30th of May 2016. If any heritage resources, including archaeological

material, palaeontological material, graves or human remains are encountered, work must cease immediately

and must be reported to HWC.

2. WASTE AND EMISSIONS

(a) Waste (including effluent) management

Did the activity produce waste (including rubble) during the construction phase? YES NO

If yes, indicate the types of waste (actual type of waste, e.g. oil, and whether hazardous or not) and

estimated quantity per type? M3

Does the activity produce waste during its operational phase? YES NO

If yes, indicate the types of waste (actual type of waste, e.g. oil, and whether hazardous or not) and

estimated quantity per type? M3


S24GEIAR/07/2012 40

Where and how was/will the waste be treated / disposed of (describe)?

During an unexpected flooding event in January 2014 the Doring River flooded its banks and the newly

constructed 160mm pipeline was severely damaged. Parts of the pipeline were broken and some segments

remain within the watercourse and/or are entangled within the riverine vegetation. These damaged pipes are

still currently within the watercourse and will be removed and disposed of at the nearest licenced landfill site

once authorization is given to remove them. This is because the pre-compliance notice that was issued to Mr.

Doms instructed all listed activates to cease immediately.

Has the municipality or relevant authority confirmed that sufficient capacity exist for treating / disposing of

the waste (to be) generated by this activity(ies)? If yes, provide written confirmation from Municipality or

relevant authority.

The solid PVC waste from the damaged pipeline will be disposed of at the nearest licenced

landfill site once environmental authorization is given. The quantity of damaged pipe is not

known by the EAP, although is considered not to be a significant amount. Sufficient capacity

at the municipal landfill should be available.

YES NO

Does/will the activity produce waste that is/will be treated and/or disposed of at another facility other than

into a municipal waste stream? YES NO

If yes, has this facility confirmed that sufficient capacity exist for treating / disposing of the waste (to be)

generated by this activity(ies)? Provide written confirmation from the facility and provide the following

particulars of the facility:

YES NO

Does the facility have an operating license? (If yes, please attach a copy of the license.) YES NO

Facility name:

Contact person:

Postal address:

Postal code:

Telephone: Cell:

E-mail: Fax:

Describe the measures that were/will be taken to reduce, reuse or recycle waste:

(b) Emissions into the atmosphere

Does/will the activity produce emissions that will be disposed of into the atmosphere? YES NO

If yes, does it require approval in terms of relevant legislation? YES NO

Describe the emissions in terms of type and concentration and how it is/will be treated/mitigated:

3. WATER USE

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

Municipal Water board Groundwater River, Stream,

Dam or Lake Other

The activity did/does/will not use

water

If water was extracted from a groundwater source, river, stream, dam, lake or any other natural feature, please indicate

the volume that was extracted per month: 12500 m3




offered to Mr. Doms, however this volume would not meet his future water requirement needs. A servitude was

then purchased from Mr. Busch for a 160 mm pipeline leading from the dam in close proximity to the existing

110 mm pipeline. The roughly 1.6 km 160 mm pipeline was subsequently illegally constructed in November

2013. See Addendum D for recent water bill from the Klaasvoogds Water Users Association.

Please provide proof of assurance of water supply (eg. Letter of confirmation from municipality / water user associations, yield


S24GEIAR/07/2012 41

of borehole)

Did/does the activity require a water use permit / license from DWA? YES NO

If yes, please submit a certified copy of the water use permit/license or submit the necessary application to Department of

Water Affairs and attach proof thereof to this application, whichever is applicable.

See Addendum D for recent water bill from the Klaasvoogds Water Users Association. Guillaume Nel

Environmental Consultants will submit an application to confirm the applicability of General

Authorisation GN 1199 or a Water Use License Application to the Breede-Gouritz Catchment

Management Agency (BGCMA) (see Addendum D).

Describe the measures that were/ will be taken to reduce water demand, and measures to reuse or recycle water:

Guidelines and measures taken with respect to water efficiency is not yet known to the EAP.

4. POWER SUPPLY

Please indicate the source of power supply eg. Municipality / Eskom / Renewable energy source

The water pipeline is gravity fed and therefore does not require electricity. A portable generator will be used for

the construction of a new replacement pipeline, if authorization is granted. The electricity on the farm is

however supplied by Eskom. See Addendum D for recent electricity bill from the Langeberg Municipality.

If power supply is not available, where will power be sourced from?

A portable generator will be used for the construction of a new replacement pipeline, if authorization is

granted. The use thereof must be enforced according to the attached EMP.

5. ENERGY EFFICIENCY

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

Guidelines and measures taken with respect to energy efficiency is not known to the EAP.

Describe how alternative energy sources have been taken into account or been built into the design of the activity, if any:

Guidelines and measures taken with respect to alternative energy sources is not known to the EAP.

6. DESCRIPTION AND ASSESSMENT OF THE SIGNIFICANCE OF IMPACTS PRIOR TO AND AFTER

MITIGATION

Please note:

While sections are provided for impacts on certain aspects of the environment and certain impacts,

the sections should also be copied and completed for all other impacts.

Mitigation measures that were implemented and mitigation measures that are to be implemented should be clearly

distinguished.

(a) Impacts that resulted from the planning, design and construction phases (briefly describe and compare the impacts (as

appropriate), significance rating of impacts, proposed mitigation and significance rating of impacts after mitigation that

occurred as a result of the planning, design and construction phases.

Impacts on geographical and physical aspects:

Nature of impact: Localized bank erosion where the pipeline crossed the Doring River


S24GEIAR/07/2012 42

Extent and duration of impact: Local Long Term

Probability of occurrence: Definite

Degree to which the impact can be reversed: Medium Degree to which the impact may cause irreplaceable

loss of resources: Improbable

Cumulative impact prior to mitigation: Low – Medium Significance rating of impact prior to mitigation

(Low, Medium, Medium-High, High, or Very-High) Low – Medium

Degree to which the impact can be mitigated: High

Proposed mitigation:

Reshaping, rehabilitation with appropriate indigenous vegetation and the installation of erosion protection structures on the river banks are recommended to mitigate the effects of the illegal pipeline construction and to reduce any further erosion. Hydroseeding with appropriate endemic riparian vegetation is also recommended.

