project database and proof of notification · notice is hereby given in terms of the national...

PROJECT DATABASE AND PROOF OF

NOTIFICATION

Draft S24G Database – March 2017

NAME SURNAME COMPANY NAME / ORGANISATION

Client

Ruben Brandt Mpact Plastic Containers

Associations

Fabian Williams Atlantis Residents Association

Roy Nagan Atlantis Civic Association

Neighbours and other I&APs

Johannes Brand City of Cape Town (Sub-council 1)

Babara Rass City of Cape Town (Ward 32)

Eskom Ankerlig Power Station

Dirk Maree City of Cape Town: Property Department

TR w Occupant Restraints SA

Commenting authorities

Morne Theron City of Cape Town

Alana Duffell-Canham CapeNature

Ziyaad Allie DEA&DP Rectification

Cape Town

Tel: +27 21 530 1800

Fax: +27 21 532 0950

14 Central Square

Pinelands 7405

PO Box 38561

Pinelands 7430

South Africa

JG Afrika (Pty) Ltd • Reg. No. 1977/000524/07

Directors: PA Olivier (Managing), Ms MV Makhetha, SN Makhetha, Ms VG Mkaza, Ms JC Norris, PL Ngqumshe, HH Tiganis

Member Firm: Consulting Engineers South Africa (CESA) • ISO 9001:2008 certified [email protected]

Cape Town - Durban - Johannesburg - Maputo - Maseru - Maun - Pietermaritzburg - Port Elizabeth - Postmasburg - Pretoria www.jgafrika.com

Our Ref.: 4250

DEA&DP Ref: 14/2/1/1/A1/2/0025/16

11 April 2017

Attention: Interested and Affected Party

SECTION 24G RECTIFICATION PROCESS FOR THE EXPANSION OF MPACT PLASTIC CONTAINERS FACILITY IN

ATLANTIS INDUSTRIA: RELEASE OF DRAFT S24G REPORT FOR PUBLIC COMMENT

This letter serves to inform you of the commencement of a Section 24G (S24G) process for Mpact Plastic

Containers (Pty) Ltd (Mpact) at their facility in Atlantis Industria.

Mpact expanded their external storage area and cleared more than 300 m2 of indigenous vegetation, which

triggered a Listed Activity in terms of the National Environmental Management Act (NEMA) (No. 107 of 1998).

As such, Mpact is undertaking a rectification process.

A Draft S24G Environmental Impact Assessment Report, including an Operational Environmental

Management Programme (EMP), has been released for a 30-day public comment period from 11 April 2017

to 16 May 2017. A copy of the Draft S24G Report will be placed at the following locations from 11 April 2017

for the duration of the commenting period:

• Mpact Plastic Containers offices (1 Neil Hare Road, Atlantis Industria) (Contact Person – Ruben

Brandt); and

• JG Afrika website: www.jgafrika.com/public-participation.

All written comments on the Draft S24G Report must reach JG Afrika by no later than 16 May 2017 for

consideration as part of the project and for inclusion in a Comments and Responses Report.

Please do not hesitate to contact the undersigned ([email protected]) should you have any questions.

Yours faithfully

TAMRYN HEYDENRYCH

for: JG AFRIKA (PTY) LTD

ADVERT AND SITE NOTICE

10 Weskus Nuus GEKLASSIFISEERD CLASSIFIEDS 11 April 2017

TENDER:INVITATION TO OPERATECAFETERIA AT CAMPUSES

CLOSING DATE: Wednesday 19 April 2017 TIME: 11H00TENDER NUMBER: CAF/01/2017

West Coast College is seeking to tender the lease of theAtlantis and Vredenburg cafeteria for a period of 3 years.Services to be provided during college days, for recess and lunch. The cafeteria services are required from07h30am to 17h30pmevery day,while students and staff are at college.

Additional afternoon and evening hours on weekdays and also on weekends will be at the discretion of thesuccessful operator. The operator’s submission must include how they intend to operate the business and theirproposed opening hours.

At the Vredenburg campus, we have about 1 300 students during the day including college staff, evening classesfrom Monday to Saturday and 240 students in our residence; whilst at theAtlantis campus we have about 1 500students during the day including college staff.

