dea ref no: 12/12/20/2085/3 report on proposed … ukomeleza wef ea... · 1 introduction ......

EOH Coastal & Environmental Services i InnoWind (Pty) Ltd

UKOMELEZA WIND ENERGY FACILITY

INNOWIND (PTY) LTD

NELSON MANDELA BAY METROPOLITAN MUNICIPALITY, EASTERN CAPE PROVINCE OF SOUTH AFRICA

DEA Ref No: 12/12/20/2085/3

REPORT ON PROPOSED AMENDMENTS TO THE ENVIRONMENTAL AUTHORISATION

Prepared for:

InnoWind (Pty) Ltd.

PO Box 1116 Port Elizabeth, 6000

South Africa

Prepared by:

EOH Coastal & Environmental Services

67 African Street Grahamstown

6139

www.cesnet.co.za

Draft

May 2016

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

EOH Coastal & Environmental Services i InnoWind (Pty) Ltd

EOH Coastal & Environmental Services

Report Title: Report on Proposed Amendment to the Environmental Authorisation Report Version: Draft for Public Review and Comment Project Number: 288

Name Responsibility Date

Craig Sholto-Douglas Drafting Report May 2016

Caroline Evans Contributing Author and Reviewer

May 2016

Copyright This document contains intellectual property and proprietary information that are protected by copyright in favour of EOH Coastal & Environmental Services (CES) and the specialist consultants. The document may therefore not be reproduced, used or distributed to any third party without the prior written consent of CES. The document is prepared exclusively for submission to the Client, and is subject to all confidentiality, copyright and trade secrets, rules intellectual property law and practices of South Africa.

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EOH Coastal & Environmental Services ii InnoWind (Pty) Ltd

TABLE OF CONTENTS

1 INTRODUCTION ....................................................................................................................................... 1 2 LISTED ACTIVITIES: 2010 COMPARED WITH 2014 ............................................................................. 3 3 DETAILS OF PROPOSED AMENDMENTS ............................................................................................. 7

3.1 First amendment: – Increase the size of the turbines and components. ......................................... 7 3.2 Second Amendment: - Increase the width of the access road......................................................... 7 3.3 Third amendment: - Changing the foundation specifications of the Environmental Authorisation. . 7 3.4 Fourth amendment: - An increase in the validity of the Environmental Authorisation ............. Error!

Bookmark not defined. 3.5 Fifth amendment: - Amend the property description ....................... Error! Bookmark not defined.

4 ENVIRONMENTAL IMPACTS ASSOCIATED WITH AMENDMENTS .................................................... 9 4.1 Introduction ....................................................................................................................................... 9 4.2 Specialist Opinions and Comment ................................................... Error! Bookmark not defined.

5 PUBLIC PARTICIPATION PROCESS ................................................................................................... 15 5.1 Public participation methodology ................................................................................................... 15 5.2 Comments and issues raised by I&APs ........................................... Error! Bookmark not defined.

6. CONCLUSIONS AND RECOMMENDATION ......................................................................................... 17

LIST OF FIGURES

Figure 1-1: The proposed layout of the Coega Wind Farm which received Environmental Authorisation

(REF: 12/12/2085) in August 2011. ............................................................... Error! Bookmark not defined. Figure 1-2: The proposed layout of the Ukomeleza WEF which received Environmental Authorisation

(REF: 12/12/2085/3) in March 2013. ............................................................................................................. 2

LIST OF TABLES

Table 2-1: Authorised listed activities (Amended EA dated 28th March 2013) .............................................. 3 Table 2-2: Applicable listed activities from GNs published on 8th December 2014Error! Bookmark not

defined.

