project database and proof of notification · notice is hereby given in terms of the national...
TRANSCRIPT
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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ContactChris Koopmanat 064 701 1531
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
JG Afrika (Pty) Ltd Mpact – CCT meeting Page 2
# Description Action
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.
JG Afrika (Pty) Ltd Mpact – CCT meeting Page 3
# Description Action
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.
4250: Draft S24G EIA Report - Comments and Responses Report 1 May 2017
JG Afrika (Pty) Ltd Page 2 of 5
# COMMENTS I&AP RESPONSE
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.
4250: Draft S24G EIA Report - Comments and Responses Report 1 May 2017
JG Afrika (Pty) Ltd Page 3 of 5
# COMMENTS I&AP RESPONSE
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.
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JG Afrika (Pty) Ltd Page 4 of 5
# COMMENTS I&AP RESPONSE
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.
4250: Draft S24G EIA Report - Comments and Responses Report 1 May 2017
JG Afrika (Pty) Ltd Page 5 of 5
# COMMENTS I&AP RESPONSE
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
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PR V
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M C TN-T28
C TN-T27
C TN-T26
C TN-U28
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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
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3717750
3718000
4950
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4875
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NE IL HAR E R OAD
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-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
DATE : R E V: S C ALE : WGS 19°
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
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
NE IL HARE ROAD
150
Ø
150 Ø
150 Ø
150 Ø
150 Ø
150 Ø
150 Ø
150 Ø150 Ø
150
Ø
150 Ø
230 Ø
150 Ø
150 Ø
230 Ø150 Ø
150 Ø
150 Ø
150 Ø
150
Ø
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-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
DATE : R E V: S C ALE : WGS 19°
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
ARE ROAD CHARE L UY S DR IVE
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
Ø23
0 Ø
150
Ø
230
Ø
230
Ø
150
Ø
230
Ø 150 Ø
150 Ø
230
Ø
150
Ø
150 Ø
150 Ø
150
Ø15
0 Ø
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
Ø
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
DATE : R E V: S C ALE : WGS 19°
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
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