The successful bidder for Vredenburg Cafeteria will have to bring their own deep fryer and urn. Equipment that isavailable is 1xcoke fridge, 1xstainless steel table, 1x4plate stove and small freezer. For theAtlantis Cafeteria, thecollegewill supply the successful bidderwith a fully furnished kitchen.

For the following campuses: Malmesbury, Citrusdal and Vredendal we invite bidders to operate from a mobilecontainer for the period of 3 years. The collegewill provide the space and electricity at a fee. The average studentpopulation including staff is around 1000.

The successful service provider will need to communicate with the college regarding any signage they wish touse.

Information relating to repairs and maintenance of the area, the fittings and equipment is included in theproposed contract. Insurance requirements are also covered in the proposed contract.The cost for the provision of utilities (water & electricity) supplied to the Cafeteria are included in the monthlyrental proposed by the bidder.

In order for a tender to be acceptedby the college the followinghas to be adhered to:

The following information and documentation will be required for the bid to be accepted.• WCC Bidding documentation SBD1- SBD9 (do not complete SBD7)• You can attached the quotation(proposed menus and price lists) if the space provided on SBD3.1 or SBD3.2 form is not enough.

• Company profile of the bidding company and contact details.• Company registration (CK form)• Certified ID copies of ALL the Directors/members of the bidding company• Original Bank stamped banking details of the company or certified copies of 3 months bank statement.• Original and Valid Tax Clearance certificate.• Certified copies of a VALID BBBEE certificate/status• 80/20 or 90/10 rule will be applied

Please note that non-adherence to the above will render bids invalid

Thephysical address for collection and delivery of tender documents is theWest Coast College (WCC)Located at 2 Loedolf street,Malmesbury, 7299..All proposals must be placed in a sealed envelope, clearly marked with the description and TENDERNUMBER.Late submission of bids, telegraphic, telephonic telefax, facsimile and e-mail documentswill NOTbeaccepted.

A non-refundable tender fee of R500,00 must be deposited into the West Coast College Bank Account, asfollows: ABSA Bank, Account No. 4052300937, Branch Code: 632005, Reference: WCC/TS/2017, followed bythe service provider’s name. Proof of payment is required upon collection of the tender documents.

Public opening of bids will be conducted immediately after the closing time, 11:00 and bidders arewelcome to view the process.

West Coast College reserves the right to accept or reject tender offer or alternative tender offer and may cancelthe tender process and reject all tender offers at any timebefore the drafting of a contract.WestCoastCollegewillnot incur any liability to a tenderer for such cancellation and rejection, but will give written reasons for such actionupon request to do so.

PLEASE NOTE: TENDER WILL BE CLOSE STRICTLY AT 11H00 ON 19 APRIL 2017. NO LATE TENDERSWILLBEACCEPTED.

The successful bidder(s) should be operational as from the 1stMay 2017.

For enquiries please contact Mr Dumisani Nyamza (Infrastructure and Facilities Manager or Ms Myrna Folding(SupplyChain) at 022 4821143

0000000-WU110417

S24G APPLICATION FOR THE EXPANSION OF ASTORAGE AREAAT MPACT PLASTIC CONTAINERS

FACILITY IN ATLANTIS INDUSTRIA, ERF 228

PUBLIC PARTICIPATION PROCESS

Notice is hereby given in terms of the National Environmental ManagementAct, 1998 (No. 107 of 1998) (NEMA) as amended, of the commencement of aSection 24G rectification process and associated Public ParticipationProcess.Applicant:Mpact Plastic Containers (Pty) Ltd (Mpact)Project:Mpact extended their existing external storage area byapproximately 6 400 m2.Location:Neil Hare Road,Atlantis Industria, Cape TownRectification application for environmental authorisation to undertakethe following activities: In terms of GN No. R985 of NEMA, the followingListed Activity was triggered by the clearing of indigenous vegetation: ListingNotice 3 –Activity 12.Opportunity to participate: A Draft S24G Environmental ImpactAssessment Report has been compiled and has been released for a 30-daypublic comment and review period from 11 April 2017 to 16 May 2017. Acopy of the S24G Report is available for review at Mpact (1 Neil Hare Road,Atlantis) or can be viewed on JG Afrika’s website: www.jgafrika.com/public-participation.Interested and Affected Parties (I&APs) are invited to register and providewritten comments on the abovementioned Draft S24G Report. Writtencomments must be submitted to JG Afrika by no later than 16 May 2017 forinclusion in the Final S24G Report.

