regulation 54 (a) iii environmental compliance audit report

REGULATION 54 (A) III

ENVIRONMENTAL COMPLIANCE

AUDIT REPORT

Longyuan Mulilo De Aar 2 North (Pty) Ltd

December 2019

Prepared by: AMATHEMBA Environmental Management Consulting CC

REGULATION 54 (A) III

ENVIRONMENTAL COMPLIANCE

AUDIT REPORT

1. INTRODUCTION

1.1 BACKGROUND TO THE REPORT

Amathemba Environmental Management Consulting was appointed by Longyuan Mulilo De Aar 2 North (Pty) Ltd. (hereafter referred to as the “DA1”) to conduct an external audit in terms of Regulation 54 (a) iii.

The audit is with regards to compliance with the conditions stipulated in the Environmental Authorisations (EAs) and Environmental Management Programme (EMPr) issued to its Wind Energy Facility (WEF) situated outside of De Aar, Emthanjeni Local Municipality.

The National Environmental Management Act (Act No. 107 of 1998) (NEMA) Environmental Impact Assessment Regulations were amended on the 7th April 2017.

The following significant regulation was added as GN 326 under transitional provisions section 54A:

(3) Where an environmental authorisation issued in terms of the ECA regulations or the previous NEMA regulations is still in effect by 8 December 2014, the EMPr associated with such environmental authorisation is subject to the requirements contained in Part 3 of Chapter 5 of these Regulations and the first environmental audit report must be submitted to the competent authority no later than 7 December 2019 and at least every 5 years thereafter for the period during which such environmental authorisation is still in effect.

The implication of this for the holder of a valid Environmental Authorisation/RoD for any project, is to have an environmental audit to gauge and report on compliance with the associated conditions of approval. For projects that are beyond construction phase, the EA/RoD is still valid if the EA/RoD and EMPr mentions the operational phase with conditions and/or specifications. Compliance audits must be undertaken by an experienced, independent Environmental Auditor. Failure to comply with the NEMA Regulations is considered a criminal offence.

A site visit was conducted on the 27th November 2019 after which a report is compiled and serves to document the External Audit proceedings, and is a record of all observations, recommendations and conclusions made during the engagement.

1.2 ASSUMPTIONS AND LIMITATIONS

• The assumption is made that all information received from Longyuan Mulilo De Aar 2 North (Pty) Ltd whether written or verbal communication, on which this audit report is based is accurate and correct.

• The audit is based purely on the conditions as stipulated in the EAs and EMPrs issued for DA2.

1.3 SCOPE, PURPOSES AND OBJECTIVES OF THE AUDIT

1.3.1 External compliance audit in terms of Regulation 54 (a) III

The main objective of the compliance audit was to respond to the need for external independent compliance audit as required in terms of Regulation 54 (a) III. The facility operates under the following authorisations and Environmental Management Programs:

Documents

audited:

Document Title Document Reference Number Date of Issue

DEA EA ENVIRONMENTAL

AUTHORISATION IN TERMS OF

THE NATIONAL ENVIRONMENT

AL MANAGEMENT ACT, 1998:

GN R.543, 544, 545 AND 546:

WIND ENERGY FACILITY

SITUATED ON THE PLATEAU

(NORTH) NEAR DE AAR,

NORTHERN CAPE PROVINCE

NEAS Ref.:

DEA/EIA/0000578/2011

DEA Ref.:12/12/20/2463/2

1 March 2013

10th June 2013 (Amendment)

8th August 2014 (Amendment

DENC EA THE GRANTING OF THE

ENVIRONMENTAL

AUTHORISATION FOR GNR546:

ACTIVITY 13 &; 16(III)(A), II(BB):

THE PROPOSEO WIND ENERGY

FACILITY(NORTH) IN THE

EASTERN PLATEAU NEAR DE

AAR.

NC/BA/12/PIX/EMT/DEA4/2014 31 August 2014

DEA EA for

Transmission

line

ENVIRONMENTAL

AUTHORISATION FOR THE

CONSTRUCTION OF THE 132KV

TRANSMISSION LINE AND

ASSOCIATED INFRASTRUCTURE

FROM THE LONGYUAN MULILO

DE AAR MAANHAARBERG

WIND ENERGY FACILITY TO THE

HYDRA SUBSTATION NEAR DE

AAR, NORTHERN CAPE

PROVINCE

DEA REFERENCE NO:

14/12/16/3/3/1/1166

NEAS Reference:

DEA/EIA/0002380/2014

11th August 2014

24th November 2014

(Amendment)

14th March 2016 (Amendment)

25th August 2017 (Amendment)

EMPr (DEA &

DENC)

And EMPr

Transmission

line

Lifecycle Environmental

Management Programme for

Longyuan Mulilo De Aar 2

North Wind Energy Facility

Final Lifecycle Environmental

Management Program

DEA REFERENCE NO.:

12/12/20/2463/2

DENC REFERENCE NO.:

NC/BA/12/PIX/EMT/DEA4/2014

September 2014

June 2014

The scope of the audit was limited to compliance matters as they relate to the above-mentioned documents. Please note that the transmission line was only audited with respect to the construction phase as it is handed over to Eskom for the operational phase.

1.3.2 Meeting requirements of Appendix 7 of EIA Regulations (2014, as amended)

A further objective was to meet the requirements of Appendix 7 of the 2014 EIA Regulations, as amended, which contains the minimum content requirements for compliance audit reports. The specific requirements are detailed in the table below, together with a reference of where this is responded to in this audit report.

Regulatory Ref # of Appendix 7

Details of requirement Report Section Reference

1 The environmental audit report must provide for recommendations regarding the need to amend the EMPr, and where applicable, the closure plan.

Section 4

2 (a) (i) Report on level of compliance with the conditions of the environmental authorisation and the EMPr, and where applicable, the closure plan.

Section 3

2 (a) (ii) Report on the extent to which the avoidance, management and mitigation measures provided for in the EMPr, and where applicable,

Section 4

the closure plan achieves the objectives and outcomes of the EMPr, and closure plan.

2 (b) Identify and assess any new impacts and risks as a result of undertaking the activity.

Section 4

2 (c) Evaluate the effectiveness of the EMPr, and where applicable, the closure plan.

Section 4

2 (d) Identify shortcomings in the EMPr, and where applicable, the closure plan.

Section 4

2 (e) Identify the need for any changes to the avoidance, management and mitigation measures provided for in the EMPr, and where applicable, the closure plan.

Section 4

3 (1) a An environmental audit report prepared in terms of these Regulations must contain details of the— (i) independent person who prepared the environmental audit report; and (ii) expertise of the independent person that compiled the environmental audit report

Section 2

3 (1) b a declaration that the independent auditor is independent in a form as may be specified by the competent authority;

Section 2.4

3 (1) c an indication of the scope of, and the purpose for which, the environmental audit report was prepared;

Section 1.3

3 (1) d a description of the methodology adopted in preparing the environmental audit report;

Section 1.4

3 (1) e an indication of the ability of the EMPr, and where applicable, the closure plan to— (i) sufficiently provide for the avoidance, management and mitigation of environmental impacts associated with the undertaking of the activity on an ongoing basis; (ii) sufficiently provide for the avoidance, management and mitigation of environmental impacts associated with the closure of the facility; and (iii) ensure compliance with the provisions of environmental authorisation, EMPr, and where applicable, the closure plan;

Section 4

3 (1) f a description of any assumptions made, and any uncertainties or gaps in knowledge;

Section 1.2

3 (1) g a description of any public consultation process that was undertaken during the course of carrying out the environmental audit report;

Section 1.4.3

3 (1) h a summary and copies of any comments that were received during any public consultation process; and

NA

3 (1) i any other information requested by the competent authority.

No additional requirements known at this point.

1.4 AUDIT METHODOLOGY

This audit report is based on a site inspection undertaken on 27th November 2019, review of relevant documentation and subsequent follow-up communication with the facility’s compliance officer and representatives of Longyuan Mulilo De Aar 2 North (Pty) Ltd.

1.4.1 Pre-audit tasks

Review of the various approvals / documents relevant to the facility. These documents have included the findings

of the ECO construction closure report and operation environmental audits reports undertaken by NCC Environmental Services (Pty) Ltd (NCC).

Preparation of audit report template, which includes transfer of conditions of approval and EMPrs into the report to inform the auditor’s enquiries during the on-site inspection.

1.4.2 On-site audit

The site inspection served to give the auditor an understanding of the environmental setting and the specific operational aspects of the facility, especially as it relates to the relevant approvals. The day-to-day operations of the facility were observed, and interviews held with key parties in relation to compliance aspects.

1.4.3 Reporting

Compilation of the audit report and compliance checklist (Appendix A) based on the information obtained during the audit inspection and any subsequent follow up liaison with relevant role-players. The final report will be issued to the client (electronically) and the appropriate environmental authority.

In terms of NEMA Chapter 5, Part 3 Regulation 34 (6):

Within 7 days of the date of submission of an environmental audit report to the competent authority, the holder of an environmental authorisation must notify all potential and registered interested and affected parties of the submission of that report, and make such report immediately available—

(a) to anyone on request; and

(b) on a publicly accessible website, where the holder has such a website.

A notification will be sent to all registered interested and affected parties and the report will be uploaded onto the Amathemba Environmental management Consulting website under public documents:

http://amathemba.com/

2. EXPERTISE OF THE AUDITOR

2.1 BARRY WIESNER

Barry Wiesner of Amathemba Environmental Management Consulting has been the independent ECO on several other large-scale wind energy facilities and is author of this audit report.

Barry completed a MPHIL in Environmental Management at the University of Cape Town. Barry also has read a BA majoring in Archaeology and Environmental and Geographical Science and has a Higher Diploma in Education (HDE) from the University of Cape Town. He also has a Bachelor of Theology from the University of South Africa. Barry is a Green Star SA Accredited Professional and a member of the International Association of Impact Assessors.

Barry has extensive site experience working as an Environmental Control Officer at major construction sites and in conducting Environmental Audits, EIAs, BARs and the compilation of numerous Environmental Management Programmes (EMPrs) over the last 18 years.

2.2 STATEMENT OF INDEPENDENCE

Amathemba Environmental Management Consulting was appointed to carry out the external compliance audit and compile this resultant Audit Report. Amathemba Environmental Management Consulting has any material present or contingent interest in the outcome of this report, nor do they have any pecuniary or other interest that could be reasonably regarded as being capable of affecting their independence. Amathemba Environmental Management Consulting has no beneficial interest in the outcome of this compliance audit, other than reasonable remuneration for work performed in undertaking the audit inspection and compiling this report (see Appendix B for signed declaration).