Cumulative impact post mitigation: Very Low Significance rating of impact after mitigation

(Low, Medium, Medium-High, High, or Very-High) Very Low

Impacts on geographical and physical aspects:

Nature of impact: Channel modification and establishment of a new river course

Extent and duration of impact: Local Long Term


Degree to which the impact can be reversed: High Degree to which the impact may cause irreplaceable


Cumulative impact prior to mitigation: Low positive Significance rating of impact prior to mitigation

(Low, Medium, Medium-High, High, or Very-High) Low



No rectification required for positive impacts. Reshaping of the eroded banks and rehabilitation with appropriate indigenous vegetation are recommended to. Hydroseeding with appropriate endemic riparian vegetation is also recommended.

Cumulative impact post mitigation: Low Significance rating of impact after mitigation


Impact on biological aspects:

Nature of impact: Impacts on biological aspects

Extent and duration of impact: Regional Long Term

Probability of occurrence: Likely



Cumulative impact prior to mitigation: Low Significance rating of impact prior to mitigation


Degree to which the impact can be mitigated: Medium - High


All activities on site must comply with:

The regulations of the Animal Protection Act, 1962 (Act No. 71 of 1962); and Marine Living Resources Act, 1998 (Act No. 18 of 1998). All workers must be informed that the intentional killing of any animal is not permitted as faunal species are a benefit to society. Poaching is illegal and it must be a condition of employment that any employee caught poaching will be dismissed. Employees must be trained on how to deal with fauna species as intentional killing will not be tolerated. In the case of a problem animal e.g. a large snake a specialist must be called in to safely relocate the animal if the EO or ECO is not able to.


S24GEIAR/07/2012 43

Reshaping, rehabilitation with appropriate indigenous vegetation and the installation of erosion protection structures on the river banks are recommended.



Impacts on socio-economic aspects:

Nature of impact: Provision of Temporary Jobs

Extent and duration of impact: Site Short Term - construction


Degree to which the impact can be reversed: N/A Degree to which the impact may cause irreplaceable

loss of resources: N/A

Cumulative impact prior to mitigation: Low Positive Significance rating of impact prior to mitigation

(Low, Medium, Medium-High, High, or Very-High) Low Positive

Degree to which the impact can be mitigated: N/A, do not want to mitigate positive impacts.

Proposed mitigation: N/A, do not want to mitigate positive impacts.

Cumulative impact post mitigation: Low Positive Significance rating of impact after mitigation


Impacts on cultural-historical aspects:

Nature of impact: No impacts on the cultural/historical aspects are expected.

Extent and duration of impact: Site Long Term

Probability of occurrence: Improbable

Degree to which the impact can be reversed: Low Degree to which the impact may cause irreplaceable




Degree to which the impact can be mitigated: Low


Should any heritage artefacts, including archaeological material, palaeontological material, graves or human remains be encountered during demolition or construction, work in this area must cease immediately and the ECO as well as the Local Council shall be notified within 24 hours.

Upon receipt of such notification, the ECO will arrange for the excavation to be examined by an Archaeologist. Only once authorisation from Heritage Western Cape has been granted can work again commence.

Under no circumstances shall archaeological artefacts be removed, destroyed or interfered with.



Noise impacts:

Nature of impact: Construction activities of the pipeline

Extent and duration of impact: Site Short term - will be for a short time and not be excessively noisy.

Probability of occurrence: Low

Degree to which the impact can be reversed: Low - Medium Degree to which the impact may cause irreplaceable



(Low, Medium, Medium-High, High, or Very-High) Low - Medium


S24GEIAR/07/2012 44

Degree to which the impact can be mitigated: Low - Medium


Since the construction of the pipeline and subsequently the proposed replacement pipeline construction occur on an active agricultural farm it is not expected that the noise impacts during the construction phase would be significant. All construction vehicles must be in a good working order to reduce possible noise pollution. Work hours during the construction phase will be enforced unless permission was given (07H00 – 18H00). Permission should be granted without consultation with the local community. No work to be done on Sundays.



Visual impacts / Sense of Place:

Nature of impact: Construction activities of the pipeline

Extent and duration of impact: Construction - Short term


Degree to which the impact can be reversed: Low to Medium Degree to which the impact may cause irreplaceable






Since the construction of the pipeline and subsequently the proposed replacement pipeline construction occur on an active agricultural farm it is not expected that the visual impacts during the construction phase would be significant. The damaged pipelines within the riverine vegetation should be removed and disposed of at the nearest registered municipal landfill.



(b) Impacts that result from the operational phase (briefly describe and compare impacts (as appropriate), significance rating of

impacts, proposed mitigation and significance rating of impacts after mitigation that are likely to occur as a result of the

operational phase.

Impacts on the geographical and physical aspects:

Nature of impact: Impacts on the geographical and physical aspect due to infrastructure constructed

Extent and duration of impact: Site Permanent

Probability of occurrence:

Improbable – the pipeline was placed underground and so will the proposed replacement pipeline. There are no expected impacts during operation.


loss of resources: Unlikely





The pipeline was installed underground and so will the proposed replacement pipeline. Reshaping, rehabilitation with appropriate indigenous vegetation and the installation of erosion protection structures on the river banks are recommended to mitigate the effects of the illegal pipeline construction and to reduce any further erosion. Hydroseeding with appropriate endemic


S24GEIAR/07/2012 45

riparian vegetation is also recommended.



Impact on biological aspects:

Nature of impact: Transformation of natural vegetation


Probability of occurrence: Low – the pipeline will not impact any biological aspects during operation.

Degree to which the impact can be reversed: Medium - High Degree to which the impact may cause irreplaceable


Cumulative impact prior to mitigation: Medium Significance rating of impact prior to mitigation

(Low, Medium, Medium-High, High, or Very-High) Medium



Reshaping, rehabilitation with appropriate indigenous vegetation and the installation of erosion protection structures on the river banks are recommended to reduce any further erosion. Hydroseeding with appropriate endemic riparian vegetation is also recommended.

Cumulative impact post mitigation: Low - Medium Significance rating of impact after mitigation

(Low, Medium, Medium-High, High, or Very-High) Low - Medium

Impacts on the socio-economic aspects:

Nature of impact: Positive impacts - Permanent and temporary jobs during the operational phase.

Extent and duration of impact: Long term – operational phase.




Cumulative impact prior to mitigation: Low Positive Significance rating of impact prior to mitigation


Degree to which the impact can be mitigated: N/A, do not want to mitigate positive impacts.