For more information, contact JG Afrika:Mrs Tamryn HeydenrychPO Box 38561, Pinelands, 7430Tel: +27 21 530 1800 • Fax: +27 21 532 0950E-mail: [email protected]: http://www.jgafrika.com

X1TFC4QR-WU110417

Atlantis based companyseeks to employ a

qualified andexperienced

Hydraulic Technicianurgently.

Salary negotiable.

Send CV [email protected]

Deadline:20 April 2017

URGENT

POSITION

000000-WU110417

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ATTENTION RICH-MOND PARK CLAI-MANTS. The CCS Secu-rity is looking for GRADEC, D AND E Security Offi-cers. Must be PSIRA Regi-stered and have no crimi-nal record. Hand CV in atAtlantis City Centre, Unit17 before or on 5 May2017. Email:[email protected] 021 572 0266.

FORWEDDINGS,

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ContactChris Koopmanat 064 701 1531

[email protected]

CJK'sCJK'sSPITBRAAISPITBRAAI

000000-WU110417

Photographs of site notice placed at the entrance to Mpact on 11 April 2017

S G APPLICATION FOR THE EXPANSION OF A STORAGE AREA AT MPACT PLASTIC CONTAINERS FACILITY IN ATLANTIS INDUSTRIA, ERF

Noi e is here gi e i ter s of the Naio al E iro e tal Ma age e t A t, No. of NEMA as a e ded, of the o e e e t of a Se io G re ii aio pro ess a d asso iated Pu li Pari ipaio Pro ess.

APPLICANT: Mpa t Plasi Co tai ers Pt Ltd Mpa t

PROJECT: Mpa t e te ded their e isi g e ter al storage area appro i atel .

LOCATION: Neil Hare Road, Atla is I dustria, Cape To

RECTIFICATION APPLICATION FOR ENVIRONMENTAL AUTHORISATION REQUIRED: I ter s of GN No. R of NEMA, the follo i g Listed A i it as triggered the leari g of i dige ous egetaio : Lisi g Noi e – A ivity .

OPPORTUNITY TO PARTICIPATE: A Drat S G E iro e tal I pa t Assess e t Report has ee o piled a d has ee released for a -da pu li o e t a d re ie period fro April to May . A op of the S G

Report is a aila le for re ie at Mpa t Neil Hare Road, Atla is or a e ie ed o JG Afrika’s e site: .jgafrika. o /pu li -pari ipaio .

I terested a d Afe ted Paries I&APs are i ited to register a d pro ide rite o e ts o the a o e e io ed Drat S G Report. Write o e ts ust e su ited to JG Afrika o later tha May for i lusio i the Fi al S G Report.

FOR MORE INFORMATION CONTACT JG AFRIKA: Co ta t: Mrs Ta r He de r h

Postal Address: PO Bo , Pi ela ds, Telepho e: + Fa si ile: + E- ail: ta r @jgafrika. o We site: htp:// .jgafrika. o

PUBLIC PARTICIPATION PROCESS

MEETING NOTES

JG Afrika (Pty) Ltd Mpact – CCT meeting Page 1

EXPANSION OF MPACT PLASTIC CONTAINERS FACILITY IN ATLANTIS INDUSTRIA

CCT: ENVIRONMENTAL RESOURCES MANAGEMENT MEETING

MEETING NOTES

Meeting held on 16 September 2016 at 13h30 at CCT s offices, Milnerton

Attendees Company/Organisation

Ruben Brandt (RB) Mpact

Ted Kelly (TK) Engineering Analysis Services (E.A.S.)

Morné Theron (MT) City of Cape Town: Environmental Resource Management

Tamryn Heydenrych (TH) JG Afrika

Anèl Dannhauser (AD) JG Afrika

Refer to Appendix A for the attendance register.

# Description Action

1 Welcome:

TH welcomed everyone and thanked them for attending the meeting. The

purpose of the meeting was to meet with the City of Cape Town (CCT): ERM

department prior to commencing with a Section 24G application under the

National Environmental Management Act, 1998 (Act No. 107 of 1998). The

meeting with the CCT follows on from a meeting held with the Department of

Environmental Affairs and Development Planning (DEA&DP) Directorate:

Compliance and Enforcement regarding the project and the way forward.

