OPEN SPACE AND SENSITIVE AREA ASSESSMENT AS

PART OF THE ENVIRONMENTAL AUTHORISATION AND

WATER USE AUTHORISATION PROCESS FOR THE

ERASMUSKLOOF RETAIL CENTRE DEVELOPMENT AREA

Prepared for

ATTERBURY PROPERTY HOLDINGS

May 2018

Prepared by: Scientific Aquatic Services Report authors: Stephen van Staden (Pr. Sci. Nat.) Report reviewer: Nelanie Cloete (Pr. Sci. Nat.) Report Reference: SAS 218069 Field Assessment Date: April 2018 Submission Date: May 2018

Scientific Aquatic Services CC CC Reg No 2003/078943/23 Vat Reg. No. 4020235273 PO Box 751779 Gardenview 2047 Tel: 011 616 7893 Fax: 086 724 3132 E-mail: admin@sasenvgroup.co.za

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

authority

I, Stephen van Staden, declare that -

• I act as the independent specialist in this application;

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

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

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

• I will comply with the applicable legislation;

• I have not, and will not engage in, conflicting interests in the undertaking of the activity;

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

• All the particulars furnished by me in this form are true and correct

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TABLE OF CONTENTS

1. INTRODUCTION AND BACKGROUND .................................................................................... 1

2. SCOPE OF WORK AND DELIVERABLES ............................................................................... 1

3. DESKTOP ASSESSMENT RESULTS ....................................................................................... 4

4. LEGISLATIVE CONTEXT .......................................................................................................... 9

5. SITE SPECIFIC RESULTS ....................................................................................................... 10

5.1 SITE SPECIFIC HISTORICAL DATA ........................................................................................ 10 5.2 SITE ASSESSMENT RESULTS ............................................................................................... 14

6. DATA ANALYSES .................................................................................................................... 20

7. CONCLUSION AND RECOMMENDATIONS .......................................................................... 24

8. REFERENCES .......................................................................................................................... 27

LIST OF FIGURES Figure 1: Digital Satellite image depicting the location of the Erasmuskloof Retail Centre

Development Area in relation to surrounding areas. ............................................................ 2 Figure 2: The Erasmuskloof Retail Centre Development Area depicted on a 1:50 000

topographical map in relation to the surrounding area. ........................................................ 3 Figure 3: The location of natural and artificial wetland features and the Apies River in relation

to the Erasmuskloof Retail Centre Development Area, according to NFEPA (2011). ......... 6 Figure 4: Critically Endangered ecosystem (remaining extent of the critically endangered

Witwatersberg Pretoria Mountain Bushveld Ecosystem), associated with the Erasmuskloof Retail Centre Development Area according to the National Threatened Ecosystem Database (2011). ........................................................................... 7

Figure 5: The CBA, wetland buffer and Kwaggasrant Class 2 ridge associated with the Erasmuskloof Retail Centre Development Area (Gauteng C-Plan V3.3, 2011). .................. 8

Figure 6: Layout Version 1 of the Erasmuskloof Retail Centre. ........................................................ 12 Figure 7: Layout Version 2 of the Erasmuskloof Retail Centre. ........................................................ 13 Figure 8: Sensitivity analysis of the Erasmus Park Township Development Area. .......................... 16 Figure 9: The proposed Development overlaid over revised map after micro-mapping. .................. 17 Figure 10: The proposed Development overlaid over revised map after micro-mapping and

zoomed to the area of concern. .......................................................................................... 18 Figure 11: The proposed Development overlaid over revised map after micro-mapping and

zoomed to the area of concern. .......................................................................................... 19 Figure 12: Sensitivity analysis of the Erasmuskloof Retail Centre Development Area..................... 23

LIST OF TABLES Table 1: Summary of the conservation characteristics for the study area. ....................................... 4

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1. INTRODUCTION AND BACKGROUND

Scientific Aquatic Services (SAS) was appointed by Atterbury Property Holdings to conduct

an open space and sensitive areas assessment in response to the decision of GDARD on an

appeal lodged by the proponent. This study aims to provide an objective view of the value of

the area previously defined as being of Medium-High Ecological Importance and Sensitivity

as part of the environmental assessment and authorisation process as well as the appeal

process (Exigo 2016 and 2018).