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EOH Coastal & Environmental Services iii InnoWind (Pty) Ltd

LIST OF APPENDICES Appendix A: Ecological Specialist (EOH-CES)

Ms Tarryn Martin Specialist Opinion Letter

Appendix B: Avifaunal Specialist (Endangered Wildlife Trust) Full Bird Monitoring and Impact Assessment based on specifications set in this report

Appendix C: Bat Specialist (Animalia) Mr Werner Conradie Full Bird Monitoring and Impact Assessment based on specifications set in this report

Appendix D: Noise (Safetech) Dr Brett Williams Specialist Opinion Letter

Appendix E: Visual Specialist (EOH-CES) Mr Thomas King Specialist Opinion Letter

Appendix F: Letter from the MEC

Appendix G: Conservation Initiative: Alien Management Plan Ms Tarryn Martin

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EOH Coastal & Environmental Services 1 InnoWind (Pty) Ltd

1 INTRODUCTION An Environmental Impact Assessment (EIA) was conducted by Coastal and Environmental Services (CES) for the proposed establishment of a wind farm at Coega and its associated infrastructure (Figure 1-1). This report describes and discusses the application for amendments to the environmental authorisation (EA) for the Ukomeleza Wind Energy Facility (WEF) and its associated infrastructure (REF: 12/12/20/2085/3), within the Nelson Mandela Bay Metropolitan Municipality, Eastern Cape Province. The Ukomeleza WEF is proposed to be established on Portion 1 of Farm 190 and RE of Farm 190, and is expected to create a total footprint of 4.3 ha (Figure 1-2). The environmental authorisation for the Ukomeleza facility consists of the following project infrastructure components:

1) Maximum output of approximately 24 Mega Watts 2) 8 turbines and each turbine will consist of approximately 100m high steel tower and nacelle,

a rotor of approximately 100m diameter consisting of 3 blades and each blade approximately 50m long;

3) Each turbine will be connected to the Grassridge and/or Olifantskop substations via underground cables of approximately 22 kV;

4) An overhead power line (132kV distribution line) feeding into the electricity distribution network/grid; and

5) Concrete foundations of approximately 20m² and 3m deep. 6) Construction of an access road to the proposed Grassridge wind farm. The access road will

be approximately 4m wide.

The environmental authorisation for the proposed development includes the excavation of topsoil and the backfilling of trenches. All the disturbed areas will be rehabilitated after construction using locally indigenous vegetation. Fuel (petrol and diesel) will be temporarily stored on site on a portion of the construction camp. The contractor will ensure that diesel and petrol is stored in appropriate storage tanks. The storage tanks will be situated on a smooth impermeable surface (concrete) with a permanent bund. These structures will be removed upon completion of construction activities. The motivation for the proposed project in general terms arose from the following potential benefits:

Increased electrical input into the grid;

Employment creation;

The purchase of materials from local businesses where available;

Access to cleaner energy; and

Participation in the renewable energy procurement process that has been put in place by the Department of Energy.

The amendments to the environmental authorisation which are being applied for include:

an increase in turbine height; an increase in blade size;

the incorporation of steel into the concrete foundations;

an increase in the size of the foundations;

an increase in width of the access road;

and an increase in output of the WEF

Details of the proposed amendments and layout of the WEF can be found in chapter 3 of this report.

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Figure 1-2: The proposed layout of the Ukomeleza WEF which received Environmental Authorisation (REF: 12/12/2085/3) in March 2013. :

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2 LISTED ACTIVITIES: 2010 COMPARED WITH 2014 Table 2.1 shows the listed activities applicable to the project that was authorised in EA dated 28th of March 2013. Table 2.2 shows the listed activities from the EIA Regulations published on 4th December 2014 that are applicable to the project. Table 2-1: Authorised listed activities (Amended EA dated 28th March 2013)

Authorised listed activities Equivalent Listings in 2014 regulations

Activity No(s)

Description of listed activity Activity No(s)

Description of listed activity

Number and date of the relevant notice Number and date of the relevant notice

GN No R.544 (2010) GN No R.983 (2014)

Item 1 “The construction of facilities or infrastructure for the generation of electricity where:

i) The electricity is more than 10 megawatts but less than 20 megawatts; or

ii) ii) The output is 10 megawatts or less but the total extent of the facility covers an area in excess of 1 hectare”

Item 1 “The development of facilities or infrastructure for the generation of electricity from a renewable resource where- (i) the electricity output is more than 10 megawatts but less than 20 megawatts; or (ii) the output is 10 megawatts or less but the total extent of the facility covers an area in excess of 1 hectare; excluding where such development of facilities or infrastructure is for photovoltaic installations and occurs within an urban area.