2

2.1

Project Description:

A brief overview of the facility and the project activities were provided as follows:

The Mpact site is an existing site on a property in the Atlantis Industrial Area.

Mpact produces various plastic containers and final products are temporarily

stored on site. These containers do not contain any pollutants or other

harmful substances.

Due to business growth, a decision was made to extend the existing

operational area by approximately 6 400 m2. As part of the expansion, the

boundary fence was extended and an area of approximately

5 300 m2 was cleared of vegetation for the establishment of a concrete slab.

Recent botanical input was obtained from Dr Dave McDonald where he

confirmed that the vegetation type that would have been present on site was



Cape Flats Dune Strandveld.

The site was not in a pristine condition prior to the recent extension and

included a fire break, approximately 1 700 m2 in extent.

3

3.1

3.2

3.3

Section 24G Discussion:

MT confirmed that the CCT has acknowledged that land falling within the urban

area of Atlantis Industria will be developed. The only recommendation that they

request, where natural vegetation remains, is that Search and Rescue is

undertaken to form part of the land bank initiative.

MT noted that as an opinion had already been obtained from a botanical

specialist as to the vegetation that would most likely have been found on Erf 228,

the CCT will not require further botanical specialist input. However, this would

need to be confirmed by DEA&DP before a decision is made not to undertake a

further botanical study.

The following options were discussed for future mitigation or offset to

compensate for the loss in indigenous vegetation:

The CCT s la d a k refer to the des riptio elo a ot e used as an offset or punitive measure since the vegetation has already been

removed.

Mpact should consider contributing to an organisation like the

Dassenberg Coastal Catchment Partnership (DCCP) in terms of providing

funding for alien clearing, as one example. This should then be the

mitigation for the loss of vegetation presented in the report. Any money

spent on this would be in addition to the ultimate fine issued by DEA&DP,

however, it may provide sufficient motivation for a lesser fine. MT

reiterated that the CCT has no control over the outcome of the fine

calculation.

JG Afrika

4

4.1

4.2

4.3

Incentive scheme and landbank discussion:

MT sho ed a ap of the Atla tis I dustrial area o erlai ith the CCT s Bio et GIS layer. Scattered areas over a large number of properties within Atlantis

contain indigenous vegetation.

The CCT investigated obtaining a blanket departure from DEA&DP for the

development of properties containing indigenous vegetation in the Atlantis

Industrial Area. However, DEA&DP indicated that this was not possible. In

response, the CCT purchased various properties as an offset, referred to as the

la d a k . A rate of 1:1 was calculated for the offset. When a property is

developed, any plants removed are then replanted in the landbank area.

It was noted that although individual landowners would still need to apply for

Environmental Authorisation, these landowners would not be responsible for

removing the vegetation, as the CCT would facilitate the process.



5

5.1

5.2

5.3

General discussion:

It was confirmed that the expansion of the Mpact site lead to an increase in job

opportunities. MT indicated that increased job opportunities are one of the

CCT s ai interests when assessing a new or expanded project in the Atlantis

Industria area.

MT indicated that the increase in employees necessitates that an application be

made in terms of the Koeberg Nuclear Evacuation Plan. MT provided an

application form in this regard and provided an explanation as to the completion

of the form.

The CCT is in the process of undertaking a Basic Assessment Process for various

City owned land parcels within Atlantis Industria that contain indigenous

vegetation. This will enable the CCT to sell land that is ready to be developed.

6 The meeting ended at 14h30.

Notes taken by Anèl Dannhauser on 16 September 2016.

Appendix A: Attendance register

COMMENTS AND RESPONSES REPORT ON DRAFT

S24G EIA REPORT

4250: Draft S24G EIA Report - Comments and Responses Report 1 May 2017

JG Afrika (Pty) Ltd Page 1 of 5

COMMENTS AND RESPONSES REPORT ON THE DRAFT S24G EIA REPORT (1)

This Comments and Responses Report (CRR) 1 reflects the comments submitted in writing during the 30-day commenting period from 11 April 2017 to and

including 16 May 2017 on the Draft S24G EIA Report. For ease of reference, Table 1 provides a list of all written comments received during the 30-day comment

period and Table 2 includes responses to comments received.

- mail; - email; - facsimile; - telephone

Table 1: List of I&APs who submitted written comments during the Draft S24G EIA Report comment period.