2. SCOPE OF WORK AND DELIVERABLES

In order to achieve the objective above the following tasks were executed:

1. Review of existing information;

2. Identification of national, provincial and local municipal sensitivities of the surrounding

areas;

3. Consideration of National and Provincial buffers and zones and Regulations;

4. A site investigation was undertaken to gain first-hand understanding of the site-specific

conditions and to further develop a detailed baseline assessment including:

a. Considering the characteristics of the existing Medium-High sensitive area and

providing a recommendation as to whether the proposed partial development of

this area can be supported from an ecological perspective;

b. Consider grassland habitat integrity within the study area with specific

consideration of primary grassland and grassland in good ecological condition; and

c. Consider grassland species which currently exist in this area and how this aspect

affects development in this zone;

5. Consider statistical information on the area of concern and how this pertains to

conservation and development constraints; and

6. Provide recommendations, including layout considerations and other management

and mitigation measures including open space management.

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Figure 1: Digital Satellite image depicting the location of the Erasmuskloof Retail Centre Development Area in relation to surrounding areas.

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Figure 2: The Erasmuskloof Retail Centre Development Area depicted on a 1:50 000 topographical map in relation to the surrounding area.

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3. DESKTOP ASSESSMENT RESULTS

Table 1: Summary of the conservation characteristics for the study area.

Aquatic ecoregion and sub-regions in which the study area is located Detail of the study area in terms of the National Freshwater Ecosystem Priority Area (NFEPA) (2011) database (Figure 4 & 5)

Ecoregion Western Bankenveld FEPACODE

The study area falls within a sub quaternary catchment currently not considered important in terms of freshwater resources or fish species conservation.

Catchment Limpopo

Quaternary Catchment A23D

NFEPA Wetlands

According to the NFEPA database there are no wetland features located within the Erasmus Park Township Development Area, however a natural and artificial wetland feature is situated approximately 180m to the south (Figure 3).

WMA Crocodile (West) and Marico

subWMA Apies/Pienaars

Dominant characteristics of the Western Bankenveld Ecoregion Level II (11.01) (Kleynhans et al., 2007) Wetland vegetation Type

The Erasmus Park Township Development Area is located within the Dry Highveld Grassland Group 5, a least threatened wetland vegetation type.

Dominant primary terrain morphology Undulating hills and lowlands

NFEPA Rivers

According to the NFEPA database there are no Rivers located within the Erasmus Park Township Development Area, however the Apies River is situated approximately 290m southwest of the Erasmus Park Township Development Area (Figure 3). The Apies River is considered largely modified (Class D).

Dominant primary vegetation types Rocky Highveld Grassland

Altitude (m a.m.s.l) 1100 to 1700

MAP (mm) 500 to 700 Ecological Status of the most proximal sub-quaternary reach (DWS, 2014)

Coefficient of Variation (% of MAP) 25 to 29

Sub-quaternary reach A23D – 01117 (Apies River)

Proximity to site ±290m south west of Erasmus Park

Township Development Area

Rainfall concentration index 60 to 64 Assessed by expert? Yes

Rainfall seasonality Early to mid-summer Mean Ecological Importance (EI) Class Low

Mean annual temp. (°C) 14 to 18 Mean Ecological Sensitivity (ES) Class Low

Winter temperature (July) 0 – 20 ºC Stream Order 1

Summer temperature (Feb) 12 – 28 ºC Default Ecological Class (based on median PES and highest EI or ES mean)

D (Low to very low) Median annual simulated runoff (mm) 20 to 60; 60 to 80 (limited)

Details of the study area in terms of Mucina & Rutherford (2012) Description of the vegetation type(s) relevant to the study area (Mucina & Rutherford 2012)

Biome The Erasmus Park Township Development Area is situated within the Grassland Biome. Vegetation Type Carletonville Dolomite Grassland

Bioregion The Erasmus Park Township Development Area is located within the Dry Highveld Grassland Bioregion

Climate Warm temperate climate, summer rainfall

Altitude (m) 1500-1560

Vegetation Type The Erasmus Park Township Development Area is situated within the Carletonville Dolomite Grassland vegetation type.

MAP* (mm) 682

MAT* (°C) 16.1

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Conservation details pertaining to the study area (Various databases) MFD* (Days) 37

NBA (2011) The Erasmus Park Township Development Area falls within an area that is currently poorly protected.