3. COMPLIANCE RESULTS

Please refer to the comprehensive table below for the detailed audit report checklist (Appendix A) of compliance with the respective conditions of the Environmental Authorisations and EMPrs relevant to the project. Please note that the Transmission line is not included as part of the operational phase audit as it is now the property and responsibility of Eskom and not Longyuan Mulilo De Aar 2 North (Pty) Ltd.

3.1 ENVIRONMENTAL AUTHORISATION - DEA REFERENCE NO.: 12/12/20/2463/2

There are ninety-two (92) EA conditions.

88 conditions are noted as compliant, 4 conditions are partially compliant. No non-compliances or not applicable conditions are noted.

The 4 partial compliances relate to the changed layout design. Although the Layout was initially authorised, the Layout changed after some design changes occurred resulting in non-compliance to buffer zones. Approval from

DEA for the deviations is underway but is still outstanding. An amendment application has been submitted. This has been verified with the EAP undertaking the amendment.

Table 1: DEA EA summary of compliance

Compliant

Partially

Compliant

Non-

compliant

Not

Applicable

Total Conditions 88 4 0 0

Percentage

compliance 95.7%

3.2 DEA EA FOR TRANSMISSION LINE DEA REFERENCE NO: 14/12/16/3/3/1/1166

Thirty-four (34) EA conditions were considered with respect to the transmission line. 3 are not applicable.

Table 2: Transmission Line EA compliance summary

Compliant

Partially

Compliant

Non-

compliant

Not

Applicable


Percentage

compliance 100%

3.3 ENVIRONMENTAL AUTHORISATION - DENC REFERENCE NO.:


Seventy-four (74) EA conditions were considered with respect to the DENC with one partial compliance being the verification of the submission of the construction closure report to DENC. The report was done but proof of submission has not been verified.

Table 3: DENC EA compliance summary

Compliant

Partially

Compliant

Non-

compliant

Not

Applicable


Percentage

compliance 98.7%

3.4 EMPRS CONSTRUCTION PHASE

WEF

One hundred and forty (140) EMPr specifications are considered in the audit. 2 are noted as partially compliant and 4 are not applicable.

The one partial compliance relates to the layout amendment. Although the Layout was initially authorised, the Layout changed after some design changes occurred resulting in non-compliance to buffer zones. Approval from DEA for the deviations is underway but is still outstanding. An amendment application has been submitted. This has been verified with the EAP undertaking the amendment.

One specification relates to the dust monitoring. Ambient quantities of particulate matter were not measured in accordance with Air Quality Act, 2004 (Act 39 of 2004), however, adequate dust suppression was implemented such as speed limits, dust suppression etc. on site.

Table 4: WEF EMPr compliance summary

Compliant

Partially

Compliant

Non-

compliant

Not

Applicable


Percentage

compliance 98.6%

Transmission Line

One hundred and twenty-five (125) specifications are considered in this audit. Only one is a partial compliance. As above, the specification relates to the dust monitoring. Ambient quantities of particulate matter were not measured in accordance with Air Quality Act, 2004 (Act 39 of 2004), however, adequate dust suppression was implemented such as speed limits, dust suppression etc. on site.

Table 5: Transmission Line EMPr compliance summary

Compliant

Partially

Compliant

Non-

compliant

Not

Applicable


Percentage

compliance 99.2%

3.5 EMPRS OPERATIONAL PHASE

Fifty-seven (57) specifications are considered for the operational phase audit. All are complied with and 2 are not applicable.

Table 6: Operational Phase compliance summary

Compliant

Partially

Compliant

Non-

compliant

Not

Applicable


Percentage

compliance 100%

4. CONCLUSION AND RECOMMENDATIONS

The external audit was undertaken as required by the need for external independent compliance audit in terms of Regulation 54 (a) III. This resultant audit report meets the requirements of Appendix 7 of the 2014 EIA

Regulations, as amended.

The following conclusions are drawn subsequent to the audit inspection and consideration of compliance with conditions of approval:

• The overall impression was one of a very well-run facility with a strong commitment to achieving full compliance.

• The partial compliances mainly relate to the layout amendment process which is underway. It is

recommended this process be concluded as soon as possible.

• The construction closure report should also be sent to DENC in not already done.

• The other partial compliance related to the construction phase and are no longer relevant during the operation of the facility. They are just noted partial compliances from the construction phase and no further action or mitigation is required.

• It is evident that the mitigation measures implemented by the facility is sufficient and effective in preventing and/or limiting impacts that result from the facility’s operations.

• There is no need for additional mitigation measures.

• There is no need for amendments to the Management Plans (Environmental Management Programme) implemented by the facility.

• No new impacts or risks were identified.

• There is no intention to close the facility in the foreseeable future, and hence no closure plan is relevant yet. Should decommissioning be planned it would be subject to the necessary regulatory processes and the compilation and implementation of a closure plan.

The audit process itself had no implications for the rights of any parties, however in accordance with NEMA Chapter 5, Part 3 Regulation 34 (6): all registered IAPs will be notified that the required audit has been undertaken and will be made available if requested and posted on Amathemba’s website for a minimum period of 30 days.

Yours sincerely

Barry Wiesner (0824626221)

LIST OF APPENDICES

APPENDIX 1: Audit Checklist

APPENDIX 2: Declaration of independence

APPENDIX 1: AUDIT CHECKLIST

1. AUDIT INSPECTION CHECKLIST: LONGYUAN MULILO DE AAR 2 NORTH

Date: Site visit – Wednesday 27th November 2019

Participants: Barry Wiesner Amathemba Environmental Consultants

Documents audited: Document Title Document Reference Number Date of Issue

DEA EA ENVIRONMENTAL AUTHORISATION IN TERMS OF THE NATIONAL

ENVIRONMENT AL MANAGEMENT ACT, 1998: GN R.543, 544, 545

AND 546: WIND ENERGY FACILITY SITUATED ON THE PLATEAU

(NORTH) NEAR DE AAR, NORTHERN CAPE PROVINCE

NEAS Ref.: DEA/EIA/0000578/2011

DEA Ref.:12/12/20/2463/2.

1 March 2013

10th June 2013 (Amendment)


DENC EA THE GRANTING OF THE ENVIRONMENTAL AUTHORISATION FOR

GNR546: ACTIVITY 13 &; 16(III)(A), II(BB): THE PROPOSEO WIND

ENERGY FACILITY(NORTH) IN THE EASTERN PLATEAU NEAR DE AAR,

NC/BA/12/PIX/EMT/DEA4/2014 31 August 2014

DEA EA for Transmission

line

ENVIRONMENTAL AUTHORISATION FOR THE CONSTRUCTION OF

THE 132KV TRANSMISSION LINE AND ASSOCIATED

INFRASTRUCTURE FROM THE LONGYUAN MULILO DE AAR

MAANHAARBERG WIND ENERGY FACILITY TO THE HYDRA

SUBSTATION NEAR DE AAR, NORTHERN CAPE PROVINCE

DEA REFERENCE NO:

14/12/16/3/3/1/1166

NEAS Reference:

DEA/EIA/0002380/2014

11th August 2014

24th November 2014 (Amendment)

14th March 2016 (Amendment)


EMPr (DEA & DENC)

And

EMPr Transmission line

Lifecycle Environmental Management Programme for Longyuan

Mulilo De Aar 2 North Wind Energy Facility

Final Lifecycle Environmental Management Program

DEA REFERENCE NO.:

12/12/20/2463/2

DENC REFERENCE NO.:


September 2014

June 2014

Shading Key

Compliance Y Partial compliance /X Non-compliance X Not Applicable N/A

Document

Reference

Number

Issue to Review Y/X/NA Rationale/Appendix/ Proof/Site observation

Notes and Recommendations

DEA EA

Scope of authorisation

1 The wind energy facility on the North Site is approved. Y Noted and complied with.

2 Only one (1) substation must be constructed for the North Site. Y Noted and complied with.

3 Authorisation of the activity is subject to the conditions contained in this

authorisation, which form part of the environmental authorisation and are binding

on the holder of the authorisation.

Y Noted and complied with.

4 The holder of the authorisation is responsible for ensuring compliance with the

conditions contained in this environmental authorisation. This includes any person

acting on the holder's behalf, including but not limited to, an agent, servant,

contractor, sub-contractor, employee, consultant or person rendering a service to

the holder of the authorisation.

Y "The licence holder took all reasonable measures to

ensure conditions of the EA were met.

Obligations towards the EA were included in the

contracts issued to the various sub-contractors/

service providers " – confirmed in the construction

closure report.

5 The activities authorised may only be carried out at the property as described

above.


6 Any changes to, or deviations from, the project description set out in this

authorisation must be approved, in writing, by the Department before such changes

or deviations may be affected. In assessing whether to grant such approval or not,

the Department may request such information as it deems necessary to evaluate

the significance and impacts of such changes or deviations and it may be

necessary for the holder of the authorisation to apply for further authorisation in terms

of the regulations.

Y/X Although the Layout was initially authorised, the Layout

changed after some design changes occurred

resulting in non-compliance to buffer zones. Approval

from DEA for the deviations is underway but is still

outstanding. An amendment application has been

submitted and the process is underway. This has been

verified with the EAP undertaking the amendment.

7 This activity must commence within a period of three (3) years from the date of issue.

If commencement of the activity does not occur within that period, the

authorisation lapses and a new application for environmental authorisation must be

made in order for the activity to be undertaken.


8 Commencement with one activity listed in terms of this authorisation constitutes

commencement of all authorised activities.


9 The holder of an environmental authorisation has the responsibility to notify the

competent authority of any alienation, transfer and change of ownership rights in

the property on which the activity is to take place.


Notification of authorisation and right to appeal

10 The holder of the authorisation must notify every registered interested and affected

party, in writing and within 12 (twelve) calendar days of the date of this

environmental authorisation, of the decision to authorise the activity.


11 The notification referred to must -specify the date on which the authorisation was

issued; inform the interested and affected party of the appeal procedure provided

for in Chapter 7 of the Environmental Impact Assessment (EIA) Regulations, 2010;

advise the interested and affected party that a copy of the authorisation will be

furnished on request; and give the reasons for the decision.


12 The holder of the authorisation must publish a notice - informing interested and

affected parties of the decision; informing interested and affected parties where


Document

Reference

Number



the decision can be accessed; and drawing the attention of interested and

affected parties to the fact that an appeal may be lodged against this decision in

the newspaper(s) contemplated and used in terms of regulation 54(2)(c) and (d)

and which newspaper was used for the placing of advertisements as part of the

public participation process.