Item 10 “The construction of facilities or infrastructure for the transmission and distribution of electricity – (i) outside urban areas or industrial complexes with a capacity of more than 33 but less than 275 kilovolts”

Item 11

“The development of facilities or infrastructure for the transmission and distribution of electricity – (i) outside urban areas or industrial complexes with a capacity of more than 33 but less than 275 kilovolts”

Item 18 “The infilling or depositing of any material of more than 5 cubic metres into, or the dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock or more than 5 cubic metres from: (i) a watercourse; (ii) the sea; (iii) the seashore; (iv) the littoral active zone, an estuary or a distance of 100 metres inland of the highwater mark of the sea or an estuary, whichever distance is the greater but excluding where such infilling, depositing , dredging, excavation, removal or moving; (a) is for maintenance purposes undertaken in accordance with a management plan agreed to by the relevant environmental authority; or (b) occurs behind the development setback line”.

Item 19

“The infilling or depositing of any material of more than 5 cubic metres into, or the dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock or more than 5 cubic metres from:

(i) a watercourse; (ii) (ii) the seashore; or (iii) (iii) the littoral active zone, an

estuary or a distance of 100 metres inland of the high-water mark of the sea or an estuary, whichever distance is the greater

But excluding where such infilling, depositing , dredging, excavation, removal or moving- (a) will occur behind a development setback; (b) is for maintenance purposes undertaken in accordance with a maintenance management plan; or (c) falls within the ambit of activity 21 in this Notice, in which case that activity applies”.

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Activity No(s)



Item 23 “The transformation of undeveloped, vacant or derelict land to – (i) residential, retail, commercial, recreational, industrial or institutional use, inside an urban area, and where the total area to be transformed is 5 hectares or more, but less than 20 hectares, or (ii) residential, retail, commercial, recreational, industrial or institutional use, outside an urban area and where the total area to be transformed is bigger than 1 hectare but less than 20 hectares; - [except where such transformation takes place for linear activities]”.

Item 27

“The clearance of an area of 1 hectares or more, but less than 20 hectares of indigenous vegetation, except where such clearance of indigenous vegetation is required for-

(i) the undertaking of a linear activity; or

(ii) (ii) maintenance purposes undertaken in accordance with a maintenance management plan”.

Item 38 “The expansion of facilities for the transmission and distribution of electricity where the expansion capacity will exceed 275 kilovolts and the development footprint will increase”

Item 47

“The expansion of facilities for the transmission and distribution of electricity where the expansion capacity will exceed 275 kilovolts and the development footprint will increase”

GN No R.545 (2010)

GN No R.984 (2014)

Item 1 “The construction of facilities or infrastructure for the generation of electricity where the electricity output is 20 megawatts or more”

Item 1

“The development of facilities or infrastructure for the generation of electricity from a renewable resource where the electricity output is 20 megawatts or more, excluding where such development of facilities or infrastructure is for photovoltaic installations and occurs within an urban area.”

Item 8 “The construction of facilities or infrastructure for the transmission and distribution of electricity with a capacity of 275 kilovolts or more, outside an urban area or industrial complex”

Item 9

“The development of facilities or infrastructure for the transmission and distribution of electricity with a capacity of 275 kilovolts or more, outside an urban area or industrial complex”

Item 15 “Physical alternation of undeveloped, vacant or derelict land for residential, retail, commercial, recreational, industrial or institutional use where the total area to be transformed is 20 hectares or more”

Item 15

“The clearance of an area of 20 hectares or more of indigenous vegetation, excluding where such clearance of indigenous vegetation is required for- (i) the undertaking of a linear activity; or (ii) maintenance purposes undertaken in accordance with a maintenance management plan”.

GN No R.546 (2010) GN No R.985 (2014)

Item 4 “The construction of a road wider than 4 metres with a reserve less than 13,5 metres

(a) In Eastern Cape: ii. All areas outside urban areas”

4

“The development of a road wider than 4 metres with a reserve less than 13,5 metres (b) In Eastern Cape: ii. Outside urban areas, in: (ee) Critical biodiversity areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional plans;

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Activity No(s)



Item 12 “The clearance of an area of 300 square metres or more of vegetation where 75% or more of the vegetative cover constitutes indigenous vegetation.