MAPE* (mm) 2388

MASMS* (%) 78

National Threatened Ecosystems (2011)

The majority of the Erasmus Park Township Development Area falls within a remaining extent of the critically endangered Witwatersberg Pretoria Mountain Bushveld Ecosystem (Figure 4).

Distribution North-West (mainly), Gauteng and marginally into the Free State Province

Conservation Vulnerable. Conservation target is 24%, with small extent statutorily conserved.

SAPAD (2017) & NPAES (2009)

The Rietvlei / Van Riebeeck Nature Reserve (NR) is situated approximately 3,6km southeast, Groenkloof NR ±3km northwest, Groenkloof National Park ± 6,7km northwest, Austin Roberts Bird Sanctuary 5km north-northwest, Frank Struben Bird Sanctuary ± 6,4km north, Colbyn Wetland NR ±8,2km and the Faerie Glen NR ± 6,4km northeast of the Erasmus Park Township Development Area, according to SAPAD (2018). Additionally, SACAD (2018) indicates the Pretoria National Botanical Garden approximately 9km northeast of the development area. The NPAES (2009), furthermore indicates the Moreleta Kloof Municipal NR ±3,1km east and the Voortrekker Monument Private NR ±6,6km northwest of the development area.

Vegetation & landscape features

Slightly undulating plains dissected by prominent rocky chert ridges Species rich grasslands forming a complex mosaic pattern comprised of many species.

IBA (2015) The Erasmus Park Township Development Area is not located within or near an Important Bird Area (within 10 km).

Detail of the study area in terms of the Gauteng Conservation Plan (C-Plan V3.3, 2011)

Critical Biodiversity Area (CBA)

The majority (90%) of the Erasmus Park Township Development Area, with the exception of a few small scattered patches fall within a CBA (Figure 5). This CBA is considered an important area for Red and Orange Listed plant habitat and for primary vegetation. A CBA is an area considered important for the survival of threatened species and includes valuable ecosystems such as wetlands, untransformed vegetation and ridges (GDARD, 2014a). The majority of the approved development footprint is located within the CBA. Only areas of medium high sensitivity were excluded from the approved proposed layout plan.

Ridges The remaining extent of the Kwaggasrant Class 2 ridge is situated approximately 40m east of the Erasmus Park Township Development Area. Class 2 ridges include ridges of which more than 5%, but less than 35%, of their surface area has been converted to urban development, quarries and/or alien vegetation encroachment.

Wetland Buffer The Gauteng C-Plan indicates a wetland buffer located approximately 140m south of the Erasmus Park Township Development Area, corresponding with the NFEPA Database (2011).

DWS = Department of Water and Sanitation; EI = Ecological Importance; ES = Ecological Sensitivity; m.a.m.s.l = Metres Above Mean Sea Level; MAP = Mean Annual Precipitation; NFEPA = National Freshwater Ecosystem Priority Areas; WMA = Water Management Area; NBA = National Biodiversity Assessment; SAPAD = South African Protected Areas Database; IBA = Important Bird Area; NR = Nature Reserve; MAP – Mean annual precipitation; MAT – Mean annual temperature; MAPE – Mean annual potential evaporation; MFD = Mean Frost Days; MASMS – Mean annual soil moisture stress (% of days when evaporative demand was more than double the soil moisture supply).

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Figure 3: The location of natural and artificial wetland features and the Apies River in relation to the Erasmuskloof Retail Centre Development Area, according to NFEPA (2011).

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Figure 4: Critically Endangered ecosystem (remaining extent of the critically endangered Witwatersberg Pretoria Mountain Bushveld Ecosystem), associated with the Erasmuskloof Retail Centre Development Area according to the National Threatened Ecosystem Database (2011).

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Figure 5: The CBA, wetland buffer and Kwaggasrant Class 2 ridge associated with the Erasmuskloof Retail Centre Development Area (Gauteng C-Plan V3.3, 2011).

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4. LEGISLATIVE CONTEXT

The trigger for Activity 12 of Listing Notice (LN) 3 is the clearance of an area of 300m2 or more

of indigenous vegetation, provided that this is within a specified Geographical Areas Based

on Environmental Attributes.

Clearance of land is defined as ploughing of land, bulldozing of an area, eradication or removal

of vegetation cover with chemicals, amongst others, constitutes clearance of vegetation,

provided that this will result in the vegetation being eliminated, removed or eradicated.