Management of the activity

13 A copy of the final site layout plan must be submitted with the amended EMPr to

the Department for written approval prior to commencement of the activity. All

available biodiversity information must be used in the finalisation of the layout plan.

The site layout plan must indicate the following:

Y Although the Layout was initially authorised, the

Layout changed after some design changes

occurred resulting in non-compliance to buffer zones.

Approval from DEA for the deviations is underway but

is still outstanding. This has been verified with the EAP

undertaking the amendment.

13.1 Turbine positions; Y Indicated as required.

13.2 The preferred substation position; Y Indicated as required.

13.3 Foundation footprint; Y Indicated as required.

13.4 Internal roads indicating width (construction period width and operation period

width) and with numbered sections between the other site elements which they

serve (to make commenting on sections possible);

Y Indicated as required.

13.5 Wetlands, drainage lines, rivers, stream and water crossing of roads and cables

indicating the type of bridging structures that will be used;

Y The water crossing (WC) positions are indicated, but

type of bridging structures is not displayed, which

were approved by DEA - consists of ditch drains and

one pipe culverts.

13.6 The location of heritage sites; Y Indicated as required.

13.7 Sub-station(s) and/or transformer(s) sites including their entire footprint; Y/X Although the Layout was initially authorised, the




is still outstanding. An amendment application has

been submitted and the process is underway. This has

been verified with the EAP undertaking the

amendment.

13.8 Connection routes (including pylon positions) to the distribution/transmission

network;

Y Indicated as required.

13.9 All existing infrastructure on the site, especially roads; Y Indicated as required.

13.10 Buildings including accommodation; Y Indicated as required.

13.11 All "no-go" areas. Y Indicated as required.

13.12 A map combining the final layout plan superimposed on the environmental

sensitivity map. This map must reflect the proposed location of turbines as stated in

the EIR dated April 2012 and this authorisation.

Y Design change amendment approval still outstanding

but in the process.

14 The final layout plan must also be superimposed over an environmental sensitivity

map to be submitted to the department.

Y Design change amendment approval still outstanding

but in the process.

15 The Environmental Management Plan (EMPr) submitted as part of the application for environmental authorisation must be amended and submitted with the

Y The recommendations and mitigation measures were incorporated into the approved EMPr.

Document

Reference

Number



abovementioned layout plan to the Department for written approval prior to

commencement of the activity.

16 The EMPr amendments must include the following:

16.1 The requirements and conditions of this authorisation.

16.2 A plant rescue and protection plan which allows for the maximum transplant of

conservation important species from areas to be transformed.

Y Appendix F of the EMPr.

16.3 An open space management plan to be implemented during the construction and

operation of the facility.

Y Appendix K of the EMPr.

16.4 A re-vegetation and habitat rehabilitation plan to be implemented during the

construction and operation of the facility including timeframes for restoration which

must indicate rehabilitation within the shortest possible time after completion of

construction activities to reduce the amount of habitat converted at any one time

and to speed up the recovery to natural habitats.

Y Appendix G of the EMPr.

16.5 A storm water management plan to be implemented during the construction of the

facility.

Y Appendix I of the EMPr.

16.6 An effective monitoring system to detect any leakage or spillage substances during

their transportation, handling, use and storage.

Y Specifications in EMPr.

16.7 An erosion management plan for monitoring and rehabilitating erosion events

associated with the facility.

Y Specifications in EMPr.

16.8 A transportation plan for the transport of turbine components, main assembly cranes

and other large pieces of equipment.

Y Appendix J of the EMPr.

16.9 An avifauna and bat monitoring programme to document the effect of the

operation of the energy facility on avifauna and bats.

Y Appendix D (avifauna) of the EMPr.

16.10 An environmental sensitivity map indicating environmental sensitive areas and

features identified during the EIA process.


16.11 Measures to protect hydrological features such as streams, rivers, pans, wetlands,

dams and their catchments, and other environmental sensitive areas from construction impacts including the direct or indirect spillage of pollutants.


17 The approved EMPr must be implemented and strictly enforced during all phases of

the project. It shall be seen as a dynamic document and shall be included in all contract documentation for all phases of the development when approved.

Y The recommendations and mitigation measures were

incorporated into the approved EMPr.

18 The provisions of the approved EMPr including are an extension of the conditions of

this EA and therefore noncompliance with them would constitute noncompliance

with the EA.


Environmental Control Officer (ECO) and duties

19 The applicant must appoint a suitably experienced independent Environmental

Control Officer (ECO) for the construction phase of the development that will have

the responsibility to ensure that the mitigation/rehabilitation measures and

recommendations referred to in this authorisation are implemented and to ensure

compliance with the provisions of the EMPr.

Y NCC Environmental Services (Pty) Ltd were

appointed.

20 The ECO shall be appointed before commencement of any authorised activity. Y Evidence of appointment was provided.

21 Once appointed, the name and contact details of the ECO must be submitted to

the Director: Compliance Monitoring of the Department.

Y Evidence of notification to the Department including

CV's and change in ECO were provided.

Document

Reference

Number



22 The ECO shall keep record of all activities on site, problems identified, transgressions

noted, and a task schedule of tasks undertaken by the ECO.

Y ECO Concerns register and Weekly environmental

reports were provided.

23 A detailed incident (including spillage of bitumen, fuels, chemicals, or any other

material) and complaint register must be kept on site indicating how these issues

were addressed, what rehabilitation measures were taken and what preventative

measures were implemented to avoid re-occurrence of incidents/complaints.

Y Weekly environmental reports were provided.

24 In addition, the ECO must maintain the following on site:

24.1 A daily site diary; Y Records kept.

24.2 Copies of all reports submitted to the Department; and Y Noted.

24.3 A schedule of current site activities including the monitoring of such activities. Y Records kept.

25 The ECO shall remain employed until all rehabilitation measures, as required for

ir,1plementation due to construction damage, are completed and the site is ready

for operation.

Y NCC were on site as required.

26 Records relating to monitoring and auditing must be kept on site and made

available for inspection to any relevant and competent authority in respect of this

development.

Y Audit reports and records available.

Environmental audit report

27 All documentation e.g. audit/monitoring/compliance reports and notifications,

required to be submitted to the Department in terms of this authorisation, must be

submitted to the Director: Compliance Monitoring at the Department.


28 The holder of the authorisation must submit an environmental audit report to the

Department within 30 days of completion of the construction phase (i.e. within 30

days of site handover) and within 30 days of completion of rehabilitation activities.

Y NCC completed the required report.

29 The environmental audit report must:

29.1 Be compiled by an independent environmental auditor; Y NCC completed the required report.

29.2 Indicate the date of the audit, the name of the auditor and the outcome of the

audit;

Y

29.3 Evaluate compliance with the requirements of the approved EMPr and this

environmental authorisation;

Y

29.4 Include measures to be implemented to attend to any non-compliances or

degradation noted;

Y

29.5 Include copies of any approvals granted by other authorities relevant to the

development for the reporting period; and

Y

29.6 Highlight any outstanding environmental issues that must be addressed, along with

recommendations for ensuring these issues are appropriately addressed.

Y

30 The audit report must be submitted prior to commencement of the operation phase

of the project.


31 The authorised activity shall not commence within twenty (20) days of the date of

signature of the authorisation.


32 An appeal under section 43 of the National Environmental Management Act

(NEMA), Act 107 of 1998 (as amended), does not suspend an environmental

authorisation or exemption, or any provisions or conditions attached thereto, or any

directive, unless the Minister, MEG or delegated organ of state directs otherwise.


Document

Reference

Number



33 Should you be notified by the Minister of a suspension of the authorisation pending

appeal procedures, you may not commence with the activity until such time that

the Minister allows you to commence with such an activity in writing.


Notification to authorities

34 Fourteen (14) days written notice must be given to the Department that the activity

will commence. Commencement for the purposes of this condition includes site

preparation. The notice must include a date on which it is anticipated that the

activity will commence. This notification period may coincide with the notice of

intent to appeal period.


Operation of the activity


operational phase will commence.


Site closure and decommissioning

36 Should the activity ever cease or become redundant, the applicant shall undertake

the required actions as prescribed by legislation at the time and comply with all

relevant legal requirements administered by any relevant and competent authority

at that time.


Specific conditions

37 A 12-month long bird and bat monitoring programme must be implemented prior to

commencement of construction.


38 The bird and bat monitoring programme must be implemented through to the

operation of the wind energy facility to find the impact of the wind energy facility

on birds and bats.

Y Pre-construction Bat & Bird Monitoring reports were

provided.

Operational monitoring did not commence once the

first turbine started turning as stipulated (which

should've started in Aug 2017). Bird and bat

monitoring commenced in December 2017, by Chris

Van Rooyen and Animalia respectively.

39 The results of the monitoring programme must be used refine, improve and inform

mitigation measures.


40 Reports regarding bird monitoring must be submitted to the relevant provincial

environmental department, Birdlife South Africa, the Endangered Wildlife Trust (EWT),

and this Department on a quarterly basis.

Y Although the Layout was initially authorised, the







amendment.

41 Bird flappers and/or diverters must be installed at all points where powerlines cross

avifaunal corridors, wetlands, drainage line and pans.


42 A 100m buffer zone must be implemented from the edge of all cliffs, scarps and

around rocky outcrops. No wind turbines must be erected within this buffer zone.

Y Some wind turbines were erected within/ on the edge

this buffer zone; however, it was approved by both

DEA and specialists.

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43 No wind turbines must be erected within 1km radius of the Verreaux's Eagle nests. Y Condition was amended to 800m which is complied

with.

44 No wind turbines must be erected within 1.5km of the Martial Eagle nest. Y Nest not displayed on sensitivity map, only Spatial

distribution of medium height flights for Martial Eagle

are recorded in pre-con report.

45 No wind turbines must be erected within 1.5km of the Vendussiekul farm dam. Y Condition was amended to 500m which is complied

with.

46 All plant species of concern must be identified during siting of the wind turbines and

a search and rescue must be undertaken for such plants.


47 There must be continuous monitoring and removal of alien and invasive plant

species within the wind energy facility.

Y Noted and complied with. Weekly & Biodiversity

update reports.

48 Only indigenous plants of the area must be utilised for rehabilitation purposes. Y Noted and complied with.

49 Cleared alien vegetation must not be dumped on adjacent intact vegetation

during clearing but should be temporarily stored in a demarcated area.