Proposed mitigation: N/A, do not want to mitigate positive impacts.

Cumulative impact post mitigation: Low Positive Significance rating of impact after mitigation


Impacts on the cultural-historical aspects:

Nature of impact: No impacts on the cultural/historical aspects are expected during the operational phase.









Should any heritage artefacts, including archaeological material, palaeontological material, graves or human remains be encountered during the operational phase, work in this area must cease immediately and the ECO as well as the Local Council shall be notified.



Noise impacts:

Nature of impact: No noise impacts are expected during the operational phase.



S24GEIAR/07/2012 46


Degree to which the impact can be reversed: No need to mitigate as there will not be noise impacts during operation.

Degree to which the impact may cause irreplaceable





Proposed mitigation: Enforcement of acceptable working hours



Visual impacts / Sense of Place:

Nature of impact: No visual impacts are expected during the operational phase.


Probability of occurrence: Improbable – the pipeline was placed underground and so will the proposed replacement pipeline

Degree to which the impact can be reversed: No need to mitigate as there will not be visual impacts during operation.

Degree to which the impact may cause irreplaceable





Proposed mitigation: The pipeline was placed underground and so will the proposed replacement pipeline.



(c) Impacts that may result from the decommissioning and closure phase (briefly describe and compare the potential impacts

(as appropriate), significance rating of impacts, proposed mitigation and significance rating of impacts after mitigation that

are likely to occur as a result of the decommissioning and closure phase.

Potential impacts on the geographical and physical aspects:

Nature of impact: Appearance and scarring of site due to removal/decommissioning of the pipeline.


Probability of occurrence: Highly Likely – if pipeline is removed/decommissioned.


loss of resources: Low

Cumulative impact prior to mitigation: Medium – High Significance rating of impact prior to mitigation

(Low, Medium, Medium-High, High, or Very-High) Medium – High



Reshaping, rehabilitation with appropriate indigenous vegetation and the installation of erosion protection structures on the river banks are recommended to mitigate the effects of decommission to reduce any further erosion. Hydroseeding with appropriate endemic riparian vegetation is also recommended.

Cumulative impact post mitigation: Low-medium Significance rating of impact after mitigation

(Low, Medium, Medium-High, High, or Very-High) Low-medium

Potential impact on biological aspects:

Nature of impact: Impacts on biological aspects

Extent and duration of impact: Regional Long Term



loss of resources: improbable

Cumulative impact prior to mitigation: Low


S24GEIAR/07/2012 47

Significance rating of impact prior to mitigation


Degree to which the impact can be mitigated: Medium


Educate employees about environmental impacts and the potential impacts associated with the removal/decommission of the pipeline. Reshaping of the river banks and rehabilitating them with appropriate indigenous vegetation is recommended.



Potential impacts on the socio-economic aspects:

Nature of impact: Loss of Temporary and Permanent Jobs

Extent and duration of impact: Permanent




Cumulative impact prior to mitigation: High Negative Significance rating of impact prior to mitigation

(Low, Medium, Medium-High, High, or Very-High) N/A

Degree to which the impact can be mitigated: N/A

Proposed mitigation: N/A

Cumulative impact post mitigation: N/A Significance rating of impact after mitigation


Potential impacts on the cultural-historical aspects:

Nature of impact: No impacts on the cultural/historical aspects are expected.









Should any heritage artefacts, including archaeological material, palaeontological material, graves or human remains be encountered during the removal or decommissioning phase, work in this area must cease immediately and the ECO as well as the Local Council shall be notified.



Potential noise impacts:

Nature of impact: Demolition of structures

Extent and duration of impact: Short term

Probability of occurrence: High

Degree to which the impact can be reversed: Low - Medium Degree to which the impact may cause irreplaceable

loss of resources: Low



Degree to which the impact can be mitigated: Low-medium


All construction vehicles must be in a good working order to reduce possible noise pollution. Work hours during the construction phase will be enforced unless permission was given (07H00 – 18H00). Permission


S24GEIAR/07/2012 48

should be granted without consultation with the local community. No work to be done on Sundays.



Potential visual impacts:

Nature of impact: Demolition of structures

Extent and duration of impact: Short Term






Degree to which the impact can be mitigated: Low-medium


Reshaping, rehabilitation with appropriate indigenous vegetation and the installation of erosion protection structures on the river banks are recommended to mitigate the effects of decommission to reduce any further erosion. Hydroseeding with appropriate endemic riparian vegetation is also recommended.

Cumulative impact post mitigation: Low-medium Significance rating of impact after mitigation


(d) Any other impacts:

Potential impact: N/A

Nature of impact: N/A

Extent and duration of impact: N/A

Probability of occurrence: N/A

Degree to which the impact can be reversed: N/A Degree to which the impact may cause irreplaceable loss of

resources: N/A

Cumulative impact prior to mitigation: N/A Significance rating of impact prior to mitigation


Degree to which the impact can be mitigated: N/A

Proposed mitigation: N/A



Please note: If any of the above information is not available, specialist input may be requested.

7. SPECIALIST INPUTS/STUDIES AND RECOMMENDATIONS

Please note: Specialist inputs/studies that will be undertaken as part of this application. These specialist inputs/studies must

take into account the Department’s relevant Guidelines on the Involvement of Specialists in EIA Processes available on

the Department’s website (http://www.capegateway.gov.za/eadp). A summary of all the specialist inputs/studies must be

provided with the additional information / Environmental Impact Report.

Specialist inputs/studies and recommendations:



S24GEIAR/07/2012 49

The site where the illegal construction of the 160 mm pipeline was installed occurred on the Breede Shale

Renosterveld vegetation type, which is listed as vulnerable according to the National Environmental

Management: Biodiversity Act (Act 10 of 2004). The site has however largely been transformed due to

agricultural purposes. Dr Dave McDonald was appointed as the independent botanist to perform a botanical

assessment and indicated that no true Breede Shale Renosterveld vegetation was present on site. No

threatened plant species or species of conservation concern were found on the site. The riparian vegetation has

been significantly altered due to the presence of alien species such as Populus canescens (invasive cat. 2),

Salix babylonica (Weeping willow), Acacia saligna (Port Jackson Willow), Senna didymibotrya (Peanut butter

cassia), Solanum sisymbriifolium (Sticky nightshade), Arundo donax (Spanish reed) Cirsium vulgare (Spear

thistle) and Kikuyu grass (Pennistetum clandestinum) (cat. 1b). The site has been transformed due to farming

activities.