Environmental authorisation for Activity 12 of LN 3 is only required in an event where clearance

of indigenous vegetation of 300m2 or more is proposed within an identified geographical area.

The specified geographical areas have been amended on 07 April 2017 with effect the same

day (See GNR 324). Geographical areas are competent authority specific. In an event where

such an activity falls outside an identified geographical area (as per LN 3), this activity cannot

be triggered, irrespective the sensitivity of the receiving environment or close proximity thereof

to such an identified geographical area.

For this activity to be triggered:

1. The area cleared of its vegetation must be 300m2 or more; AND

2. There must be at least 300m2 of indigenous vegetation that will be cleared; AND

3. The exclusion provided for (if any) may NOT be present; AND

4. This must take place / must have taken place within an identified geographical area as

per:

a. GNR 985 if between December 08 December 2014 and end of day 06 April 2017;

OR

b. GNR 324 if on or after 07 April 2017.

In the Case of Gauteng this Listing notice is thus applicable as follows:

I. Within any critically endangered or endangered ecosystem listed in terms of section

52 of the NEMBA or prior to the publication of such a list, within an area that has been

identified as critically endangered in the National Spatial Biodiversity Assessment

2004;

II. Within Critical Biodiversity Areas or Ecological Support Areas identified in the Gauteng

Conservation Plan or bioregional plans; or

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III. On land, where, at the time of the coming into effect of this Notice or thereafter such

land was zoned open space, conservation or had an equivalent zoning.

Given the above it is clear that Listed Activity 12 of LN 3 is triggered and as such GDARD may

exercise their rights to make decisions on development within the area. The area in question

is a CBA important area and has not been defined as a CBA irreplaceable area. A CBA is an

area considered important for the survival of threatened species and includes valuable

ecosystems such as wetlands, untransformed vegetation and ridges (GDARD, 2014a).

According to the GDARD Cplan CBAs include natural or near-natural terrestrial and aquatic

features that were selected based on an area's biodiversity characteristics, spatial

configuration and requirement for meeting both biodiversity pattern and ecological process

targets. CBAs include irreplaceable sites where no other options exist for meeting targets for

biodiversity features, as well as best-design sites which represent an efficient configuration of

sites to meet targets in an ecologically sustainable way that is least conflicting with other land

uses and activities. These areas need be maintained in the appropriate condition for their

category. Some CBAs are degraded or irreversibly modified but are still required for achieving

specific targets, such as cultivated lands for threatened species.

To determine if it is appropriate to develop this area then becomes a technical discussion on

the merits of the area being defined as sensitive and worthy of conservation.

5. SITE SPECIFIC RESULTS

5.1 Site Specific Historical Data

According to the technical MEMO prepared by Exigo in January 2018, the baseline specialist

study identified various vegetation units of which the Loudetia simplex – Xerophyta retinervis

grassland outcrops was identified as having a Medium-High Sensitivity based on the GDARD

guidelines in the C-Plan. Although development within this vegetation unit was excluded by

GDARD as one of the conditions of the Environmental Authorisation, the ecological study

(Exigo; 2016) did not recommend this vegetation unit be excluded from any development. The

key reason given was because the north western section of the rocky grassland is already

degraded. Furthermore, according to Exigo (2018), degradation is anticipated to spread to the

rest of the rocky grassland area due to the current dumping on site (this expanded partially

into the area since the survey was conducted in 2016). In addition, it was noted that the rocky

grassland / outcrop to the north of the proposed new access road has been partially impacted

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during the Phase 2 Heritage project through excavations of a road to relocate features of

Heritage value. Lastly it was notable that during the baseline assessment no Red Data listed

vegetation species and no species that are protected under provincial legislation nor by the

National Forests Act were observed on site. Protected faunal species were not directly

observed on site and have at most, a low probability of occurrence, largely due to the effects

of habitat fragmentation.

As part of the development design of the Erasmuskloof Retail Centre complex and in

consideration of the ROD issued by the competent authority, the proposed development

underwent an iterative process to redesign the proposed development to reduce the impact

on the Medium-High sensitivity grassland. The Figures below present the previous two

iterations of the layout plan overlayed over the ecological sensitivities of the proposed

development site. Between the layout as presented in Figure 6 and figure 7 it is clear that the

proponent attempted to avoid and minimise the impact on the receiving environment as far as

possible. This layout was then further optimised in consultation with the ecologists to increase

the open space to be retained, conserved and managed as part of the proposed development.