(a) 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;

(b) Within critical biodiversity areas identified in bioregional plans;

(c) Within the littoral active zone or 100 metres inland from high water mark of the sea or an estuary, whichever distance is the greater, excluding where such removal will occur behind the development setback line on erven in urban areas”.

12

“The clearance of an area of 300 square metres or more of indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan. (a) In Eastern Cape 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 identified in bioregional plans; iv. 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”.

Item 13 “The clearance of an area of 1 hectare or more of vegetation where 75% or more of the vegetative cover constitutes indigenous vegetation

(a) Critical biodiversity areas and ecological support areas as identified in systematic biodiversity plans adopted by the competent authority.

(b) In the Eastern Cape: iii. In urban areas, the following:

(bb) Areas designated for conservation use in Spatial Development Frameworks adopted by the competent authority or zoned for a conservation purpose.”

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Activity No(s)



Item 14 “The clearance of an area of 5 hectares or more of vegetation where 75% or more of the vegetative cover constitutes indigenous vegetation, except where such removal of vegetation is required for:

(a) purposes of agriculture or afforestation inside areas identified in spatial instruments adopted by the competent authority for agriculture or afforestation purposes;

(b) the undertaking of a process or activity included in the list of waste management activities published in terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in which case the activity is regarded to be excluded from this list;

(c) the undertaking of a linear activity falling below the thresholds in Notice 544 of 2010”.

Item 19 “The widening of a road more than 4 metres, or the lengthening of a road by more than 1 kilometre”.

18

“The widening of a road more than 4 metres, or the lengthening of a road by more than 1 kilometre, ii. Outside urban areas, in: (ee) Critical biodiversity areas as identified in systematic biodiversity plans adopted by the competent authority or in bioregional, plans;

Item 26 “Phased activities for all activities listed in this Schedule and as it applies to a specific geographical area, which commenced on or after the effective date of the Schedule, where any phase of the activity may be below a threshold but where a combination of the phases, including expansions or extensions, will exceed a specific threshold”.

26

“Phased activities for all activities listed in this Schedule and as it applies to a specific geographical area, which commenced on or after the effective date of the Schedule, where any phase of the activity may be below a threshold but where a combination of the phases, including expansions or extensions, will exceed a specific threshold”.

No additional triggers were identified

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3 DETAILS OF PROPOSED AMENDMENTS An amendment is applied for in terms of Chapter 5, Part 2 under the National Environmental Management Act, 1998 (Act No. 107 of 1998), as amended, and the Environmental Impact Assessment Regulations 2014. 3.1 First amendment: – Increase the size of the turbines and components. Page 5 of the EA, bullet point 2 currently reads: “8 wind turbines and each turbine will consist of approximately 100m high steel tower and nacelle, a rotor of approximately 100m diameter consisting of 3 blades and each blade is approximately 50m long” AMEND to read: “8 wind turbines and each turbine will consist of approximately 137m high steel tower and nacelle, a rotor of approximately 132m diameter consisting of 3 blades and each blade is approximately 62m long” Motivation for amendment Since the amended Environmental Authorisation which was issued on the 28th March 2013, renewable energy and more specifically the harvesting of wind energy has developed into a highly global industry. The growth of the industry has allowed for vast amounts of research and technological advancement with regard to the components and models of turbines. The requested increase in the size of the turbines and associated components is to accommodate more technically advanced and efficient turbine models. 3.2 Second Amendment: - Increase the width of the access road Page 5 of the EA, bullet point 6 currently reads: “Construction of an access road to the proposed Grassridge wind farm. The access road will be approximately 4m wide” AMEND to read: “Construction of an access road to the proposed Grassridge wind farm. The access road will be approximately 8m wide” Motivation for amendment The requested increase in width of the access road is to accommodate the transportation of the larger turbine components onto the proposed project site. As there are many Wind Energy Facilities within the proposed project area, the increased width of the road will also reduce congestion and increase the safety of road users and maintenance vehicles, especially between the Ukomeleza and Grassridge Wind Energy Facilities. 3.3 Third amendment: - 3. Include cement turbine foundations in the specifications of

the Environmental Authorisation Page 5 of the EA, bullet 2 currently reads:

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“8 wind turbines and each turbine will consist of approximately 100m high steel tower and nacelle, a rotor of approximately 100m diameter consisting of 3 blades and each blade is approximately 50m long” AMEND to read: “26 wind turbines and each turbine will consist of approximately 137m high steel or cement tower and nacelle, a rotor of approximately 132m diameter consisting of 3 blades and each blade is approximately 62m long” Motivation for amendment The incorporation of cement as an option of the tower material will allow this part of the turbine to be manufactured locally. This will reduce the cost of each turbine and will create local employment opportunities. 3.4 Fourth amendment: - Increase the size of the turbine foundations in the

Environmental Authorisation Page 5 of the EA, bullet 4 currently reads: “Concrete foundations of approximately 20m2 and 3m deep” AMEND to read: “Concrete foundations of approximately 25m2 and 3m deep” Motivation for amendment The increase in the depth and incorporation of steel into the turbine foundations is required to reinforce and support the larger turbine models. 3.5 Fifth amendment: - Increase the output of the Wind Energy Facility Page 5 of the EA, bullet 1 currently reads: “Maximum output of approximately 24 Mega Watts” AMEND to read: “Maximum output of approximately 28 Mega Watts” Motivation for amendment The original turbine specifications are now outdated and new technology allows for larger turbines (as assessed in this report). It is therefore requested that the output be increased to allow for a greater generation output to accommodate the larger turbine models.

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4 ENVIRONMENTAL IMPACTS ASSOCIATED WITH AMENDMENTS 4.1 Introduction EOH Coastal & Environmental Services has identified the following negative environmental impacts that may occur if the application for amendment is granted:

The larger turbines will have an additional visual impact (of a small scale) which will require specialist input;

the amendment to authorisation could increase the noise generation depending on the outcome of the specialist input;

the potential increased impacts on birds and bats has already been assessed in the bird and bat monitoring and assessment reports as these assessments were only completed at the end of 2014 and already contain the turbine specifications outlined in this amendment report; and

the increase in the width of the road requires ecological specialist input to identify if sensitive habitats and vegetation types will be affected by the expansion of the proposed access road.

If the amendments to the Environmental Authorisation are granted, certain negative impacts may adversely affect the rights and interests of all interested and affected parties (IAPs). Therefore, notification of the modification to the turbines will be sent out to all IAPs for comment. The notification will include all increased specifications along with specialist opinion letters indicating any changes to specified impacts, these specialists include:

Visual Impact Specialist

Noise Impact Specialist

Avifaunal Impact Specialist

Bat Impact Specialist

Ecological Impact Specialist. 4.2 Assessment of all impacts related to the proposed amendments As the majority of the potential negative impacts assessed above require specialist input, the following section includes the relevant specialist’s opinion and comment on the proposed amendments. Each of the specialists undertook a study, either quantitative or qualitative, of the proposed project changes in order to identify the risks associated with: an increase in turbine height; an increase in blade size; the incorporation of concrete? into the steel foundations; and an increase in width of the access road. The conclusions are set out in the letters in Appendices A to E, and are summarised here.

AMENDMENT SPECIALISTS RELEVANCE

1. Increase the size of the turbines and components

- Ecological Specialist - Avifaunal Specialist - Bat Specialist - Noise Specialist - Visual Specialist

(n/a)

2. Increase the width of the access road


(n/a) (n/a)

3. Include cement turbine foundations in the specifications of the Environmental Authorisation

- Ecological Specialist - Avifaunal Specialist - Bat Specialist - Noise Specialist

(n/a) (n/a) (n/a)

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- Visual Specialist (n/a)

4. Increase the size of the turbine foundations in the Environmental Authorisation


(n/a) (n/a) (n/a) (n/a)

5. Increase the output of the Wind Energy Facility


(n/a) (this relates directly to the increase in turbine specifications)

4.2.1 Ecological Specialist Opinion

Original report compiled by: Coastal & Environmental Services

Comment for amendment report received by: Tarryn Martin from EOH Coastal & Environmental Services