S24GEIAR/07/2012 50

This botanical assessment also noted that the vegetation on the banks of the Doring River around the site has


played a role in the flood damage as a result. A portion of the pipeline also forms part of an Ecological Support

Area (ESA) being in a river riparian zone, however no threatened plant species or species of conservation

concern were however found on the site. Where not invaded by alien species Acacia thicket (Vachellia karoo)

typical of riparian thicket (azonal vegetation) is present in the river valley on the south of the Langeberg. This

vegetation is however not threatened.

A freshwater ecological assessment was required to i) determine the impact of the pipeline on the aquatic

diversity of the Doring River, ii) assess the erosion damage, iii) to discuss potential causes thereof and iv)

propose potential rehabilitation measures. Mr Dean Ollis from the Freshwater Consulting Group (FCG) was

appointed as the independent freshwater ecologist to perform a freshwater ecological assessment. His report

indicated that the perceived reference state of the site according to FCG is as follows. Prior to agricultural

development within the area, on portion 14 of farm 40 Klaas Voogds Rivier, the Doring River would have been

less confined than it currently is. It would most likely have been characterised by having multiple channels or

would have been a mobile channel that periodically shifted its position across the valley floor. This is in

contrast to the present-day situation of a single channel running along the western edge property. The original

reference state cannot be confirmed as the oldest dated aerial photographs dates back to 1966 and by this

time the Doring River valley had already been developed by agriculture and the river was confined to a single

channel. A Present Ecological State (PES) assessments was completed by FCG for the presumed ecological

state of the river before the illegal construction of the pipeline. This pre-pipeline PES indicated that the

instream component of the Doring River was rated to be “largely modified” (PES Class D, Freshwater Ecology

Impact Assessment Appendix 1), and the riparian zone was rated to be “moderately to largely modified” (PES

Class C/D Freshwater Ecology Impact Assessment Appendix 1). This impacts on the instream component is

believed to be due to an altered flow regime from water abstraction from the feeder dam and also because of

the modification of the river bed, channel and banks that resulted from previous agricultural practices. The

impacts on the riparian zone is believed to be due to channel modification, a decrease in indigenous

vegetation within the riparian zone and an increase in alien vegetation.




anchored by concrete foundations. During an unexpected flooding event in January 2014 the Doring River

flooded its banks and the 160 mm pipeline was severely damaged and some sections of the original existing

110 mm pipeline was also damaged. This flood also modified the river channel by establishing a new river

course, along the alignment of the unauthorised pipeline and eroded the bank into the first row of an adjacent

vineyard. There was however no damage to the pipeline between the dam and where it meets the river (the

northern section). The present ecological state (assessed by FCG on 12 May 2016, 2 years after the pipeline

construction) of the Doring River was rated to be marginally better than the pre-impact state in terms of the

instream component of the river (PES Class C/D – “moderately to largely modified”), although marginally


the instream component of the river after the flood is because the river established a new flow-path, along the

line where the unauthorised water pipeline had been placed from where it crossed the river. This new river

course bypassed the section of the river channel that was clearly an original diversion due to agricultural

activities in the valley according to the FCG. This new river course and river bed currently has a more natural

substrate of cobbles compared to the narrow densely vegetated old bypass route (which adjoined the Doring

River at nearly a 90 degree angle), further improving the new river course’s instream component. The reason

for the slightly poorer ecological condition of the riparian zone after the construction of the pipeline and

subsequently the flood was due to an increase in the degree of channel modification and, especially,

increased bank erosion. The erosion that occurred on the Doring River bank, particularly where the pipeline

crossed the river, is considered to be significantly greater than the natural levels of erosion that would have


S24GEIAR/07/2012 51

been observed during naturally-occurring flood events. This erosion will however be rectifiable with appropriate

bank reshaping and rehabilitation. The Ecological Importance and Sensitivity (EIS) of Doring River was also

assessed by FCG and indicated that the overall EIS rating of this system is of low-to-moderate importance and

sensitivity.














the FRa1 Breede Alluvium Renosterveld ecosystem, which is listed as a threatened ecosystem according to

the National Environmental Management: Biodiversity Act (Act 10 of 2004). However, the botanical

assessment also indicated this vegetation type no longer occurs here due to the current presence of a planted

pasture field and a farm homestead. Reshaping, rehabilitation with appropriate indigenous vegetation and the

installation of erosion protection structures on the river banks are also recommended once environmental

authorization has been granted. This is to mitigate the effects of the illegal pipeline construction and to reduce

any further erosion and damage. No rivers or wetlands were identified along these newly proposed routes.

This will be enforced according to the attached EMP and RMMP.

8. IMPACT ASSESSMENT

Briefly describe the impacts (as appropriate), significance rating of impacts, mitigation and significance rating of impacts of the

activity. This must include an assessment of the significance of all impacts.

Please note: This is a preliminary impact statement. The Department may request specialist input/studies depending on the type

and nature of the impact(s) of the activity/ies.

Impacts

Significance rating of impacts after

mitigation (Low, Medium, Medium-

High, High, Very High):

The transformation of indigenous Breede Shale Renosterveld and an

ESA. Please note that previous land use already transformed the

property though agricultural practices. No true Breede Shale

Renosterveld vegetation was present on site and no threatened plant

species or species of conservation concern were noted.

Low

During an unexpected flooding event in January 2014 the Doring River

flooded its banks and the 160 mm pipeline was severely damaged and

some sections of the original existing 110 mm pipeline was also

damaged. This flood also modified the river channel by establishing a

new river course, along the alignment of the unauthorised pipeline and

eroded the bank into the first row of an adjacent vineyard.

Low to medium


S24GEIAR/07/2012 52

Improvement of the instream habitat along the affected reach of the

Doring River. Low positive

The construction of a preferred and alternative replacement pipeline

route. Significant indigenous vegetation no longer occurs on the

preferred and alternative route due to the current presence of a planted

pasture field and a farm homestead. No rivers or wetlands were

identified along these newly proposed routes.