50 Contractors and construction workers must be clearly informed of all applicable

buffer zones and no-go areas.


51 There must be no construction of access roads through wetlands and pans. Y/X Although the Layout was initially authorised, the







amendment.

52 No wind turbines, pylons, substations and construction camps must be erected

within 32m of wetlands and drainage lines, and within 75m of pans.


53 Lay down areas and stockyards should be located in low visibility areas. Y Noted and complied with.

54 Liaison with landowners/farm managers is to be done prior to construction in order

to provide sufficient time for them to plan agricultural activities.


55 No unsupervised open fires are allowed on site. Y Noted and complied with.

56 All fuel tanks must be store in a bunded area and constantly monitored for damage

and leakage.


57 Any solid waste shall be disposed of at a landfill licensed in terms of section 20(b) of

the National Environment Management Waste Act, 2008 (Act 59 of 2008).


58 Should any graves or fossil remains be found, all construction activities must be

suspended, and an archaeologist or palaeontologist must be contacted

immediately. The discovered graves must be cordoned off.

Y Noted and complied with. No graves or fossils were

found.

59 A 500m buffer zone must be implemented around farm buildings which are older

than 60 years.

Y/X Although the Layout was initially authorised, the




is still outstanding. An amendment application has been submitted and the process is underway. This has

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amendment.

60 All rock kraals on site must be demarcated and labelled as no go areas. No wind

turbine must be erected within rock kraals.


General

61 A copy of this authorisation and the approved EMPr must be kept at the property

where the activity will be undertaken. The authorisation must be produced to any

authorised official of the Department who requests to see ii and must be made

available for inspection by any employee or agent of the holder of the authorisation

who works or undertakes work at the property.


62 The holder of the authorisation must notify both the Director: Integrated

Environmental Authorisations and the Director: Compliance Monitoring at the

Department, in writing and within 48 (forty-eight) hours, if any condition of this

authorisation cannot be or is not adhered to. Any notification in terms of this

condition must be accompanied by reasons for the non-compliance,


63 National government, provincial government, local authorities or committees

appointed in terms of the conditions of this authorisation or any other public

authority shall not be held responsible for any damages or losses suffered by the

applicant or his successor in title in any instance where construction or operation

subsequent to construction be temporarily or permanently stopped for reasons of

non-compliance by the applicant with the conditions of authorisation as set out in

this document or any other subsequent document emanating from these conditions

of authorisation.


EA Transmission Line

Scope of Authorisation

1

The preferred power line Route Alternative A with the abovementioned co-

ordinates as indicated in the Application for Amendment of the Environmental

Authorisation (date of application 2015), is hereby authorised.


2

Authorisation of the activity is subject to the conditions contained in this

environmental authorisation, which form part of the environmental authorisation

and are binding on the holder of the authorisation.


3

The holder of the amended environmental authorisation is responsible for ensuring

compliance with the conditions contained in this environmental authorisation. This

includes any person acting on the holder's behalf, including but not limited to, an

agent, servant, contractor, sub-contractor, employee, consultant or person

rendering a service to the holder of the authorisation.


ensure conditions of the EA were met. Obligations

towards the EA were included in the contracts issued

to the various sub-contractors/ service providers " –

confirmed in the construction closure report.

4 The activities authorised must only be carried out at the property as described

above.


5

Any changes to. or deviations from. the project description set out in this

environmental authorisation must be approved, in writing, by the Department

before such changes or deviations may be affected. In assessing whether to grant

such approval or not, the Department may request such information as it deems

Y Although the "project description" did not change,

some design changes occurred within the allowable

corridors

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necessary to evaluate the significance and impacts of such changes or deviations

and it may be necessary for the holder of the authorisation to apply for further

environmental authorisation in terms of the regulations.

6

"This activity must commence within a period of five (5) years from the date of issue

of this authorisation. If commencement of the activity does not occur within that

period, the authorisation lapses and a new application for environmental

authorisation must be made in order for the activity to be undertaken."

Y Proof of ownership transfer were provided.

7 Commencement with one activity listed in terms of this environmental authorisation

constitutes commencement of all authorised activities.


8 The holder of an environmental authorisation must notify the competent authority

of any alienation, transfer and change of ownership rights in the property on which

the activity is to take place.

Y The ownership of the EA was transferred to Eskom in

May 2017

Notification of authorisation and right to appeal 9 The holder of the authorisation must notify every registered interested and affected

party, in writing and within 12 (twelve) calendar days of the date of this

environmental authorisation, of the decision to authorise the activity.

Y Records were provided which serves as evidence.

10 The notification referred to must –

1 0.1. specify the date on which the authorisation was issued;

1 0.2. inform the interested and affected party of the appeal procedure provided

for in Chapter 7 of the Environmental Impact Assessment Regulations, 2010;

10.3. advise the interested and affected party that a copy of the authorisation will

be furnished on request; and

10.4. give the reasons of the competent authority for the decision.


11 The holder of the authorisation must publish a notice -

11.1. informing interested and affected parties of the decision;

11.2. informing interested and affected parties where the decision can be

accessed; and

11.3. drawing the attention of interested and affected parties to the fact that an

appeal may be lodged against this decision in the newspaper(s} contemplated

and used in terms of regulation 54(2}(c) and (d) and which newspaper was used for

the placing of advertisements as part of the public participation process.


Management of the activity

12 The Environmental Management Programme (EMPr) submitted as part of the

Application for EA is hereby approved. This EMPr must be implemented and

adhered to.


Monitoring

13 The holder of the authorisation must appoint an experienced independent

Environmental Control Officer (ECO) for the construction phase of the development

that will have the responsibility to ensure that the mitigation/rehabilitation measures

and recommendations referred to in this environmental authorisation are

implemented and to ensure compliance with the provisions of the approved EMPr.


appointed.

13.1 The ECO must be appointed before commencement of any authorised activities. Y Noted and complied with.

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13.2 Once appointed, the name and contact details of the ECO must be submitted to

the Director: Compliance Monitoring of the Department

Y Evidence of notification to the Department including CV’s and change in ECO were provided.

13.3 The ECO must keep record of all activities on site, problems identified, transgressions


Y ECO Concerns register and Weekly environmental reports were provided

13.4 The ECO must remain employed until all rehabilitation measures, as required for

implementation due to construction damage, are completed and the site is ready

for


Recording and reporting to the Department

14 All documentation e.g. audit/monitoring/compliance reports and notifications,

required to be submitted to the Department in terms of this authorisation, must be

submitted to the Director: Compliance Monitoring at the Department.



Department within 30 days of completion of the construction phase (i.e. within 30

days of site handover) and within 30 days of completion of rehabilitation activities.


16 The environmental audit report must indicate the date of the audit, the name of

the auditor and the outcome of the audit in terms of compliance with the

environmental authorisation conditions as well as the requirements of the EMPr.




development.


Commencement of the activities

18 The authorised activity shall not commence within twenty (20) days of the date of


19

An appeal under section 43 of the National Environmental Management Act

(NEMA), Act 107 of 1998 (as amended), does not suspend an environmental

authorisation or exemption, or any provisions or conditions attached thereto, or any

directive, unless the Minister, MEC or delegated organ of state directs otherwise.

20

Should you be notified by the Minister of a suspension of the authorisation pending

appeal procedures, you may not commence with the activity until such time that

the Minister allows you to commence with such an activity in writing.

Notification to authorities

21

Fourteen (14) days written notice must be given to the Department that the activity

will commence. Commencement for the purposes of this condition includes site


activity will commence, as well as a reference number. This notification period may

coincide with the notice of intent to appeal period.



22

Fourteen (14) days written notice must be given to the Department that the activity


NA A letter was sent to Eskom highlighting this condition,

since the ownership of the EA was transferred to

Eskom in May, and operational phase commenced in

July 2017.

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23 Should the activity ever cease or become redundant, the applicant shall

undertake the required actions as prescribed by legislation at the time and comply

with all relevant legal requirements administered by any relevant and competent

authority at that time.

NA Noted.

24

A permit from the Department of Water Affairs must be obtained prior to any

construction that is to be undertaken within 32 meters of all sensitive areas (rivers,

wetlands and riparian zones).


25 Anti-collision devices such as bird flappers must be installed where the power line

crosses avifauna! corridors, pans and drainage lines.


26

The applicant is required to inform the Northern Cape Department of

Environmental Affairs and Nature Conservation and this Department should the

removal of protected species, medicinal plants and "data deficient" plant species

be required.

Y Duly noted by the Licence Holder. No botanical issues

were identified during the detailed survey of the

proposed project area

27 A final walk-through of the alignment must be conducted by a biodiversity

specialist to assist in the placement of the pylons.


28 After construction rehabilitation must be carried out in order to maintain the

functionality of the biodiversity areas and its ecological corridor.


29 Existing access roads must be utilised as much as possible to protect biodiversity

sensitive areas.


30

An integrated waste management approach must be implemented that is based

on waste minimisation and must incorporate reduction, recycling, re-use and

disposal.


31 Any solid waste shall be disposed of at a landfill licensed in terms of section 20 (b) of

the National Environment Management Waste Act, 2008 (Act 59 of 2008).


General

32 A copy of this amended environmental authorisation and the approved EMPr must

be kept at the property where the activity/ will be undertaken. The amended

environmental authorisation and approved EMPr must be produced to any

authorised official of the Department who requests to see it and must be made

available for inspection by any employee or agent of the holder of the amended

environmental authorisation who works or undertakes work at the property.


33 The holder of the amended environmental authorisation must notify both the

Director: Strategic Infrastructure Developments and the Director: Compliance

Monitoring at the Department, in writing and within 48 (forty-eight) hours, if any

condition of this amended environmental authorisation cannot be or is not

adhered to. Any notification in terms of this condition must be accompanied by

reasons for the non-compliance.


34 National government, provincial government, local authorities or committees

appointed in terms of the conditions of this amended environmental authorisation

or any other public authority shall not be held responsible for any damages or losses

suffered by the applicant or his successor in title in any instance where construction

or operation subsequent to construction be temporarily or permanently stopped for


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reasons of non-compliance by the applicant with the conditions of amended

environmental authorisation as set out in this document or any other subsequent

document emanating from these conditions of amended environmental

authorisation.

DENC EA

Scope of Authorisation

1 Authorisation of the activity is subject to the conditions contained in this

authorisation, which conditions form part of the environmental authorisation and are

binding on the holder of the authorisation.

Y Noted

2 The holder of the authorisation shall be responsible for ensuring compliance with the

conditions by any person acting on his or her behalf, including but not limited to, an

agent, sub-contractor, employee or person rendering a service to the holder of the

authorisation.


ensure conditions of the EA were met.