The Ecological Specialist assigned to the original EIA was from Coastal and Environmental Services. Ms Martin provided a letter with her specialist opinion on the potential effects of the proposed changes to the wind turbine specifications. Refer to the attached letter in Appendix A. According to the specialist opinion, the increased height of the nacelle and blades and addition of steel in the concrete foundation will not increase the footprint of the turbine and will therefore have no additional direct impacts on the vegetation and faunal species already been assessed. The increase in the width of the road from 4m to 8m during the construction phase will result in the clearance of an additional 2.6 ha of Grassridge Bontveld. Although additional clearing will occur, this loss of vegetation is relatively small (0.12%) and is unlikely to result in a significant increase in the rating of the assessed impact provided the mitigation measures suggested in the ecological report are implemented. The client has indicated they intend to rehabilitate the road to a width of 5m during the operation phase. With successful rehabilitation, the total loss of vegetation will only be 0.6ha. It is important to note that the Ukomeleza WEF (part of the original Coega WEF) was authorised on a private nature reserve. The nature reserve did not have a conservation management plan and has not been treated as a conservation entity in decades. This nature reserve has since been de-proclaimed (October 2015) and InnoWind has committed to the conservation of the area through the funding of an alien invasive conservation and management plan. This initiative includes the removal of alien vegetation and the rehabilitation of affected areas through the incorporation of the social initiative known as working for water. This initiative will involve the conservation of the de-proclaimed area while ensuring that members of the community are empowered through skills development. Please refer to Appendix F for the letter from the MEC and Appendix G for the Alien Management Plan. 4.2.2 Avifauna (birds)

Report compiled by: the Endangered Wildlife Trust in 2014 based on the turbine specifications outlined in this amendment report.

A 12 month pre-construction monitoring program has been conducted by the Endangered Wildlife Trust subsequent to the EIA process. Please refer to Appendix B.

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4.2.3 Chiroptera (bats)

Report compiled by: Mr Werner Conradie from Animalia Zoological and Ecological Consulting based on the turbine specifications outlined in this amendment report.

A 12 month pre-construction monitoring program has been conducted by Animalia Zoological and Ecological Consulting subsequent to the EIA process. Please refer to Appendix C. 4.2.4 Noise

Original report compiled by: Dr Brett Williams from Safetech

Comment for amendment report received by: Dr Brett Williams from Safetech The specialist has remodelled the change in hub and rotor height and the change in noise impact on the receptors is negligible. The change in scope will thus not cause any additional noise impacts and the overall significance of the noise impact will remain the same as the noise impact assessment previously submitted. 4.2.5 Visual

Original report compiled by: Mr A. McMaster

Comment for amendment report received by: Mr Thomas King from EOH Coastal & Environmental Services

The Visual Impact Assessment for the original EIA was carried out by Mr Alistair McMaster. Mr McMaster now works for the provincial Department of Economic Development, and thus could no longer be approached for comment. Mr Thomas King, the visual impact specialist for EOH CES, provided a specialist opinion on the potential visual impacts by the proposed changes to the wind turbine specifications. Please refer to Appendix E for the specialist letter. According to the specialist, the Visual Impact Assessment for the original Coega Wind Farm, made the following points and conclusions:

The landscape character of the region is a mixture of industrial and urban development, and agricultural land. The proposed wind farm is located in a low landscape character sensitivity area and surrounded by landscapes of low to moderate sensitivity to change brought on by the introduction of a wind farm. (Page i).

There are no recognised viewpoints protected for their scenic quality in the region. (Page i).

Residents of a couple of nearby settlements such as Motherwell and Wells Estate will have a high visual exposure to the development due to their proximity to the wind farm. (Page i).

High visual exposure is expected for the Swartkops Valley Local Nature Reserve. The GAENP and three islands off Coega River mouth will have a low visual exposure (Page i).

The landscape into which the wind farm will be introduced is in close proximity to large industrial and urban centres. Wind turbines will not be out of place in such a metropolitan setting. (Page i).

Viewsheds were modelled based on a 180 metre high wind turbine model (base to blade tip). With the new heights proposed, turbines will be 23 metres taller at the blade tip. The Ukomeleza turbines are, on average:

17 kilometres from the centre of Motherwell;

19 kilometres from the Swartkops Valley Local Nature Reserve;

22.5 kilometres from the centre of Wells Estate. At these distances, the visual exposure of these sensitive receptors will be negligible. The reason that these conclusions were reached for the original Coega Wind Farm was because turbines were located farther to the south and much closer to these identified sensitive areas.