This layout has been used in the further analyses of the project with the results presented from

Figure 8 onwards.

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Figure 6: Layout Version 1 of the Erasmuskloof Retail Centre.

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Figure 7: Layout Version 2 of the Erasmuskloof Retail Centre.

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5.2 Site Assessment Results

Given the above information gleaned from the relevant databases and given the findings made

by Exigo both during 2016 and 2018 it was deemed important to consider and define primary

vegetation associated with the Medium-High sensitivity areas.

According to SANBI (2013)1, primary grassland can be defined as “those that have not been

significantly modified from their original state; even though they may no longer have their full

complement of naturally-occurring species, they have not undergone significant or irreversible

modification and still retain their essential ecological characteristics.”

During the field assessment focus was placed on the areas previously defined as being of

Medium- High ecological importance and sensitivity. A micro-mapping exercise was

undertaken in this area to refine the extent of the primary grassland and also in order to

determine the degree of continuity of the intact vegetation.

The results of the micro-mapping yielded the following results. These results are supported by

the findings of Exigo (2016) and Galago (2018):

1. The area is not a ridge and, at most, can be defined as a rocky outcrop. However, the

best description is considered to best rocky grassland which, in small areas, can be

considered intact.

2. Due to historical anthropogenic activity in the area, including agriculture, development

of roadways (Notably the M28 and Bayside Rd as well as the N1, R21 and Solomon

Mahlangu drive further afield) dumping as well as development of residential dwellings,

the grassland and in particular the primary grassland has been isolated and thus the

small remaining extent on the subject property is under greater threat from the

surrounding agents of change;

3. An informal road has been developed through the middle of the area during the Phase

2 Heritage project. In order to develop the road a significant amount of material was

imported to create a level road surface on the sloping terrain. This disturbance has

additionally led to the proliferation of alien invasive species and in particular Tagetes

minuta (khaki weed).

4. Isolated areas of substantial building rubble dumping are scattered throughout the

Medium-High sensitivity area. In these areas habitat disturbance is significant and

1 SANBI. 2013. Grasslands Ecosystem Guidelines: landscape interpretation for planners and managers. Compiled by Cadman, M., de Villiers, C., Lechmere-Oertel, R. and D. McCulloch. South African National Biodiversity Institute, Pretoria.

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proliferation of alien invasive species and in particular Tagetes minuta (khaki weed)

has occurred;

5. In relatively extensive areas, transformation of the vegetation has occurred and in

these areas the vegetation can no longer be defined as primary grassland. In some of

these areas Hyparrhenia hirta has become dominant forming pockets of pseudoclimax

grassland;

6. Numerous footpaths and informal tracks occur throughout the area, which although

not particularly severe, do fragment the primary grassland; and

7. These results of the micro-mapping are presented in figure 8 below followed by the

results with the proposed development overlaid in Figures 9 and 10 (overall view) and

Figures 11 and 12 (zoomed in view).

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Figure 8: Sensitivity analysis of the Erasmus Park Township Development Area.

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Figure 9: The proposed Development overlaid over revised map after micro-mapping.

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Figure 10: The proposed Development overlaid over revised map after micro-mapping and zoomed to the area of concern.

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Figure 11: The proposed Development overlaid over revised map after micro-mapping and zoomed to the area of concern.

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6. DATA ANALYSES

Based on the results of the field assessment and in consideration of the GIS databases,

several important statistical observations can be made:

1. The development of the majority of the site, even though defined as a CBA, has

already been approved in terms of the existing authorisation for development excluding

the medium high sensitivity area as defined by Exigo (2016). Refer to the dark orange

(remaining medium high sensitivity grasslands) and grey areas (disturbed medium

high sensitivity grasslands mapped as part of this study) in Figures 8 and 9 (overall

view) and Figures 10 and 11 (zoomed in view) which indicates the combined extent of

the medium high sensitivity grasslands of Exigo (2016). The results of this study

indicate that portions of this medium high sensitivity area can be considered for

development as set out below:

2. The total extent of primary Vegetation as Per Exigo (2016) is 6.298 ha. Refer to the

combined dark orange and grey areas in Figures 8 and 9 (overall view) and Figures

10 and 11 (zoomed in view);

3. After the micro mapping exercise undertaken as part of this study to exclude areas

which no longer function as true primary grassland, the remaining extent of primary

grassland (Medium high sensitivity) is 2.207ha. Refer to the dark orange areas in

Figures 8 and 9 (overall view) and Figures 10 and 11 (zoomed in view).