Low

9. IMPACT SUMMARY OF ACTIVITY

Please fill in the table below, by crossing out (“”) the appropriate box(es):

9.1 Socio-Economic Benefit Index (e.g. Municipal Infrastructure)

9.1.1 The development provides no direct social service to the affected community and /or will have little, or no,

positive impact on job creation and/or poverty alleviation in the area; or

9.1.2 The development provides little direct social service to the affected community and/or will have little, or

minor, positive impacts on job creation and/or poverty alleviation in the area; or

9.1.3 The development provides some social service to the affected community and/or will have a possible

positive impacts on job creation and/or poverty alleviation in the area; or X

9.1.4 The development provides a social service and/or will have a possible positive impact on job creation

and/or poverty alleviation in the area; or

9.1.5 The development provides an important social service and/or will have a measurable positive impact on

job creation and/or poverty alleviation in the area; or

9.1.6 The development provides an essential social service (immediately required/ emergency) and will have a

measurable positive impact on job creation and/or poverty alleviation in the area

Please provide motivation for the impact rating of the above impact index:

Saratoga farm is a fully functioning farm specializing in growing blueberries and provides employment for 40

permanent and 200 seasonal staff, all of which are previously disadvantaged individuals. The pipeline was

initially installed to provide water to a portion of these Blueberry orchards on the farm. The farming of berries

has a very high labour requirement due to the fact that the berries can only be picked by hand and cannot be

picked by machine. This therefore provides large employment opportunities to previously disadvantaged

individuals. This pipeline will allow Mr. Doms to further expand on the agricultural activities on his farm,

potentially leading to additional job creation and financial injection in the local community. A replacement

pipeline route is therefore required to provide water to these agricultural fields, which will have a positive

socio-economic impact and not result in further negative impacts on the physical environment.

9.2 Socio Economic Impact Index

9.2.1 The development will not give rise to any significant negative socio-economic impacts; or X

9.2.2 The development could give rise to negative socio-economic, but highly localised, impacts

9.2.3 The development could give rise to significant negative socio-economic, and regionalized impacts

9.2.4 The development could result in wide-scale socio-economic hardship.


The construction of an illegal pipeline occurred on an agricultural field and did not have any dust or noise

impacts on any communities. The construction of a replacement pipeline will enable water to be provided to

an increased area of agricultural field, resulting in a positive impact on the local community as there will be an

increase in job opportunities. No noise and odour impacts occurred during the construction of the water

pipeline as these activities were only temporary in nature.


S24GEIAR/07/2012 53

9.3 Biodiversity Impact Index

9.3.1

The development will give rise to insignificant impacts on biodiversity; or X

9.3.2 The development could give rise to significant, but localised biodiversity impacts

9.3.3 The development could give rise to significant, but regional biodiversity impacts

9.3.4 The development is likely to permanently/ irreversibly transform/ destroy a recognised biodiversity ‘hot-spot’

or threaten the existence of a species or sub-species.


The construction could have impacted upon indigenous Breede Shale Renosterveld and an ESA, although

previous land use already transformed the property though agricultural practices. A botanical assessment,

performed by Dr Dave McDonald, confirmed that no true Breede Shale Renosterveld vegetation is present

on site. No threatened plant species or species of conservation concern were found on the site. The riparian

vegetation has been significantly altered due to the presence of alien species such as Populus canescens

(invasive cat. 2), Salix babylonica (Weeping willow), Acacia saligna (Port Jackson Willow), Senna


reed) Cirsium vulgare (Spear thistle) and Kikuyu grass (Pennistetum clandestinum) (cat. 1b). Where not


present in the river valley on the south of the Langeberg. This vegetation is however not threatened. A small

portion (± 50 m) of the proposed preferred and alternative replacement pipeline route is mapped as the FRa1

Breede Alluvium Renosterveld ecosystem, which is listed as a threatened ecosystem. However, the

botanical assessment also indicated this vegetation type no longer occurs here due to the current presence of

a planted pasture field and a farm homestead. No rivers or wetlands were identified along these newly

proposed routes.

During an unexpected flooding event in January 2014 the Doring River flooded its banks and the 160 mm

pipeline was severely damaged and some sections of the original existing 110 mm pipeline was also

damaged. This flood also modified the river channel by establishing a new river course, along the alignment

of the unauthorised pipeline and eroded the bank into the first row of an adjacent vineyard. There was

however no damage to the pipeline between the dam and where it meets the river (the northern section). The

present ecological state (assessed by FCG on 12 May 2016, 2 years after the pipeline construction) of the

Doring River was rated to be marginally better than the pre-impact state in terms of the instream component

of the river (PES Class C/D – “moderately to largely modified”), although marginally worse in terms of the

riparian component (PES Class D – “largely modified”). This improvement in the state of the instream

component of the river after the flood is because the river established a new flow-path, along the line where

the unauthorised water pipeline had been placed from where it crossed the river. This new river course

bypassed the section of the river channel that was clearly an original diversion due to agricultural activities in

the valley according to the FCG. This new river course and river bed currently has a more natural substrate of

cobbles compared to the narrow densely vegetated old bypass route (which adjoined the Doring River at

nearly a 90 degree angle), further improving the new river course’s instream component.

The reason for the slightly poorer ecological condition of the riparian zone after the construction of the

pipeline and subsequently the flood was due to an increase in the degree of channel modification and,

especially, increased bank erosion. The erosion that occurred on the Doring River bank, particularly where

the pipeline crossed the river, is considered to be significantly greater than the natural levels of erosion that

would have been observed during naturally-occurring flood events. This erosion will however be rectifiable

with appropriate bank reshaping and rehabilitation. The Ecological Importance and Sensitivity (EIS) of Doring

River was also assessed by FCG and indicated that the overall EIS rating of this system is of low-to-

moderate importance and sensitivity.


S24GEIAR/07/2012 54

9.4 Sense of Place (including visual) Impact Index

9.4.1 The development is in keeping with the surrounding environment X

9.4.2 The development is not in keeping with the surrounding environment and will have a significant localised

impact on the affected area's sense of place

9.4.3 The development is not in keeping with the surrounding environment, but will have a significant regionalised


9.4.4 The development is completely out of keeping with the surrounding environment and will have a significant



The illegal pipeline was constructed underground and placed parallel to an existing 110 mm pipeline. The

subsequent construction of a replacement pipeline will also occur underground and be located underneath a

planted pasture field and an existing dirt/gravel road. The visual character of the site was only minimally

altered because the pipeline was installed underneath the ground. The construction of the water pipeline is

not expected to alter the sense of place and character of the site, as it fits into the current land use being

utilized for agriculture. The visual impact is thus considered to be not significant. The visual aspect of the site

was however altered as a result of a flooding event in January 2014 that caused erosion of the river banks.