Name Organisation Comment

Received Via Date Comment Received

Morné Theron City of Cape Town: Environmental & Heritage Management Branch 16 May 2017 and 26 May 2017

Rhett Smart CapeNature 6 June 2017 (outside commenting period)

Table 2: Co e ts su itted as well as the proje t tea ’s respo ses

# COMMENTS I&AP RESPONSE

1 Disaster Risk Management Centre

1.1 The subject site is located within the 5 to 16 km Urgent

Protection Zone (UPZ) Radius of the Koeberg Nuclear Power

Station (KNPS). The Draft S24G Report indicated that the

project will generate 11 new employment opportunities. This

increase in employment opportunities could have an impact

on the KNPS Traffic Evacuation Model. As such the projected

population increase associated with this activity was tested by

the Koeberg Traffic Evacuation Model (TEM) which indicated

that the City of Cape Town road network will still be able to

evacuate the 5 to 16 km UPZ within the National Nuclear

Morné Theron

(City of Cape Town)

This comment is noted. No further action required.




regulator prescribed time of 16 hours.

1.2 The City of Cape Town Disaster Risk Management Centre

(DRMC) is the custodian (on behalf of the City of Cape Town)

for the execution of the KNPS Radiological Release Hazard

Disaster Risk Management Plan (RRR) and is tasked with the

responsibility of ensuring that the public safety arrangements

are in place in the case of a nuclear emergency and that

individual citizens are not endangered with particular

emphasis on the population residing in the UPZ of the 0 – 16

km area from the KNPS. The DRMC indicated that the

following must also be reflected in the EMPr, namely:

A comprehensive risk assessment must be undertaken

for the Mpact facility and submitted to the DRMC; and

An on-site Emergency Risk Management Plan must be

compiled for the Mpact facility and submitted to the

DRMC.

Morné Theron

(City of Cape Town)

A telephonic discussion with the head of Area North, Mr van

Rensburg, was held on 23 May 2017, whereby it was

confirmed that the City of Cape Town will assist Mpact with

the completion of the necessary documents.

As such, no further information is required as part of the S24G

process.

The Operational EMP has been updated to reflect the

requirements for a risk assessment and an Emergency Risk

Management Plan.

2 Environmental & Heritage Management:

2.1 The proposed R 50 000 is considered a fair punitive

biodiversity off-set mitigation measure in lieu of the loss of

5 300 m2 of critical Cape Flats Dune Strandveld (Note: This is in

addition to the anticipated S24G administrative fine that will

be imposed by the Competent Authority).

As such, the EAPs proposed conditions as contained in Section

H (page 31 of 32) of the draft S24G report is supported by the

City of Cape Town, provided that a timeframe is stipulated

when the alien vegetation clearing shall be completed. To this

extent a maximum period of six months from the date that the

Morné Theron

(City of Cape Town)

Section H of the Final S24G EIA Report has been updated to

reflect that the alien clearing must be completed within a

period of 6 months from the date the S24G Environmental

Authorisation is issued.




S24G Environmental Authorisation is issued, is suggested.

3 Confirmation of Infrastructure Capacity

The City of Cape Town: Utility Directorate: Electricity

Generation and Distribution Branch confirmed sufficient

electrical power infrastructure to support the upgrade.

The City of Cape Town: Utility Directorate: Water and

Sanitation also confirmed sufficient capacity for sewer,

wastewater and water supply. Water supply pressure

pertaining to fire supply is however, cautioned as follows:

The water demand is not very high and can be supplied

by the 75 mm main in John St Ledger Street, this main is

however smaller than the 100 mm required for fire

supply. In most cases a 75 mm supply is acceptable for a

hydrant. The pressure is at 53m peak and is good as well.

If however the fire supply is for a sprinkler system the

75 mm will not be large enough then the developer will

have to lay a new 100 mm main to the 225 mm line in

Neil Hare Road. A dedicated 100 mm supply will require

trenching and road reinstatement.

[The comment also included plans of the municipal water and

sewer infrastructure in the area.]

Morné Theron

(City of Cape Town)

This comment is noted. The project engineer confirmed that

there are no sprinkler systems in the additional external

storage area, only fire hydrants are in place.