4. Of the 6.298 ha mentioned in 2 above 4.091 ha has been disturbed to such a degree

that it no longer functions as primary grassland and can, at best, be considered of

moderate sensitivity. This represents a 65% loss of medium high sensitivity area from

that mapped in 2016 by Exigo. Refer to the grey areas in Figures 8 and 9 (overall view)

and Figures 10 and 11 (zoomed in view). Also refer to the footpaths presented as black

lines in Figure 8;

5. It must be noted that the remaining extent of the primary grassland is significantly

fragmented with the largest relatively contiguous extent being 1.15 ha. Refer to Figures

8 and 9 (overall view) and Figures 10 and 11 (zoomed in view). It is furthermore notable

that even then, this area is fragmented by footpaths which may lead to further creation

of nodes of alien vegetation dispersal. Refer to figure 8;

6. The proposed development within the medium high sensitivity area will lead to a loss

of 1.988 ha (31.6%) of medium high sensitivity grassland as mapped by Exigo (2016).

Refer to the dark orange and grey areas in Figures 8 and 9 (overall view) and Figures

10 and 11 (zoomed in view); However:

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7. The proposed development will lead to the loss of 1.102 ha of currently functional

primary grassland which equates to 17.5% of the extent of medium high sensitivity

grassland as defined by Exigo (2016) Refer to the dark orange areas in Figures 8 and

9 (overall view) and Figures 10 and 11 (zoomed in view);

8. This is a significant decrease from what was proposed with the original submission

where the medium high sensitivity grassland was impacted substantially more in terms

of extent than the current revised layout. See Figure 6;

9. 74.4% of the development within the medium high sensitivity habitat as mapped by

Exigo (2016) will be located in areas which are no longer functioning as primary

grassland (grey areas). Without intervention these areas will slowly degrade further

and lead to edge effects on the adjacent grassland. Only a small portion of the overall

development footprint (25.6% of the development area within the originally mapped

medium sensitivity grassland) occurs in areas where functional primary grassland is

currently still established;

10. As part of the revised layout the open space areas, which extend beyond the medium

high sensitivity grasslands mapped by Exigo (2016) will be managed and conserved.

Refer to Figure 12 (Green hatched areas). It is possible to create two contiguous areas

totalling 6.4ha of managed and rehabilitated grassland and wetland habitat. These two

areas will be connected with culverts to ensure faunal movement under the road can

take place with a fence to prevent fauna moving over the road and being at risk of

roadkill. Furthermore, these open space areas will also be connected to the open

space along the watercourse which extends as far as the pit-lake adjacent to the N1.

Refer to Figure 1.

11. In addition to the remaining medium high sensitivity Grasslands within the planned

open space area (1.5 ha) as mapped (dark orange) as part of this investigation a further

3.5 ha of grassland will be rehabilitated along with 1.4 ha of wetland within the open

space area;

12. With the rehabilitation of the total area of 6.4ha of grassland there will be a 48.8% gain

in grassland habitat in relation to the 4.3 ha of grassland lost as mapped by Exigo

(2016);

13. The additional areas that will be rehabilitated back to an analogous condition to primary

grassland (green hatched areas in Figure 12) will lead to a 4.5X gain in area in relation

to the 1.102 ha of primary vegetation that will be lost as a result of the development

within the currently functional medium high sensitivity habitat (dark orange) in Figures

8 and 9 (overall view) and Figures 10 and 11 (zoomed in view);

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14. If rehabilitation and management is correctly undertaken this will lead to a net gain to

biodiversity conservation in relation to the loss of the current extent of primary

grassland; and

15. Please refer to the management and mitigation measures presented below to assist in

executing this strategy.

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Figure 12: Sensitivity analysis of the Erasmuskloof Retail Centre Development Area.