The botanical assessment also noted that the vegetation on the banks of the Doring River around the site has


played a role in the erosion damage as a result.

9.5 Noise Impact Index

9.5.1 The development is unlikely to give rise to any significant noise X

9.5.2 The development may lead to significant noise pollution, limited to the site.

9.5.3 The development will give rise to significant noise pollution, affecting the surrounding community


No noise and odour impacts occurred during the construction of the water pipeline as these activities were

only temporary in nature. There will also not be any noise impacts during the operational phase as the

pipeline will be gravity fed and therefore not require the use of a pump. The construction of a replacement

pipeline will also not result in significant noise or odour impacts as these impacts will only be temporary in

nature. The site is predominantly surrounded by agricultural land use.

9.6 Pollution and Waste Impact Index

9.6.1 The development will not give rise to any significant quantities of waste or pollution; or X

9.6.2 The development could give rise to quantities of pollution or waste that could have significant, but

localised (immediate community and environment)impacts.

9.6.3 The development could give rise to quantities of pollution or waste that could have significant, but regional

(beyond immediate environment and community) impacts.

9.6.4 The development is likely to give rise to a significant quantity of prioritised pollutants or waste streams (e.g.

greenhouse gases, hazardous substances, radioactive waste, etc.).


A non-significant amount of waste would have been produced during the construction of the 160 mm pipeline.

During an unexpected flooding event in January 2014 the Doring River flooded its banks and the newly

constructed 160mm pipeline was severely damaged. Parts of the pipeline were broken and some segments

remain within the watercourse and/or are entangled within the riverine vegetation. These damaged pipes are

still currently within the watercourse and will be removed and disposed of at the nearest licenced landfill site

once authorization is given to remove them. This is because the pre-compliance notice that was issued to Mr.

Doms instructed all listed activates to cease immediately. The construction of a replacement 160 mm pipeline

will also not produce a significant amount of waste.

Please note: Section 9 is to be completed after all specialist studies and input from Interested and Affected Parties have been

obtained.


S24GEIAR/07/2012 55

10. OTHER MANAGEMENT, MITIGATION AND MONITORING MEASURES

(a) Over and above the mitigation measures described above, please indicate any additional management, mitigation and

monitoring measures.

Full compliance with the Environmental Management Programme as compiled for this specific 24G EIA

Report.

(b) Describe the ability of the applicant to implement the management, mitigation and monitoring measures.

The applicant has the finances, resources and knowledge to implement the EMP.

Please note: A draft ENVIRONMENTAL MANAGEMENT PROGRAMME must be attached this report as appendix F.


S24GEIAR/07/2012 56

SECTION G: ASSESSMENT METHODOLOGIES AND CRITERIA, GAPS IN

KNOWLEDGE, UNDERLAYING ASSUMPTIONS AND UNCERTAINTIES

(a) Please describe adequacy of the assessment methods used.

The assessment methods used for the proposed project were adequate as all possible impacts were assessed

in detail.

(b) Please describe the assessment criteria used.

The criteria for the description and assessment of environmental impacts were drawn from the National Environmental Management Act, 1998 (Act No.107 of 1998).

The level of detail was somewhat fine-tuned by assigning specific values to each impact. In order to establish a coherent framework within which all impacts could be objectively assessed it is necessary to establish a rating system, which is consistent throughout all criteria. For such purposes each aspect was assigned a value, ranging from 1-5, depending on its definition.

1 Potential Impact

This is an appraisal of the type of effect the proposed activity would have on the affected environmental component. Its description should include what is being affected and how it is being affected.

2 Extent

The physical and spatial scale of the impact is classified as:

Local

The impacted area extends only as far as the activity, e.g. a footprint.

Site

The impact could affect the whole, or a measurable portion of the site.

Regional

The impact could affect the area including the neighbouring erven and/or farms, the transport routes and the adjoining towns.

3 Duration

The lifetime of the impact, which is measured in relation to the lifetime of the proposed base.

Short term

The impact will either disappear with mitigation or will be mitigated through a natural process in a period shorter than any of the phases.

Medium term

The impact will last up to the end of the phases, where after it will be entirely negated.

Long term

The impact will continue or last for the entire operational lifetime of the Development, but will be mitigated by direct human action or by natural processes thereafter.

Permanent

This is the only class of impact, which will be non-transitory. Mitigation either by man or natural process will not occur in such a way or in such a time span that the impact can be considered transient.

4 Intensity

The intensity of the impact is considered here by examining whether the impact is destructive or benign, whether it destroys the impacted environment, alters its functioning, or slightly alters the environment itself. These are rated as:

Low

The impact alters the affected environment in such a way that the natural processes or functions are not affected.


S24GEIAR/07/2012 57

Medium

The affected environment is altered, but functions and processes continue, albeit in a modified way.

High

Function or process of the affected environment is disturbed to the extent where it temporarily or permanently ceases.

This will be a relative evaluation within the context of all the activities and the other impacts within the framework of the project.

5 Probability

This describes the likelihood of the impacts actually occurring. The impact may occur for any length of time during the life cycle of the activity, and not at any given time. The classes are rated as follows:

Improbable

The possibility of the impact occurring is none, due either to the circumstances, design or experience.

Possible

The possibility of the impact occurring is very low, due either to the circumstances, design or experience.

Likely

There is a possibility that the impact will occur to the extent that provisions must therefore be made.

Highly Likely

It is most likely that the impacts will occur at some stage of the Development. Plans must be drawn up before carrying out the activity.

Definite

The impact will take place regardless of any prevention plans, and only mitigation actions or contingency plans to contain the effect can be relied on.

6 Determination of Significance – Without Mitigation

Significance is determined through a synthesis of impact characteristics, and is an indication of the importance of the impact in terms of both physical extent and time scale. The significance of the impact “without mitigation” is the prime determinant of the nature and degree of mitigation required. Where the impact is positive, significance is noted as “positive”. Significance is rated on the following scale:

No significance

The impact is not substantial and does not require any mitigation action.

Low

The impact is of little importance, but may require limited mitigation.

Medium

The impact is of importance and is therefore considered to have a negative impact. Mitigation is required to reduce the negative impacts to acceptable levels.