Obligations towards the EA were included in the

contracts issued to the various sub-contractors/

service providers " – confirmed in the construction

closure report.

3 The activity(s) which is authorised must only be carried out at the property indicated

above.


4 Any changes to, or deviations from, the project description set out in this

authorisation must be approved, in writing, by the Department before such changes

or deviations may be affected. In assessing whether to grant such approval or not,

the Department may request such information as it deems necessary to evaluate

the significance and impacts of such changes or deviations and it may be

necessary for the holder of the authorisation to apply fat further authorisation in

terms of the regulations.


5 This authorisation does not negate the holder of the authorisation's responsibility to

comply with any other statutory requirements that may be applicable to the

undertaking of the activity.


General conditions

6 A copy of this authorisation must be kept at the property where the activity will be

undertaken. The authorisation must be produced to any authorised official of the

Department who requests to see it and must be made available for inspection by

any employee or agent of the holder of the authorisation who works or undertakes

work at the property.


7 Where any of the applicant's contact details change, including the name of the

responsible person, the physical or postal address and/ or telephonic details, the

applicant must notify the Department as soon as the new details become known to

the applicant.


8 The holder of the authorisation must notify the Department, in writing and within 24

(TWENTY-FOUR) hours, if condition 16 of this authorisation cannot be or is not adhered

to. In all other cases, the holder of the authorisation must notify the Department, in

writing, within 7 (SEVEN) days if a condition of this authorisation is not adhered to.


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Any notification in terms of this condition must be accompanied by reasons for the

non-compliance.

9 Non-compliance with a condition of this authorisation may result in criminal

prosecution or other actions provided for in the National Environmental

Management Act, 1998 and the regulations.


10 This authorization is subject to the approval by the relevant local authorities i.e. in

terms of any relevant legislation administered by those local authorities.


11 The activity may not commence without the necessary permits/licenses/approvals

and/or service agreements, where it is relevant, from or with the relevant regulatory

authorities whether national, provincial or local (these include but are not limited

to National Department of Environmental Affairs, National Department of

Agriculture, Forestry and Fisheries, Department of Housing & Local Government,

Department of Water Affairs, Department of Minerals Resources, Department of

Transport, Roads & Public Works, Department Arts, Sports & Culture, South African

Heritage Resources Agency, South African Civil Aviation Authority).


12 The activity, including site preparation, may not commence before the thirty (30)

day appeal period expires or until such time as the Department has considered any

appeals that have been lodged.


a One week's written notice must be given to the Administration clerk (Impact

Management Unit) before commencement with the activity.


b Such notice shall make clear reference to the site location details and the reference

number given above.


c The said notice must also include proof of compliance with the following conditions

described herein: conditions 11 and 23.


13 The applicable conditions of this authorization must form part of all contractors' and

sub-contractors' conditions of contract. A performance based requirement with

regard to environmental impact management must be included in all contracts

related to any aspect of this authorization.


14 The applicant must carry out regular environmental audits to establish compliance

with the conditions of this authorization and contracts.

Y Weekly environmental reports were provided.

15 Records relating to the compliance/non-compliance with the conditions of the

authorization and contracts must be kept in good order. Such records must be

made available to the Department within 7 (seven) days of receipt of a written

request by the Department for such records.



16 Any complaints regarding the said development must be brought to the attention

of the Department within 24 (twenty-four) hours after receiving the complaint. A

complaints register must be kept up to date for inspection by the Department.


17 0fficials in the employ of the Department shall be given access to the property as

described above (see detailed description of the activity) for the purposes of

assessing and/or monitoring compliance with the conditions contained in this

Environmental Authorization. Where the activity is located on a third party's property

the applicant shall be responsible to arrange access for departmental officials.

Y Noted.

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18 This Department may add to, change and/or amend any of the conditions in this

authorization if, in the opinion of the Department, the addition, change of

amendment is environmentally justified. In event that such impacts exceed its

significance as predicted in the independent consultant's environmental scoping

report and supporting documentation, the authorization may be withdrawn after

proper procedures were followed.

Y Noted.

19 In the event of any dispute concerning the significance of a particular impact, the

opinion of this department in respect of its significance will prevail.

Y Noted.

20 This Department and any national department, provincial department, local

authorities or committees appointed in terms of the conditions of this application or

any other public authority or organization shall not be held responsible for any

damage of losses suffered by the applicant or his successor in title in any instance

where construction or operation subsequent to construction be temporarily or

permanently stopped for reasons of non- compliance by the applicant with the

conditions of approval as set out in this document or any other subsequent

document emanating from these conditions of approval.

Y Noted.

21 The applicant shall be responsible for all costs necessary to comply with the above

conditions unless otherwise specified.


22 The applicant must apply the principle of best practicable environmental option for

all technologies used/ implemented during construction and operational phases.

Y Noted.

Appeal of authorisation

23 The holder of the authorisation must notify every registered interested and affected

party, in writing and within 12 (TWELVE) calendar days, of the date of the

Department's decision to authorise the activity.


24 The notification referred in 23 must - Y Noted and complied with.

• specify the date on which the authorisation was issued; Y Noted and complied with.

• Inform the interested and affected party of the appeal procedure provided for in

Chapter 7 of the regulations; and


• Advise the interested and affected party that a copy of the authorisation and

reasons for the decision will be furnished on request.


25 If the applicant should appeal against this Environmental Authorisation, he/she must

inform all interested and affected persons that such an appeal is being lodged with

the MEC and if requested, the applicant/appellant must provide those persons with

reasonable access to a full copy of the appeal within a reasonable time before

expiry of the thirty day appeal period.

Y Noted.

Management of activity

26 The Environmental Management Programme ("EMPr'') submitted as part of the

application for environmental authorisation must be implemented.

27 The Environmental Management Programmes is a living document and must be

updated as determined or required.

28 The disturbance of the environment must be restricted to the absolute minimum.

Monitoring and Recording

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26 A site monitoring must be instituted to the satisfaction of this Department; access

routes must be monitored during routine site maintenance visits.


27 This Department retains the right to inspect or monitor the proposed project during

both construction and operation, to ensure that it complies with the legislation and

the conditions stipulated in this Environmental Authorisation.



Department upon the completion of the construction and rehabilitation of the

activities. The environmental audit report must-

Y/X NCC completed the required report but submission to

DENC has not been verified.

• Indicate the date of the audit, the name of the auditor and the outcome of the

audit.


• Records relating to the monitoring and auditing must be kept on site and made


development.


29 The applicant must appoint a suitably experienced Environmental Control Officer

(ECO) for the construction phase of the development that will have the responsibility

to ensure that the mitigation / rehabilitation measures and recommendations

referred to in this authorisation are implemented.


appointed.

30 The ECO shall be appointed before commencement of any land clearing or

construction activities.

Y Evidence of appointment was provided.

31 The ECO shall keep record of all activities on site, problems identified, transgressions




32 The ECO shall remain employed until all rehabilitation measures, as required for

implementation due to construction damage, are completed and the site is ready

for operation.




development.


Commissioning of the activity

34 14 days written notice must be given to the Department that the activity will

commence. Commencement for the purposes of this condition includes site


activity will commence.


35 The authorised activity shall not commence within thirty (30) days of the date of



36 Should you be notified by the minister of a suspension of the authorisation pending

appeal procedures, you shall not commence with the activity unless authorised by

the minister in writing.






38 Any waste generated during construction and operation phase disposed must be

disposed of at a waste disposal site licensed for such waste.


39 No on-site burning of solid waste is permitted. Y Noted and complied with.

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40 All forms of pollution must be prevented, or where it cannot, should be minimized or

remedied.


41 The appropriate toilets must be supplied for the entire construction period and must

be serviced on regular basis.


42 In the event of oil spillages and contamination of soil by hazardous substances that

contaminated area must be cleaned up immediately by removing the

contaminated soil and disposing it off into the designated hazardous skip bin for

correct disposal.


43 Any spillage of diesel and oil must be reported and cleared up immediately. Y Noted and complied with.

44 The clearing of natural vegetation must be limited to the footprint of the

development.


45 The intentional and accidental killing of fauna must be avoided at all times. No

pouching is permitted.


46 The habitat fragmentation must be avoided where possible. Y Noted and complied with.

47 The level of noise during the construction phase of the project must be kept as low

as possible and must comply with the Noise Control Regulations (GN R 154) as well

as the acceptable day rating levels as per the SANS10103:2008 guidelines.


48 Storm water control works must be constructed, operated and maintained in a

sustainable manner throughout the project;


49 Increased runoff due to vegetation clearance and/or soil compaction must be

managed, and steps must be taken to ensure that storm water does not lead to

bank instability and excessive levels of silt entering the water course.


50 Storm water leaving the premises mustn't in any way be contaminated by any

substance, whether such substance is a solid, liquid, vapour, gas or a combination

thereof which is produced, used, stored, dumped or spilled on the premises.


51 All construction activities must be conducted in a manner that does not cause any

damage/effect to the existing wetlands, streams and rivers.


52 Existing and dedicated access roads must be used. Y Noted and complied with.

53 Dust control measures must be implemented during construction phase and must

comply with the dust regulations promulgated under the Air Quality Act, 2004 (Act 39 of 2004).

Y Noted and complied with. Appropriate dust

suppression measures were used.

54 The areas that have been denuded and disturbed as a result of the construction on

site must be vegetated with indigenous vegetation as soon as possible.

Y Noted and complied with. Hydroseeding was done.

55 A monitoring program must be implemented for early detection of alien invasive

plant species and must be in accordance with the Conservation of Agriculture

Resources Act (Act 43 of 1983).


56 No invasive alien plant species may be used in landscaping or rehabilitating the site. Y Noted and complied with.

57 All the areas known to have sensitive archaeological sites must be clearly

demarcated and not disturbed.


58 Old buildings Which have historical significance must be fenced off during

construction phase to avoid vandalism.

Y Noted and complied with. No buildings were

disturbed.

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59 The graves/burials must not be impacted by the construction activities. In the event

of accidental uncovering of graves, work must stop immediately and SAHRA Burial

Unit must be notified.

Y Noted and complied with. No graves were found.

60 If any new evidence of archaeological Sites or artefacts, paleontol0gical fossils,

graves or other heritage resources is found during development or construction,

SAHRA and an archaeologist and/or palaeontologist, depending on the nature of

the resources found, must be alerted immediately.

Y Noted and complied with. No artefacts or fossils were

found.