4 Atlantis Industrial Incentives Scheme

[Extract of comment]

Of relevance to this application is the Atlantis Industrial

Rhett Smart

(CapeNature)

It should be noted that the project is not applying for the

biodiversity offset, but is merely setting the scene in terms of

current practices in the area relating to natural vegetation.




Incentives Scheme (AIIS), which has been described in the

Draft S24G Report. In brief, the scheme is aimed at

encouraging investment in the Atlantis Industrial area, with

the incentive being that if the application is located on natural

vegetation, the development could qualify for a biodiversity

offset. The biodiversity offsets have been proactively secured

through a land banking mechanism. The application would

have to meet several criteria in order to qualify for this, and

further detail can be provided on request from the City of

Cape Town: Biodiversity Management Branch (with

endorsement from CapeNature).

The AIIS however should not apply to a NEMA Section 24G

rectification process for illegal or unlawful activities that have

taken place. The incentives should only be available for

applicants that comply with the legislation and receive

environmental authorisation prior to commencement of the

activity. Based on the above, CapeNature therefore

recommends that the activities undertaken should be

assessed in the same way as if the application had taken place

outside of the Atlantis industrial area, where the Atlantis

Industrial Incentives do not apply, as they are not available for

rectification applications for unlawful activities.

It is noted that a conservation contribution has been proposed

towards alien clearing in the Dassenberg Coastal Catchment

Partnership which consists of current and proposed priority

conservation areas adjacent to Atlantis. This is supported and

can be considered as a form a mitigation for the activities

This scheme would have applied if the project had undertaken

a process prior to commencing.




which have been undertaken. The conservation contribution

would not however qualify as a biodiversity offset in terms of

the national policy and provincial guidelines.

CapeNature does not recommend that any additional

mitigation or remediation is required. The Environmental

Management Plan is supported and does not require

additional measures.

5 Firebreak

[Extract of comment]

It is noted that based on historical Google Earth imagery the

expansion area was cleared between 2009 and 2011. This may

have only been brushcutting or mowing. Reference is made to

a maintained firebreak, although this clearing would appear to

be more extensive. The applicant should provide further

clarification in this regard and should be taken into

consideration for the application.

Rhett Smart

(CapeNature)

Based on input from the applicant’s environmental lawyers,

no environmental authorisation was required at the time the

area was cleared for a firebreak, based on the following:

The area cleared for the fire break was 1 700 m2 (0.17

hectares).

Given that the fire break was cleared on or before

May 2010, the 2006 EIA regime would have been

applicable (the 2010 Regulations came into effect in

June 2010). In terms of those notices, no Listed

Activities were triggered.

As such, this has not been taken into account in this

application.

WRITTEN COMMENTS

450 Ø

400 Ø

400 Ø

75 Ø

75 Ø

150 Ø

350 Ø

450 Ø

350 Ø

350 Ø

300 Ø

225 Ø

75 Ø

1183

4

1183

1183

1183

1183

1506

NE IL HARE ROAD

NE IL H

ARE ROAD CHARE L UY S DR IVE

J OHN S T LE GE R C R E S C E NT

CHAREL UYS DR IVE

F low meters

Isolating valve

Air valve

R eservoir / Tower

Bulk connection1234

Network pipes (Ø )

Pump station

E nd cap

Bulk water pipes

S cour valve

Hydrant

Zone valveC losed

Non-return valve

PR V

S chematic pipes

M C TN-T28

C TN-T27

C TN-T26

C TN-U28

C TN-U27

C TN-U26

C TN-V28

C TN-V27

C TN-V261 : 2 500

0m 10m 20m 30m 40m 50mWater distribution systemLE GE ND

Nov 2014 1

DATE : R E V: S C ALE : WGS 19°

No.:

INDE X

C ity of C ape Town

4925

0

4950

0

3717500

3717750

3718000

4950

0

4925

0

4900

0

3718000

4875

0

3717750

3717500

4875

0

4900

0

C TN-U27

150 Ø225

Ø

225 Ø

75 Ø

225

Ø

75 Ø

300 Ø

225 Ø

225 Ø

75 Ø

1183

1183

1183

1183

1183

1183

1183

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C HAR LE S MATTHE WS S TR E E T

DE KORTE S TRE E T

NE IL HARE ROAD

NE IL H


NE IL HAR E R OAD

F low meters

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Air valve

R eservoir / Tower

Bulk connection1234

Network pipes (Ø )