High

The impact is of great importance. Failure to mitigate, with the objective of reducing the impact to acceptable levels, could render the entire development option or entire project proposal unacceptable. Mitigation is therefore essential.

7 Determination of Significance – With Mitigation

Significance is determined through a synthesis of impact characteristics. It is an indication of the importance of the impact in terms of both physical extent and time scale, and therefore indicates the level of mitigation required. In this case the prediction refers to the foreseeable significance of the impact after the successful implementation of the suggested mitigation measures. Significance with mitigation is rated on the following scale:

No significance

The impact will be mitigated to the point where it is regarded to be insubstantial.

Low

The impact will be mitigated to the point where it is of limited importance.


S24GEIAR/07/2012 58

Low to medium

The impact is of importance, however, through the implementation of the correct mitigation measures such potential impacts can be reduced to acceptable levels.

Medium

Notwithstanding the successful implementation of the mitigation measures, to reduce the negative impacts to acceptable levels, the negative impact will remain of significance. However, taken within the overall context of the project, the persistent impact does not constitute a fatal flaw.

Medium to high

The impact is of great importance. Through implementing the correct mitigation measures the negative impacts will be reduced to acceptable levels.

High

The impact is of great importance. Mitigation of the impact is not possible on a cost-effective basis. The impact continues to be of great importance, and, taken within the overall context of the project, is considered to be a fatal flaw in the project proposal. This could render the entire development option or entire project proposal unacceptable.

(c) Please describe the gaps in knowledge.

There are no known gaps in the knowledge to the EAP.

(d) Please describe the underlying assumptions.

Due to the fact that the area surrounding the site where the pipeline was constructed has previously been

transformed due to agriculture, it is difficult to determine whether there are any archaeological artefacts were

present on site, however this is highly unlikely. A notice of intent to develop has been submitted to Heritage

Western Cape (HWC), and they have issued a positive Record of Decision, to permit the proposed

construction on the 30th of May 2016. This is because the newly proposed route encompasses predominantly

on pasture fields and an existing dirt/gravel road.

(e) Please describe the uncertainties.

It is uncertain if the construction would have had an impact on any cultural or archaeological artefacts in the

area.


S24GEIAR/07/2012 59

SECTION H: RECOMMENDATIONS OF THE EAP

In my view (EAP), the information contained in this Application Form and the documentation attached

hereto is sufficient to make a decision in respect of the activity applied for. YES NO

If “NO”, list the aspects that should be further assessed through additional specialist input/assessment:

N/A

If “YES”, please indicate below whether in your opinion the applicant should be directed to cease the activity or if it should be

authorised:

Applicant should be directed to cease the activity: YES NO

Please provide reasons for your opinion


S24GEIAR/07/2012 60

1. The construction of the 160 mm pipeline occurred in close proximity to an existing 110 mm pipeline

and would not have significantly impacted upon the existing vegetation as the area had already be

transformed due to agriculture. No true Breede Shale Renosterveld vegetation was present on site and

no threatened plant species or species of conservation concern were found on the site by the

botanical assessment.

2. Historically the Doring Rivers would have been characterised by having multiple channels or a

periodically shifting channel across the valley floor. The ecological state of the Doring River before the

pipeline was constructed indicated that its instream component was already largely modified due to an

altered flow regime and agricultural practices. The present ecological state (after the pipeline

construction and flood) was rated to be marginally better than the pre-impact state in terms of the

instream component, bypassing a heavily vegetated previously diverted section of river and having a

more natural substrate of cobbles. The present ecological state is however marginally worse in terms

of the riparian component as a result of an increase in the degree of channel modification and bank

erosion.

3. The flood-related damage to the Doring River was not attributable to the pipeline construction and

was likely a result of a major flood event. The river erosion was however exacerbated by the presence

of the unauthorised pipeline. The overall significance would become low with rectification. The

negative impacts of the flood-related modifications to the river must be weighed up against the

positive impact of the improvement of the instream habitat within the new channel.

4. Negative impacts with regards to the disturbed indigenous vegetation and the erosion of the Doring

River can be mitigated to acceptable levels by the implementation of rehabilitation according to the

EMP and RMMP. The existing PVC segments of the damaged pipeline must be removed from within

riverbanks and be disposed of at a licenced landfill. The river banks must then be reshaped and

rehabilitated with appropriate indigenous riverine vegetation. This erosion will however be rectifiable

with appropriate bank reshaping and rehabilitation at the point where the pipeline crossed the river.

Guillaume Nel Environmental Consultants should be consulted to design and oversee the

implementation of the reshaping and rehabilitation.

5. A replacement pipeline is required whereby a preferred and an alternative replacement pipeline

route has been proposed to have positive socio-economic impacts and minimal environmental

damage. Both the preferred and the alternative replacement route will not trigger any National

Environmental Management Act: Environmental Impact Assessment Regulations GN R. 982 of 2014

listed activities, however it is foreseen that the preferred route will be more cost efficient and have less

environmental impacts.

6. No negative impact on any Cultural/Historical aspects occurred during the illegal construction of the

160 mm pipeline and are subsequently not expected to occur when constructing the replacement

pipeline. This is because it will be placed underneath a planted pasture field and an existing dirt/gravel

road.


S24GEIAR/07/2012 61

7. The construction of the illegal pipeline and subsequently the replacement pipeline is in line with the

provincial and Municipal Spatial Development Frameworks as it promotes agricultural activities and

job creation.

8. The construction of a replacement pipeline will result in the expansion of agricultural activities and

increase the farm’s production, which will lead to the creation of short and long-term employment

opportunities and inject necessary capital into the local community.

9. The riparian vegetation has been significantly altered due to the presence of alien species and is a

contributing factor to the instability of the soils and could have played a role in the erosion damage as

a result. The Doring River banks will therefore require regular alien clearing within the watercourse

and the river catchment area.


S24GEIAR/07/2012 62

SECTION I: MOTIVATION FOR RESPONSE TO AN EMERGENCY This section is only applicable to instances where Section 24F (3) of NEMA applies. Please list all steps that where taken in

response to the emergency.

N/A

Please note: Section 30 of NEMA deals with the procedures to be followed for the control of emergency incidents.


S24GEIAR/07/2012 63

SECTION J: APPENDICES The following appendices must, where applicable, be attached to this report:

Appendix

Tick the box

if Appendix

is attached

Appendix A: Project plan

Appendix B: Locality map, Site map, Vegetation map, Biodiversity overlay

map, Preferred and Alternative site map and Topographical map.