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7. CONCLUSION AND RECOMMENDATIONS

The medium high sensitivity area mapped by Exigo (2016) is not a ridge and at most can be

defined as a rocky outcrop. However, the best description is considered to best rocky

grassland which, in areas, can be considered intact. Given the analyses of the available

databases, the baseline study by Exigo (2016) and subsequent Technical Memo of Exigo

(2018), the grassland was defined as a CBA important area, as being of Medium-High

sensitivity was further refined through a micro-mapping exercise. The remaining primary

grasslands (2.2 ha) are in good condition but do not host any particularly sensitive faunal or

floral assemblages (based on Field work by Exigo (2016), Galago (2018) and in the current

assessment by SAS). It was further noted that the remaining primary grassland has been

significantly fragmented with the largest contiguous extent being 1.15ha in extent, which

reduces the overall ecological importance and sensitivity of the area and also weighs on the

overall sensitivity of the area. Furthermore, the various disturbances have formed numerous

nodes of distribution for alien and invasive species as well as less desirable grassland species.

These findings are supported by Exigo (2018 and Galago (2018).

Given the above, the long-term viability of the primary grassland in the area is questionable

and exclusion from development is unlikely to yield the envisaged outcome of grassland

conservation. This conclusion supports the conclusion of (Exigo 2016) which was re-iterated

in Exigo (2018) and Galago (2018). It is however acknowledged that primary grasslands are

important ecological features to be conserved. The proponent has already undertaken detailed

investigations to avoid and minimise impacts on the intact grassland. In addition to the

remaining medium high sensitivity Grasslands within the planned open space area (1.5 ha) as

mapped (dark orange) as part of this investigation a further 3.5 ha of grassland will be

rehabilitated along with 1.4 ha of wetland within the open space area. With the rehabilitation

of the total area of 6.4ha of grassland there will be a 48.8% gain in grassland habitat in relation

to the 4.3 ha of grassland lost as mapped by Exigo (2016). The additional areas that will be

rehabilitated back to an analogous condition to primary grassland (green hatched areas in

Figure 12) will lead to a 4.5X gain in area in relation to the 1.102 ha of primary vegetation that

will be lost as a result of the development within the currently functional medium high

sensitivity habitat.

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In line with the mitigation hierarchy as defined by the Department of Environmental Affairs

(DEA), it is therefore recommended that the following take place:

1. The proposed development which has been redesigned and optimised, including a

reduced overall footprint, to avoid and minimise the impact on grassland which is in

good condition be permitted to proceed provided that:

a. The entire south western corner of the property must be rehabilitated to return

the area to a more natural condition free of alien and invasive vegetation and

less desirable grassland species. The objective should be to return the area to

a state similar to the primary grasslands and natural wetland vegetation types

typical of the area it is possible to create two contiguous areas of 1.234ha in

the north and 4.344 in the south ha totalling 6.4ha of managed and rehabilitated

open space which will also be connected to the open space along the

watercourse which extends as far as the pit-lake adjacent to the N1. In order to

protect this area, the proponent will:

i. Fence off the area with a palisade fence,

ii. Develop a detailed rehabilitation plan for the open space area which

must be approved by the competent authority;

iii. Rehabilitate the area and ensure that funding and other resources are

available to manage the area for a minimum of 30 years;

iv. Having sufficient fire management infrastructure present to prevent

excessive fire damage; and

v. The overall management of the area must be overseen by an

appropriately qualified and experienced ecologist

b. Culverts must be placed at 15m intervals under the road to allow movement of

faunal species under the road to join the two areas of planned open space and

these culverts must span the entire length of the road where open space will

be present on both sides of the road. The culverts must be at least 1m wide

and 30cm high.

2. Should the above options be deemed insufficient, from a conservation perspective, the

entire area within the wetland buffer zone north of the wetland as well as the entire

area to the south of the wetland up to the road should be rehabilitated as a green

corridor. The objective should be to return the area to a state similar to the primary

grasslands and natural wetland vegetation types typical of the area; and

3. Should this approach be approved, the designated open space area should be set up

as a conservation area and must have a conservation servitude registered over it and

sterilised from development for a minimum of 99 years. Furthermore, active

management of the open space area must be managed for a minimum of 30 years. It

SAS 218069 May 2018

26

is the intention of the proponent to enter into a maintenance agreement with the

Tshwane Municipality to undertake the management of any designated public open

space to ensure that the area is rehabilitated and maintained in an ecologically

functional manner analogous to the primary grassland areas and natural wetland

conditions of the area without such requirements becoming burdensome to the

municipality.

We trust that this short technical report assists in finding the balance between the need for

conservation and economic development as enshrined in the principles of sustainable

development as supported by Section 24 of the Constitution of South Africa.

SAS 218069 May 2018

27

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