61 All mitigation measures detailed in the Environmental Management Programme

report must be implemented.



62 In case of decommissioning of the project, the holder of the Environmental

Authorisation must properly rehabilitate the site to the satisfaction of the Directorate:

Environmental Quality Management.


63 The ecosystem integrity must be promoted at all times. Y Noted and complied with.

WEF EMPr

4.3 Specification Data: ENVIRONMENTAL MANAGEMENT (SDEMA)

SDEM 4.3.1 Materials handling, use and storage (Subclause 2.4.11)

The Engineer shall be advised of the areas that the Contractor intends to use for the

stockpiling of both natural and manufactured materials. No stockpiling shall occur

outside of the working area (as designated by the engineer) and without the

Engineer’s prior approval of the proposed stockpiling areas. Imported material shall

be free of litter, contaminants or exotic plant seed. The Contractor shall ensure that

material is not stockpiled along the border of any water body (permanent or

seasonal).


Location and treatment of material stockpiles shall take consideration of prevailing

wind directions and dwellings. Stockpiles shall be stored under cover so as to prevent

erosion and run off during rainy periods. No rubble, earth or other material shall be dumped within the Eskom servitude restriction area.


Topsoil (100 -150 mm) from construction areas where vegetation clearing is required

shall be removed and stockpiled for rehabilitation purposes. This shall be spread over

the top of the turbine foundation after the turbine has been erected and any other disturbed areas which are to be rehabilitated and seeded with indigenous species.

Ground shall be returned as far as possible to original levels/gradients and any

excess material shall not be left in piles but shall be removed off-site.


Dust suppression measures shall be used particularly during dry periods of weather during the summer months.


2.4.12 Dust

*Apx B

As required by the National Dust Control Regulations, promulgated in terms of

section 53(o) of National Environmental Air Quality Act (Act 39 of 2004) the

Contractor shall establish of a network of dust monitoring points using method ASTM

Y/X Ambient quantities of particulate matter were not

measured in accordance with Air Quality Act, 2004

(Act 39 of 2004), however, adequate dust suppression

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D1739: 19702 (or equivalent), sufficient in number to establish the contribution of the

person to dust fall in residential and non-residential areas in the vicinity of the

premises, to monitor identified or likely sensitive receptor locations, and to establish

the baseline dust fall for the district.. The following standards will apply: For residential

areas the dust fallout may not exceed 600mg/m2/day (on a 30-day average) more

than two times a year and not on sequential months. For non-residential areas the

dust fallout may not exceed 1200mg/m2/day (on a 30-day average) more than two

times a year and not on sequential months.

was implemented such as speed limits, dust

suppression etc. on site.

All materials on the construction sites should be properly stored and contained.

Storage of materials and builders’ rubble shall be screened from public view.


Cut material shall be used, where possible in construction or on site (e.g. in grading

gravel roads), or removed from site.


SDEM 4.3.2 Hazardous substances (Subclause 2.4.9.3)

Procedures detailed in the Materials Safety Data Sheets (MSDS) shall be followed in

the event of an emergency situation. Potentially hazardous substances shall be

stored, handled and disposed of as prescribed by the Engineer.


An effective monitoring system to detect any leakage or spillage of all hazardous

substances during their transportation, handling, use and storage shall be

implemented. This shall include precautionary measures to limit the possibility of oil

and other toxic liquids from entering the soil or storm water systems.


Measures should include:

• Daily vehicle inspection to detect any leakages and or spillages.


• Weekly visual inspection of plant and standing equipment. Y Noted and complied with.

• Weekly visual inspection of fuel tanks. Y Noted and complied with.

• A record of these inspections needs to be kept to demonstrate compliance. Y Noted and complied with.

• The contractor needs to provide a method statement for “emergency procedures

to deal with leakage and spillage of hazardous substances”.


• Spill remediation kits shall be kept on site and all staff members shall be informed

of where it is located.


SDEM 4.3.3 Shutter oil and curing compound (Subclause 2.4.9.1)

Shutter oil and curing compound shall be stored and dispensed within a bunded

area, and not located closer than 32m from the top of the riverbanks/water

courses/drainage lines.


4.4 Requirements

SDEM 4.4.1 Ablution facilities (Subclause 2.4.20)

A sufficient number of chemical toilets shall be provided by the Contractor in the

construction camp area and at appropriate locations approved by the Engineer.

Temporary/ portable toilets shall not be located within 100 m from the top of the

riverbanks/water courses/drainage lines. The ratio of ablution facilities for workers

should not be less than that required by the Construction Regulations of 2003 of the

Occupational Health and Safety Act. All temporary/ portable toilets shall be

secured to the ground to prevent them from toppling due to wind or any other cause.


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SDEM 4.4.2 Solid Waste Management (Subclause 2.4.9)

The contractor shall be required to prepare a method statement to indicate how

and where solid waste will be disposed of based on the following requirements:


• Hazardous waste

o Hazardous wastes shall only be disposed at landfill sites registered for

hazardous waste;


Spills or leaks of construction hazardous materials including, but not limited to,

concrete curing compounds, asphalt products, paints, petroleum products from

equipment operation and maintenance, pesticides and herbicides shall be

monitored and remediated immediately if detected.


All hazardous waste materials must be carefully stored as advised by the ECO, and

then disposed of at a licensed landfill site.


No hazardous waste may be buried or burned under any circumstances.

Y Noted and complied with. Except for explosive

associated waste, which according to explosives act

has to be burnt on site, which happened in a

controlled manner.

A certificate of disposal by shall be obtained the Contractor and kept on file, if

relevant.


o MSDS shall be available for all hazardous substances stored on site. Y Noted and complied with.

o Appropriate hazardous waste spill kits shall be available on site. Y Noted and complied with.

o An approved waste disposal contractor must be employed to remove and

recycle waste oil, if practical.

Y Noted and complied with. Oil recycling not feasible.

o Burying or burning of solid waste shall not be allowed.




controlled manner.

• General waste

o Regular disposal of general waste to registered landfill sites shall be required to

prevent nuisance factors such as odours, vermin and flies. No burning of waste shall

be allowed.


o Provide adequate waste bins. Y Noted and complied with.

o Set up system for regular waste removal to an approved landfill facility. Y Noted and complied with.

o Minimise waste by sorting wastes into recyclable and non-recyclable wastes, if

practical.


o No waste may be buried or burned under any circumstances. Y Noted and complied with.

o A housekeeping team should be appointed to regularly maintain the litter and

rubble situation on the construction site.


o Littering by the employees shall not be allowed under any circumstances. Y Noted and complied with.

o The ECO shall monitor the neatness of the work sites as well as the Contractor

campsite.


o Skip waste containers should be maintained on site. These should be kept covered

and arrangements made for them to be collected regularly to prevent vermin and

odours.


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o A certificate of disposal by shall be obtained the Contractor and kept on file, if

relevant.


SDEM 4.4.3 Contaminated Water (Subclause 2.4.7)

The Contractor shall prevent the discharge of any pollutants, such as soaps,

detergents, cements, concrete, lime, chemicals, hydrocarbons, glues, solvents,

paints and wastewater into the surrounding terrestrial and aquatic environment. No

discharge would be allowed, and all contaminated soil, contaminated water and

hazardous materials shall be disposed at a registered facility.


SDEM 4.4.4 Site Structures (Subclause 2.3)

No site structures shall be located within 32 m from the top of the riverbanks/water

courses/drainage lines. Construction yards should be restricted in extent as far as

possible and should be screened by visually impermeable material. No structures to

be occupied or frequented by people shall be built within delineated servitude

areas.


Ensure the construction yards are neat and tidy at all times. Site offices, if required,

should be limited to single storey and should be sited carefully using temporary

screen fencing to screen from the wider landscape.


SDEM 4.4.5 Noise control (Subclause 2.4.4)

Construction traffic shall be routed as far as practically possible from potentially

sensitive receptors.


A good working relationship between the contractor and all potentially sensitive

receptors shall be ensured by establishing communication channels to ensure prior

notice to the sensitive receptor if work is to take place close to them. Information

that should be provided to the potential sensitive receptor(s) include:

Y Noted and complied with. No noise related

complaints were received during construction phase.

o Proposed working times; Y Noted and complied with.

o how long the activity is anticipated to take place; Y Noted and complied with.

o what is being done, or why the activity is taking place; Y Noted and complied with.

o contact details of a responsible person where any complaints can be lodged

should there be an issue of concern.


When working within 500 m of a potential sensitive receptor, the number of simultaneous activities (e.g. construction of access roads, trenches, etc) shall be

limited to the minimum as far as possible. Furthermore, working time shall be co-

ordinated with periods when the receptors are not at home, where possible. An

example would be to work within the 08:00 to 14:00 timeslot to minimize the

significance of the impact because potential receptors are most likely at school or

at work, minimizing the probability of an impact happening.

Y Noted and complied with. Farm occupants were >500m from activities.

Use of the smallest/quietest equipment for the particular purpose shall be

considered.


Ensure that equipment is well-maintained and fitted with the correct and

appropriate noise abatement measures.


2.4.5 Lighting

*Apx B The Contractor shall ensure that any lighting installed on the site for his activities does

not interfere with road traffic or cause a reasonably avoidable disturbance to the


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surrounding community or other users of the area. Subject to meeting the minimum

requirements of the OHSA and general security, lighting shall be kept to the

minimum. Care will be taken to ensure lighting is task specific and does not spill into

the surrounding environment through appropriate placement and shielding.

Floodlighting of expansive work areas or up- or down lighting of vertical structures or

natural features shall only be permitted if approved by Engineer.

SDEM 4.4.6 Fuel (Petrol and Diesel) and oil (Subclause 2.4.6)

Fuels in the form of diesel and petrol shall not be stored within 32 m from the top of

the riverbanks/water courses/drainage lines.


SDEM 4.4.7 Equipment Maintenance and Storage (Subclause 2.4.10)

A designated area with an impermeable surface shall be available for the washing

of equipment and vehicles. Wastewater generated from the washing of vehicles

and equipment shall drain via an oil and water separator into a bunded area. The

oil should be removed as required by a registered service provider to a register

facility. The water accumulated in the bunded area can evaporate. If solids area

accumulated in the bunded area over time, if should be removed by a registered

contractor and disposed at a registered facility. Wastewater generated from

construction or the washing of vehicles shall not be permitted to enter water courses,

either directly or via a stormwater system.

Y Noted and complied with. Only wastewater from

concrete wash-bays were applicable.