Pump station

E nd cap

Bulk water pipes

S cour valve

Hydrant

Zone valveC losed

Non-return valve

PR V

S chematic pipes

M C TN-T29

C TN-T28

C TN-T27

C TN-U29

C TN-U28

C TN-U27

C TN-V29

C TN-V28

C TN-V271 : 2 500

0m 10m 20m 30m 40m 50mWater distribution systemLE GE ND

Nov 2014 1


No.:

INDE X

C ity of C ape Town

4925

0

4950

0

3718000

3718250

3718500

4950

0

4925

0

4900

0

3718500

4875

0

3718250

3718000

4875

0

4900

0

C TN-U28

1183

4

1183

1183

1183

1506

1183

NE IL H


J OHN S T LE GE R C R E S C E NT

CHAREL UYS DR IVE

NE IL HARE ROAD

150

Ø

150 Ø

150 Ø

150 Ø

150 Ø

150 Ø

150 Ø

150 Ø150 Ø

150

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230 Ø

150 Ø

150 Ø

230 Ø150 Ø

150 Ø

150 Ø

150 Ø

150

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Manhole

Pump station

<= 175 mmØ

> 175 <= 325 mmØ

> 325 mmØ

F low direction

R ising Mains

>

S chematic pipes

Unknown diameter149mmØ

Diversion structure

WWTWC TN-T28

C TN-T27

C TN-T26

C TN-U28

C TN-U27

C TN-U26

C TN-V28

C TN-V27

C TN-V261 : 2 500

0m 10m 20m 30m 40m 50m

LE GE ND

Nov 2014 1


No.:

INDE X

S ewer drainage systemC ity of C ape Town

4925

0

4950

0

3717500

3717750

3718000

4950

0

4925

0

4900

0

3718000

4875

0

3717750

3717500

4875

0

4900

0

C TN-U27

1183

1183

1183

1183

1183

1183

1183

1183

1506

NE IL HARE ROAD

NE IL H


NE IL HAR E R OAD

C HAR LE S MATTHE WS S TR E E T

DE KORTE S TRE E T

150 Ø

150 Ø

150

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150

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230

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230

Ø

150

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230

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150 Ø

230

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150

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150 Ø

150 Ø

150

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150 Ø

230 Ø

150 Ø

150 Ø

230 Ø150 Ø

150 Ø

230

Ø

150 Ø

150 Ø

230 Ø150 Ø

150 Ø

150 Ø

150 Ø

150 Ø

150 Ø

150 Ø

150

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150 Ø

Manhole

Pump station

<= 175 mmØ

> 175 <= 325 mmØ

> 325 mmØ

F low direction

R ising Mains

>

S chematic pipes

Unknown diameter149mmØ

Diversion structure

WWTWC TN-T29

C TN-T28

C TN-T27

C TN-U29

C TN-U28

C TN-U27

C TN-V29

C TN-V28

C TN-V271 : 2 500

0m 10m 20m 30m 40m 50m

LE GE ND

Nov 2014 1


No.:

INDE X

S ewer drainage systemC ity of C ape Town

4925

0

4950

0

3718000

3718250

3718500

4950

0

4925

0

4900

0

3718500

4875

0

3718250

3718000

4875

0

4900

0

C TN-U28

The Western Cape Nature Conservation Board trading as CapeNature

Board Members: Ms Merle McOmbring-Hodges (Chairperson), Dr Colin Johnson (Vice Chairperson), Mr Mervyn Burton, Prof Denver Hendricks,

Dr Bruce McKenzie, Adv Mandla Mdludlu, Mr Danie Nel, Prof Aubrey Redlinghuis, Mr Paul Slack

JG Afrika P.O. Box 38561 Pinelands Cape Town 7430 Attention: Tamryn Heydenrych By email: [email protected] Dear Tamryn Draft NEMA Section 24G Environmental Impact Report for the Unlawful Clearing of Natural Vegetation for the Expansion of the Storage Area of the Mpact Plastic Containers Facility, Portion 212 of Farm 1183, Atlantis (DEA&DP ref. no.: 14/2/1/1/A1/2/0025/16)