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Based on the above, it is the specialists opinion that the proposed increase in the heights of the eight wind turbines will not significantly alter the impact significance of the turbines. 4.3 Advantages and disadvantages associated with the proposed amendments

AMENDMENT ADVANTAGES DISADVANTAGES


- The increase in the size of the turbines will allow the new and improved technology to be used in the construction of the wind energy facility.

- Possible negative environmental impacts including impacts on birds, bats, noise and the visual aspect have been assessed in this report and have been found to have no additional significant impacts.


- The increase in the width of the road will facilitate the transportation of the turbine parts onto the site. The larger turbines will need larger vehicles for transportation.

- Possible negative environmental impacts include the loss of vegetation which has been assessed by the ecological specialist in this report. No significant additional impacts were found during the additional assessment for this report.


- The use of cement turbines will allow a large section of the turbine structure to be produced locally which will decrease the carbon footprint of the transportation cost involved in the development of the wind farm.

- None


- The increase in the size of the turbine foundation will facilitate the construction of turbines with a new and improved technology.

- Possible negative environmental impacts include the loss of vegetation which has been assessed by the ecological specialist in this report. No significant additional impacts were found during the additional assessment for this report.

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- The increase in the output of the wind energy facility will allow a higher electricity output which will improve the energy benefits from the wind farm. The increased energy output will also facilitate the use of new and improved wind technology.

- None

4.4 Measures to ensure avoidance, management and mitigation of impacts associated

with the proposed amendments The following table summarises the recommendations made by the specialists in their opinion letters as per the information summarised above. This section relates specifically to any additional mitigation measures and avoidance techniques which must be applied based on the specialist input.

PROPOSED AMENDMENT

SPECIALIST AVOIDANCE/MANAGEMENT/ MITIGATION



- No additional mitigation measures - No additional mitigation measures - No additional mitigation measures - No additional mitigation measures - No additional mitigation measures













4.5 Changes to the EMPr based on the proposed amendments

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The following table summarises any recommendations made by the specialists in their opinion letters as per the information summarised above. This section relates specifically to any changes which must be added to the EMPr based on the specialist input. Please note that as per the specialist letters there are no additional mitigation measures which must be added to the EMPr and the EMPr stays as is.

PROPOSED AMENDMENT

SPECIALIST CHANGES TO THE EMPr
















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5 PUBLIC PARTICIPATION PROCESS 5.1 Public participation methodology The Public Participation Process commenced after the application was submitted and continued for 30 days. Interested & Affected Parties (I&APs) were afforded further opportunities to raise their issues, concerns and comments regarding the proposed amendments. I&APs and key stakeholders were given the opportunity to review the amendment application form and this report before it was submitted to the authorities for consideration. All comments on the amendments to the Environmental Authorization received from I&APs have been included and addressed in the amendment report. I&AP Database

Name Association Email

Andre Buchnault EWT [email protected]

Andrew Lucas DWAF (ELC) [email protected]

Anngus Tanner SA Wild [email protected]

Arthur Rump Zwartkops Trust [email protected]

Brett Williams DC MANAGER [email protected]

Cllr Jantjies Motherwell [email protected]

Cllr Mafana Motherwell [email protected]

Cllr Magopeni Motherwell [email protected]

Cllr Matebese Motherwell [email protected]

Cllr Mlomo Motherwell [email protected]

Cllr Mnyaka Motherwell [email protected]

Cllr T Barnes Motherwell [email protected]

Cull, Patrick The EC Herald [email protected]

Danie Gerber BRANCH MANAGER [email protected]

de Klerk, Renee TCP (ELC) [email protected]

Deseree Main Library P.E. [email protected]

Egmont Ottermann PPC [email protected]

Fikle Desi NMBM [email protected]

Geeringh, John DEAT (ELC) [email protected]

Gillian Solom HR MANAGER [email protected]

Govender, Jeff DEDEA (ELC) [email protected]

Grove, Pieter Lafarge Industries SA [email protected]

Johann Steyn CDC [email protected]

John Drinkwater CDC [email protected]

Koza, Themba CDC [email protected]

Len Cowely Manager [email protected]