SDEM 4.4.8 Stormwater Erosion Control (Add Section 2.4.8)

The Contractor shall take reasonable measures to control the erosive effects of

stormwater runoff. Any runnels or erosion channels developed during the

construction period or during the maintenance period shall be backfilled and

compacted to limit the impacts of sediment deposition into the surrounding aquatic

environment.


A stormwater management plan shall be implemented (see Appendix I). The plan

shall ensure compliance with applicable regulations and prevent off-site migration

of contaminated storm water or increased soil erosion. The plan shall include the

appropriate measures that allow surface and subsurface movement of water along

drainage lines so as not to impede natural surface and subsurface flows. Drainage

measures shall promote the dissipation of storm water run-off.


Run-off over any exposed areas should be mitigated to reduce the rate and volume

of run-off and prevent erosion occurring on the site and within the freshwater

features and drainage lines. Contaminated runoff from the construction site(s)

should be prevented from entering the rivers/streams.


SDEM 4.9 Method Statements (Subclause 2.2)

The following additional method statements shall be provided by the Contractor

within 14 days of the receipt of the Letter of Acceptance and prior to the activity

covered by the Method Statement being undertaken: • Logistics for the

environmental awareness course for all the Contractors employees.


• Emergency procedures for fire, accidental leaks and spillages of hazardous

materials including:


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o who shall be notified in the event of an emergency, including contact numbers

for the relevant local authority,

o where and how any hazardous spills will be disposed of,

o the size of spillage which the emergency procedures could contain,

o location of all emergency equipment and an indication of how regularly the

emergency equipment will be checked to ensure that it is working properly.

• Location and layout of the construction camp in the form of a plan showing

offices, stores for fuels, hazardous substances, vehicle parking, access point,

equipment cleaning areas and staff toilet placement.


• Location, layout and preparation of cement/concrete batching facilities including

the methods employed for the mixing of concrete and the management of runoff

water for such areas. An indication shall be given of how concrete spoil will be

minimised and cleared.


• Method of undertaking earthworks, including spoil management, erosion, dust

and noise controls.


• Method of undertaking blasting. Y Noted and complied with.

• Method to detect leakages based on Section 4.3.2. Y Noted and complied with.

• Management measures to be undertaken in instances where traffic flows may be

interrupted.


• Extent of areas to be cleared, the method of clearing and the preparation for this

clearing so as to ensure minimisation of exposed areas.


• Measures to be put in place during temporary closure periods, e.g. December

holidays.


• Measures to be put in place to limit sediment deposition into the surrounding

terrestrial and aquatic environment.


• Method statement on integrated waste management shall be compiled by the

contractor based on SDEM 4.4.2.


SDEM 4.4.10 Site Clearance (Subclause 2.7.1)

Removal of vegetation (uprooting) must be kept to a minimum. Only those areas

where it is imperative to remove vegetation i.e. construction areas, identified

storage areas, roads and minor tracks should be cleared. If uprooting is required,

the Contractor shall store the top


material and root material of cleared vegetation (top 300 mm layer), for subsequent

use during rehabilitation and re-vegetation. All other areas should remain

vegetated. If brush-cutting is required as a minimum intervention, this should be

applied with discretion; however, it would always be preferred to uprooting. If

vehicle movement is required off designated roads and tracks, it would be

advisable to drive over the shrubs (crush) rather than to uproot them. This would

prevent loss of these shrubs since they would be able to regrow if not uprooted.


The Contractor shall not make use of herbicides or other chemical methods to clear

the proposed site especially near the identified water courses. In order to limit

erosion, the Contractor shall retain original groundcover, as far as practically


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possible, adjacent to the aquatic environment and to the trenching line as per the

Revegetation and Rehabilitation Plan in Appendix G.

SDEM 4.4.11 No go areas (Subclause 2.3.3)

All works to be undertaken shall be within the boundary of the site, refer to the Open

Space Management Plan in Appendix K. A “no go” area shall extend on either side

of the working area i.e. all areas outside of the defined working area and

designated access roads. The working area shall be demarcated in an appropriate

manner determined by the Engineer.


Based on the ecological importance, all construction activities shall remain outside

of all aquatic environments, with special efforts implemented to maintain a 32 m

buffer between construction related activities and any rivers/water

courses/drainage lines. These no go areas shall stay in place until construction of the

infrastructure within the buffer area must commence.


No equipment associated with earthworks shall be allowed outside of the site and

defined access routes, or within “no go” areas, unless expressly permitted by the

Engineer.


The recommended ecological sensitivity and buffer areas indicated in Figure 1 shall

be demarcated as “no go” areas and construction activities shall remain outside

these designated areas.


No mechanical equipment, including mechanical excavators or high lifting

machinery, shall be used in the vicinity of Eskom’s apparatus and/or services, without

prior written permission having been granted by Eskom. If such permission is granted

the Contractor must give at least seven working days’ notice prior to the

commencement of work. This allows time for arrangements to be made for

supervision and/or precautionary instructions to be issued by the relevant Eskom

Manager Note: Where and electrical outage is required, at least fourteen workdays

are required to arrange it.


2.3.2 Site fencing and demarcations

*Apx B

The Contractor shall not damage or remove any boundary fences without the

agreement of the adjoining landowner. Where property fences are replaced these

shall, at the minimum, meet specification of the fencing it replaces, in terms of top

height, sturdiness and rigidity (pole foundations and supports and strength and wire

gauge), security (barbed or razor wire) and size of the largest openings (i.e.

distances between horizontal wires or mesh dimensions.


2.4.1 Protection of natural features

*Apx B

The Contractor shall not deface, paint, damage or mark any natural features (e.g.

rock formations) situated in or around the Site for survey or other purposes unless

agreed beforehand with the Engineer. Any features affected by the Contractor in

contravention of this clause shall be restored/ rehabilitated to the satisfaction of the

Engineer.


SDEM4.4.12 Protection of flora and fauna (Subclause 2.4.2)

A Revegetation and Rehabilitation Plan, included in Appendix G, shall be

implemented. The specialist shall recommend species to be used in rehabilitation as


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well as any special measures for rehabilitation, such as shade-netting and alien

vegetation removal. Restoration shall be undertaken as soon as possible after

completion of construction activities to reduce the amount

Rehabilitation of site camp area

2.7.13 Temporary revegetation of the areas disturbed by construction

*Apx B

e) The prepared area shall be hydro- or hand-seeded at a rate of 40 kg/ha using a

suitable indigenous grass species or Rye grass (Lolium multiflorum). In the event of

hand-seeding, the seed mixture as specified shall be mixed with two parts per

volume of clean dry plaster sand, then divided in half and applied evenly in two

successive applications, one after the other, by means of an approved hand

seeding machine (known colloquially as a “tefsaaier”). On completion of the

seeding the surface shall be lightly raked to cover the seed with no more than 5 mm

of soil.

Y Noted and complied with. Hydroseeding was done.

of habitat converted at any one time and to speed up the recovery to natural

habitats. A Plant Rescue and Protection Plan, included in Appendix F, shall be

implemented. This plan will be compiled by a vegetation specialist familiar with the

site and be implemented prior to commencement of the construction phase.


No flora shall be removed or damaged, outside of the designated working area,

without specialist botanical input.


The collection of firewood by construction workers should be prohibited. Y Noted and complied with.

Any snakes found on site shall be removed from site and released into an area away

from the site, without harm.


The contractor shall ensure that the time a trench is left exposed is kept to a

minimum, and that open trenches are inspected on a daily basis for animals which

may have fallen or become trapped. Any animals found trapped in any trenches

shall be freed without harm.


The Alien Invasive Management Plan, included in Appendix H, shall be

implemented.

Y Noted and complied with. No aliens observed on site.

An Open Space Management Plan, included in Appendix K, shall be implemented. Y Noted and complied with.

Noise shall be reduced and maintained to a minimum particularly with regards to

blasting on the ridge-top associated with excavations for foundations. Blasting


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should not take place during the breeding seasons of the resident avifaunal

community and in particular for priority species. Blasting shall be kept to a minimum

and, where possible, synchronized with neighbouring blasts.

Disturbance associated with the operation of the facility shall be minimised, by

scheduling maintenance activities to avoid and/or reduce disturbance in sensitive

areas at sensitive times – such areas will be identified during the pre-construction

and operational monitoring.


An avifauna and bat monitoring programme, included in Appendices D and E, shall

be implemented.


provided.






*3.1

Implement long-term [Avifauna] monitoring to inform design, construction,

operation and decommissioning of the project. The long-term monitoring

programme shall be compiled by a qualified avifaunal specialist to meet the

requirements of the Avifaunal Impact Assessment conducted as part of the EIA.


provided.






*EMP Apx.E Implement an Operational Phase Bat Monitoring programme (included in Appendix

E).


provided.






SDEM 4.4.13 Protection of archaeological and paleontological remains (Subclause 4.4.3)

Should substantial fossil remains be exposed during construction, these should be

safeguarded by the ECO, preferably in situ, and the South African Heritage

Resources Association (SAHRA) should be notified by the ECO immediately so that

appropriate mitigation can be undertaken.


A general buffer of 500m is recommended for the distance between a heritage site

and development including access roads (such as Zwagershoek and Pienaarskloof).

Y/X Although the Layout was initially authorised, the







amendment.

Areas known to have sensitive archaeological sites shall be avoided. Y Noted and complied with.

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Old buildings shall be fenced off during construction to avoid vandalism of the

buildings, kraal complexes must be avoided, and access roads re-routed to avoid

damage to the buildings.

Y Except for the Enkeldebult farm building which was

used as offices, in consultation with and approval

from the heritage specialist.

SDEM 4.4.14 Access routes/ haul roads (Subclause 2.4.18)

Eskom’s rights and services shall be acknowledged and respected at all times.

Unobstructed access shall be granted to Eskom to access their servitudes.


The contractor shall ensure that all regulations relating to traffic management are

observed and local traffic officials are informed of the proposed construction

activities. As far as possible, attempts shall be made to ensure that high construction

related road usage coincides with low traffic flow periods. If the roads through De

Aar of Phillipstown are used as the access road, make use of this road only between

08h00 to 17h00 Monday to Friday for construction traffic.


Signage and safety measures during the construction of the access roads shall

comply with the guidelines as set out in the latest issue of the SADC Road Traffic Signs

Manual. Standard “construction ahead” warning signs should be placed on all

relevant roads in the area. Ensure access roads are kept clean and storage of

materials is screened.