Appendix C: Photographs

Appendix D: Permit(s) / license(s) from any other organ of state including

service letters from the municipality

Appendix E: Specialist Report(s)

Appendix F: Environnemental Management Programme

River Maintenance Management Plan

Appendix G: Certified copy of Identity Document of Transgressor/Applicant

Appendix H: Any Other (if applicable): Pre-compliance notice

Appendix I:

Public participation information: including a copy of the register

of interested and affected parties, the comments and responses

report, proof of notices, advertisements and any other public

participation information as required in Section C above.


S24GEIAR/07/2012 64

DECLARATIONS

The applicant

I …………………………………., in my personal capacity or duly authorised as ………………………….

(state capacity) by …………….................................………………… thereto hereby declare that I:

regard the information contained in this report to be true and correct, and

am fully aware of my responsibilities in terms of the Environment Conservation Act, 1989 (Act No. 73

of 1989) and the National Environmental Management Act of 1998 (“NEMA”) (Act No. 107 of 1998),

the Environmental Impact Assessment Regulations (“EIA Regulations”) in terms of NEMA, and the

relevant specific environmental management Act(s), and that failure to comply with these

requirements may constitute an offence in terms of the environmental legislation;

appointed the environmental assessment practitioner as indicated above, which meet all the

requirements in terms of Regulation 17 of GN No. R. 543, to act as the independent Environmental

Assessment Practitioner for this application;

have provided the environmental assessment practitioner and the competent authority with

access to all information at my disposal that is relevant to the application;

am fully aware of the administrative fine to be paid before a decision with respect to the

continuation of the listed activity(ies) for which rectification is sought will be made;

will be responsible for the costs incurred in complying with the environmental legislation including

but not limited to –

o costs incurred in connection with the appointment of the environmental assessment

practitioner or any person contracted by the environmental assessment practitioner;

o costs incurred in respect of the undertaking of any process required in terms of this application;

o costs in respect of any fee prescribed by the Minister or MEC in respect of the regulations;

o costs in respect of specialist reviews, if the competent authority decides to recover costs;

o the provision of security to ensure compliance with the applicable management and

mitigation measures; and

o fine costs

am responsible for complying with the conditions that might be attached to any decision(s) issued

by the competent authority;

am aware that I may be issued with a directive and that I must comply with such a directive;

have the ability to implement the applicable management, mitigation and monitoring measures;

hereby indemnify, the government of the Republic, the competent authority and all its officers,

agents and employees, from any liability arising out of, inter alia, the content of any report, any

procedure or any action for which the applicant or environmental assessment practitioner is

responsible; and

Please Note: If acting in a representative capacity, a certified copy of the resolution or power of

attorney must be attached.

Signature of the applicant:

Name of company:

Date:


S24GEIAR/07/2012 65

The independent environmental assessment practitioner (“EAP”)

I ……………………………………, as the appointed independent environmental practitioner (“EAP”)

hereby declare that I:

act/ed as the independent EAP in this application;

regard the information contained in this report to be true and correct, and

do not have and will not have any financial interest in the undertaking of the activity, other than

remuneration for work performed in terms of the ECA , the NEMA, the Environmental Impact

Assessment Regulations and any specific environmental management Act(s);

have and will not have any vested interest in the proposed activity proceeding;

have disclosed, to the applicant and competent authority, any material information that have or

may have the potential to influence the decision of the competent authority or the objectivity of

any report, plan or document required in terms of the NEMA, the Environmental Impact Assessment

Regulations, 2010 and any specific environmental management Act(s);

am fully aware of and meet the responsibilities in terms of NEMA, the Environmental Impact

Assessment Regulations (specifically in terms of Regulation 17 of GN No. R. 543) and any specific

environmental management Act, and that failure to comply with these requirements may

constitute and result in disqualification;

have ensured that information containing all relevant facts in respect of the application was

distributed or made available to interested and affected parties and the public and that

participation by interested and affected parties was facilitated in such a manner that all interested

and affected parties were provided with a reasonable opportunity to participate and to provide

comments;

have ensured that the comments of all interested and affected parties were considered, recorded

and submitted to the competent authority in respect of the application;

have kept a register of all interested and affected parties that participated in the public

participation process;

have provided the competent authority with access to all information at my disposal regarding the

application, whether such information is favourable to the applicant or not; and

Note: The terms of reference must be attached.

Signature of the environmental assessment practitioner:

Name of company:

Date:


S24GEIAR/07/2012 66

The independent PERSON WHO COMPILED A SPECIALIST REPORT OR UNDERTOOK A

SPECIALIST PROCESS

I ……………………………………, as the appointed independent specialist hereby declare that I:

act/ed as the independent specialist in this application;

regard the information contained in this report as it relates to my specialist input/study to be true

and correct, and

do not have and will not have any financial interest in the undertaking of the activity, other than

remuneration for work performed in terms of the ECA, the NEMA, the Environmental Impact

Assessment Regulations and any specific environmental management Act(s);

have and will not have any vested interest in the proposed activity proceeding;

have disclosed, to the applicant, EAP and competent authority, any material information that

have or may have the potential to influence the decision of the competent authority or the

objectivity of any report, plan or document required in terms of the NEMA, the Environmental

Impact Assessment Regulations and any specific environmental management Act(s);

am fully aware of and meet the responsibilities in terms of NEMA, the Environmental Impact

Assessment Regulations (specifically in terms of Regulation 17 of GN No. R. 543) and any specific

environmental management Act, and that failure to comply with these requirements may

constitute and result in disqualification;

have ensured that information containing all relevant facts in respect of the specialist input/study

was distributed or made available to interested and affected parties and the public and that

participation by interested and affected parties was facilitated in such a manner that all interested

and affected parties were provided with a reasonable opportunity to participate and to provide

comments on the specialist input/study;

have ensured that the comments of all interested and affected parties on the specialist input/study

were considered, recorded and submitted to the competent authority in respect of the

application;

have ensured that the names of all interested and affected parties that participated in terms of the

specialist input/study were recorded in the register of interested and affected parties who

participated in the public participation process;

have provided the competent authority with access to all information at my disposal regarding the

application, whether such information is favourable to the applicant or not; and

Note: The terms of reference must be attached.

Signature of the specialist:

Name of company:

Date:

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