CapeNature would like to thank you for the opportunity to comment on the activities undertaken and would like to make the following comments. Please note that our comments only pertain to the biodiversity related impacts and not to the overall desirability of the activities. As a standard principle, CapeNature does not support the undertaking of activities listed in the EIA regulations prior to authorisation, and supports the implementation of appropriate action in terms of the relevant legislation in this regard. The area within which the expansion took place is classified as Other Natural according to the Western Cape Biodiversity Spatial Plan (WCBSP, March 2017) and the Biodiversity Network (BioNet) for the City of Cape Town. The natural vegetation occurring on the site would have consisted of Cape Flats Dune Strandveld listed as Endangered. No wetlands or watercourses are mapped for the site. A botanical specialist opinion is included, which confirms that the vegetation that would have occurred on the site is Cape Flats Dune Strandveld. In terms of the condition, it is described as highly likely to have had a moderate to high infestation of alien invasive Port Jackson (Acacia saligna) and Rooikrans (Acacia cyclops), based on historical aerial imagery (Google Earth) and the condition of the neighbouring properties. However it still would have contained an adequate component of Cape Flats Dune Strandveld species and would have been considered restorable with a suitable alien clearing programme. Of relevance to this application is the Atlantis Industrial Incentives Scheme (AIIS), which has been described in the Draft S24G Report. In brief, the scheme is aimed at encouraging investment in the Atlantis Industrial area, with the incentive being that if the application is located on natural vegetation, the development could qualify for a biodiversity offset. The biodiversity offsets have been proactively secured through a land banking mechanism. The application would have to meet several criteria in order to qualify for this, and further detail

SCIENTIFIC SERVICES

postal Private Bag X5014, Stellenbosch, 7599

physical Assegaaibosch Nature Reserve, Jonkershoek

website www.capenature.co.za

enquiries Rhett Smart

telephone +27 21 866 8017 fax +27 21 866 1523

email [email protected]

reference SSD14/2/6/1/4/1/118-212_S24G_Atlantis

date 6 June 2017

mailto:[email protected]

can be provided on request from the City of Cape Town: Biodiversity Management Branch (with endorsement from CapeNature). It should be noted that the classification of the vegetation on site as Other Natural is related to the AIIS, with the assumption that all of the natural vegetation within the urban edge of the industrial area of Atlantis is available for development through the acquisition of the proactive biodiversity offset. Therefore the BioNet, and as adopted in the WCBSP, has classified this natural vegetation as Other Natural, which otherwise would have likely been classified as Critical Biodiversity Area (CBA) or Ecological Support Area (ESA) as it is intact Endangered vegetation. The botanical specialist opinion has also indicated that in his opinion the natural vegetation on site should be classified as CBA due to the threat status. The AIIS however should not apply to a NEMA Section 24G rectification process for illegal or unlawful activities that have taken place. The incentives should only be available for applicants that comply with the legislation and receive environmental authorisation prior to commencement of the activity. Based on the above, CapeNature therefore recommends that the activities undertaken should be assessed in the same way as if the application had taken place outside of the Atlantis industrial area, where the Atlantis Industrial Incentives do not apply, as they are not available for rectification applications for unlawful activities. It is noted that based on historical Google Earth imagery the expansion area was cleared between 2009 and 2011. This may have only been brushcutting or mowing. Reference is made to a maintained firebreak, although this clearing would appear to be more extensive. The applicant should provide further clarification in this regard and should be taken into consideration for the application. Reference is made to search and rescue as a mitigation. This would have only applied to an application prior to commencement which qualifies for the AIIS, as the vegetation has already been cleared. It is noted that a conservation contribution has been proposed towards alien clearing in the Dassenberg Coastal Catchment Partnership which consists of current and proposed priority conservation areas adjacent to Atlantis. This is supported and can be considered as a form a mitigation for the activities which have been undertaken. The conservation contribution would not however qualify as a biodiversity offset in terms of the national policy and provincial guidelines. CapeNature does not recommend that any additional mitigation or remediation is required. The Environmental Management Plan is supported and does not require additional measures. In conclusion, CapeNature recommends that the competent authority should evaluate all the information in assessing the application, including assigning the administrative fine. Queries raised above should however be addressed. CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received. Yours sincerely

Rhett Smart For: Manager (Scientific Services) cc. Ziyaad Allie, Department of Environmental Affairs and Development Planning

CORRESPONDENCE FROM

HERITAGE WESTERN CAPE

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