Lucas, Andrew DWAF (ELC) [email protected]

M Andries CLO Ward 57 [email protected]

Madikizela, Primrose TNPA (ELC) [email protected]

Marc Later FINANCIAL MANAGER [email protected]

Martin, Dr Paul ECO CDC [email protected]

Martin, Paul ECO, Coega IDZ [email protected]

Mkosana, Joram NMBM (ELC) [email protected]

Motherwell Library Marian [email protected]

Mr. Joram Mkosana Env Manager NMBM [email protected]

Ms Primrose madikizela SHEQ Manager [email protected]

Ms Renee de Klerk Ngqura Env Manager [email protected]

Ngesi, Kithi NMBM (ELC) [email protected]

NiMBLE (Local Env. NGO) Greg Smith [email protected]

Nocawa NMBM [email protected]

Nokuxola Skefile NMBM [email protected]

mailto:[email protected]









































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Ntene, Mosili DEAT (ELC) [email protected]

Oosthuizen, Dr Ané SANPARKS [email protected]

Tshikotshi Mulalo DEAT/MCM (ELC) [email protected]

Retief, Pieter DWAF (ELC) [email protected]

Rump, Jenny Zwartkops Trust [email protected]

SAHRA Thanduxolo Lungile [email protected]

Simpiwe Nkohla NMBM [email protected]

Struwig, Andries DEDEA (ELC) [email protected]

van As, Jan DME (ELC) [email protected]

von Holdt, Andrea CDC (ELC) [email protected]

Wandile Myataza Telkom [email protected]

Wayne Poultan REGIONAL MANAGER [email protected]

WESSA Morgan Griffiths [email protected]

Willie Claasen CEO [email protected]

Paul Hansen SRV Comunitiy Forum [email protected]

Junaid Moosajee ERM [email protected]

Dr Michael Botha DTMS [email protected]















EA Amendment - 12/12/20/2085/3


6. CONCLUSIONS AND RECOMMENDATION The decision regarding whether to proceed with the proposed development should be based on weighing up of the positive and negative impacts as identified and assessed by the independent specialists. In addition to the findings of the specialist studies, it is also necessary to consider the following when making a decision:

The majority of the impacts associated with the proposed project can be mitigated by applying specialist study findings and recommendations;

The project proponent has taken the issues raised by interested and affected parties into consideration;

The project has extensive potential environmental and socio-economic benefits including the generation of clean energy for the NMBMM, and

The project will contribute directly and significantly to social upliftment through a community development trust and skills transfer.

PROPOSED AMENDMENT

CONCLUSION


- The potential impacts have been assessed by the specialists and no additional significant impacts were identified. The bird and bat reports were completed in 2014 and have assessed the turbines based on the larger size.

- No additional mitigation measures were identified and the specialist reports remain unchanged.


- The potential impacts have been assessed by the ecological specialist and no additional significant impacts were identified.



- The positive social (job creation) and environmental (reduced carbon footprint) of the use of cement turbine bases will have an additional positive impact both locally and globally.


- The potential impacts have been assessed by the ecological specialist and no additional significant impacts were identified.



- The increase in the output of the WEF will allow the WEF to have a higher contribution towards the energy needs of Southern Africa while allowing the use of new and improved technology.

The specialist comments suggest that the amendments applied for will not alter the findings of the specialist studies that were included in the EIR. It is the opinion of the EAP that, due to the opinions expressed by the relevant specialists, the above mentioned amendments be authorised.

EA Amendment - 12/12/20/2085/3


APPENDIX A - ECOLOGICAL SPECIALIST OPINION

EA Amendment - 12/12/20/2085/3


APPENDIX B – AVIFAUNAL REPORT

EA Amendment - 12/12/20/2085/3


APPENDIX C – BAT REPORT

EA Amendment - 12/12/20/2085/3


APPENDIX D - NOISE SPECIALIST OPINION

EA Amendment - 12/12/20/2085/3


APPENDIX E – VISUAL SPECIALIST OPINION

EA Amendment - 12/12/20/2085/3


APPENDIX F – LETTER FROM THE MEC

EA Amendment - 12/12/20/2085/3


APPENDIX G – CONSERVATION INITIATIVE: ALIEN MANAGEMENT PLAN

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