A traffic management plan for the site access roads shall be compiled and

implemented to ensure that no hazards would results from the increased truck traffic

and that traffic flow would not be adversely impacted. This plan shall include

measures to minimize impacts on local commuters e.g. limiting construction vehicles

travelling on public roadways during the morning and late afternoon commute time

and avoid using roads through densely populated built-up areas so as not to disturb

existing retail and commercial operations.

Y Transportation Plan provided. Site access road was in

rural area with minimal traffic

A transportation plan shall be compiled and implemented for the transport of

turbine components, main assembly cranes and other large pieces of equipment.

The transportation plan will only be undertaken once the origin of all components,

main assembly cranes and other large pieces of equipment is known (Appendix J).


2.4.18 Access routes / haul roads

*Apx B

Unless inside the urban edge or part of an environmental authorisation in terms of

NEMA R544 Activity No. 22. (II) no new construction road shall exceed 8m or where

such road already exists be widened by more than 6m or lengthened by more than

1000m.


SDEM 4.4.15 Cement and concrete batching (Subclause 2.7.3)

No cement and / or concrete batching shall occur within the “no-go” areas or within

32 m from the top of riverbanks/water courses/drainage lines. Reasonable measures

shall be implemented to limit contaminated surface run-off into the surrounding

vegetation.


SDEM 4.4.16 Earthworks (Subclause 2.7.4)

Any blasting is to be executed by a suitably qualified person. Y Noted and complied with.

Controlled blasting techniques shall be employed to minimise dust and fly rock

during blasting.


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The use of explosives of any type within 500 m of Eskom’s services shall only occur

with Eskom’s previous written permission. If such permission is granted the Contractor

must give at least fourteen working days prior notice of the commencement of

blasting. This allows time for arrangements to be made for supervision and/or

precautionary instructions to be issued in terms of the blasting process. It is advisable

to make application separately in this regard.


Prior to blasting the Contractor shall notify the relevant occupants/ owners of

surrounding land and address any concerns. Buildings within the potential

damaging zone of the blast shall be surveyed preferably with the owner present,

and any cracks or latent defects pointed out and recorded either using

photographs or video. All Local Authority regulations are to be adhered to and all

service infrastructures are to be located prior to commencement of blasting

activities.


Blasting or drilling shall take place during normal working hours. The Contractor shall

notify emergency services, in writing, a minimum of 24 hours prior to any blasting

activities commencing on site. Adequate warning must be issued to all personnel on

site prior to blasting activities taking place. All legally required signals are to be

clearly indicated. The Engineer shall be issued daily updates of the days intended

blasting activities.


The Contractor shall prevent damage to special features and the general

environment, which includes the removal of flyrock. Damage caused by blasting /

drilling shall be repaired to the satisfaction of the Engineer.


Minimise areas disturbed at any one time and protect exposed soil against wind

erosion, e.g. by dampening with water or covering with hessian.


Changes in ground level may not infringe statutory ground to conductor clearances

or statutory visibility clearances with respect to existing powerlines onsite.

Clearances between Eskom’s live electrical equipment and the proposed

construction work shall be observed as stipulated in terms of Regulation 15 of the

Electrical Machinery Regulations of the Occupational Health and Safety Act, 1993

(Act 85 of 1993) at all times.


SDEM 4.4.17 Community relations (Subclause 2.6)

Maintain a register that shall contain details of the measures taken to resolve

complaints and the details of the communication of these measures to the person

who raised the complaint.


*DENC EA 16 Any complaints must be brought to the attention of the Dept within 24h and a

complaints register kept up to date.


2.4.13 Aesthetics

*Apx B

The Contractor shall take reasonable measures to ensure that construction activities

do not have an unreasonable impact on the aesthetics of the area. Measures will

be taken to obscure construction yards and associated plant and equipment from


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onlookers as far as is reasonable. Refer also to 2.4.4 regarding requirements for

lighting.

2.4.14 Disruption to existing and neighbouring land use activities

*Apx B The Contractor shall take measures to limit the disruption of any existing land use

activities occurring on the site or neighbouring sites as far as reasonable.


2.4.15 Temporary site closure

*Apx B If the site is closed for a period exceeding one week, the Contractor, in consultation

with the Engineer shall carry out [the specified] checklist procedure.


2.4.16 Public roads

*Apx B

Where road safety may be impacted on the Contractor shall notify the relevant

roads authority and arrange for the necessary road warning signage and appoint

trained points men to control traffic around any hazards. Any damage caused to

the public road system as a result of construction or as a direct result of construction

vehicles and equipment shall be repaired to the satisfaction of the Engineer.

Y

Although there were some issues during construction

phase, these have now been resolved.

*Apx B

On gravel or earth roads on Site and within 500 m of the Site, the vehicles of the

Contractor and his suppliers shall not exceed a speed of 20 km/h. Mud and sand

deposited onto public roads by construction activities shall be cleared on a daily

basis.


2.4.17 Security and access control

*Apx B

The Contractor shall ensure that access to the Site and associated infrastructure and

equipment is off-limits to the public at all times during construction. If so required, as

directed by the Engineer, the Contractor shall fence the site to ensure effective

control of access to the site.


SDEM 4.4.18 Erosion and sedimentation control (Subclause 2.7.7)

Erosion control measures, as included in Appendix I, shall be implemented to

minimise erosion at excavation / clearing sites or aggregate storage sites. Where

necessary, sedimentation barriers shall be laid between the Work Area and the “no-

go” areas to limit sediment deposition. The sedimentation barrier shall consist of a

geotextile fabric stretched across and attached to supporting posts and stabilised

with sandbags. The barrier shall be inspected daily and any damage shall be

repaired immediately. Sediment deposits shall be removed once they reach half the

height of the barrier.

Y Noted and complied with. Storm water management

plan in place.

Minimise duration and extent of construction activities in the river. Construction shall

also preferably take place in the low flow season. Where access routes need to be

constructed through ephemeral streams, disturbance of the channel should be

limited.


Clearing of debris, sediment and hard rubble associated with the construction

activities should be undertaken post construction to ensure that flow within the

drainage channels are not impeded or diverted. Rehabilitate disturbed stream bed

and banks and revegetation with suitable indigenous vegetation.


SDEM 4.4.19 Site closure and rehabilitation (Subclause 2.7.12)

All construction debris found within the disturbed areas shall be removed and

disposed of at a registered landfill site.


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A Vegetation Rehabilitation Plan, included in Appendix G, shall be implemented.

The construction footprint associated with the activity shall be re-vegetated with

indigenous vegetation, as directed by this rehabilitation plan. Rehabilitation of

disturbed areas shall commence as soon construction of the specific section have

been completed.


SDEM 4.4.20 Labour requirements

Equipment shall be regarded electrically live and therefore dangerous at all times.

Safety and best practice standards with regards to all safety hazards related to

electrical plant shall be employed for the development.


Recruitment shall be based on sound labour practices and with gender equality in

mind. Obtain a list of locally available labour and skills. Preference shall be given to

local communities.


Appropriate training shall be provided to enable individuals to apply their skills to

other construction and development projects in the region once the construction

phase is completed.


EMPr Transmission Line

General

The EMP for DA1-Tx has followed exactly the same template as the EMP for DA2N-WEF, which was managed by the same Principle contractor (Longyuan Engineering) in the

same way. Therefore, please refer to the EMP for DA2N-WEF below:

Since duplicate info exist in the EMP, only the conditions relating to the Specification Data requiring compliance were listed and scored. Each paragraph item *Noteworthy

conditions/ subclauses added from: GENERAL ENVIRONMENTAL SPECIFICATION FOR CONSTRUCTION (Apx B)

*Specific conditions which are not referred to in the EMP for DA2N-WEF, which were applicable for the EMP for DA1-Tx are included below:

4.3 Specification Data: ENVIRONMENTAL MANAGEMENT (SDEMA)

SDEM 4.3.1 Materials handling, use and storage (Subclause 2.4.11)

The Engineer shall be advised of the areas that the Contractor intends to use for the

stockpiling of both natural and manufactured materials. No stockpiling shall occur

outside of the working area (as designated by the engineer) and without the

Engineer’s prior approval of the proposed stockpiling areas. Imported material shall

be free of litter, contaminants or exotic plant seed. The Contractor shall ensure that material is not stockpiled along the border of any water body (permanent or

seasonal).


Location and treatment of material stockpiles shall take consideration of prevailing

wind directions and dwellings. Stockpiles shall be stored under cover so as to prevent erosion and run off during rainy periods. No rubble, earth or other material shall be

dumped within the Eskom servitude restriction area.


Topsoil (100 -150 mm) from construction areas where vegetation clearing is required

shall be removed and stockpiled for rehabilitation purposes. This shall be spread over the top of the turbine foundation after the turbine has been erected and any other

disturbed areas which are to be rehabilitated and seeded with indigenous species.

Ground shall be returned as far as possible to original levels/gradients and any

excess material shall not be left in piles but shall be removed off-site.


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Dust suppression measures shall be used particularly during dry periods of weather

during the summer months.


2.4.12 Dust

*Apx B

As required by the National Dust Control Regulations, promulgated in terms of

section 53(o) of National Environmental Air Quality Act (Act 39 of 2004) the

Contractor shall establish of a network of dust monitoring points using method ASTM

D1739: 19702 (or equivalent), sufficient in number to establish the contribution of the

person to dust fall in residential and non-residential areas in the vicinity of the

premises, to monitor identified or likely sensitive receptor locations, and to establish

the baseline dust fall for the district.. The following standards will apply: For residential

areas the dust fallout may not exceed 600mg/m2/day (on a 30-day average) more

than two times a year and not on sequential months. For non-residential areas the

dust fallout may not exceed 1200mg/m2/day (on a 30-day average) more than two

times a year and not on sequential months.

Y/X Ambient quantities of particulate matter were not

measured in accordance with Air Quality Act, 2004

(Act 39 of 2004), however, adequate dust suppression

was implemented such as speed limits, dust

suppression etc. on site.

All materials on the construction sites should be properly stored and contained.

Storage of materials and builders’ rubble shall be screened from public view.


Cut material shall be used, where possible in construction or on site (e.g. in grading

gravel roads) or removed from site.


SDEM 4.3.2 Hazardous substances (Subclause 2.4.9.3)

Procedures detailed in the Materials Safety Data Sheets (MSDS) shall be followed in

the event of an emergency situation. Potentially hazardous substances shall be

stored, handled and disposed of as prescribed by the Engineer.


An effective monitoring system to detect any leakage or spillage of all hazardous

substances during their transportation, handling, use and storage shall be

implemented. This shall include precautionary measures to limit the possibility of oil

and other toxic liquids from entering the soil or storm water systems.


Measures should include: • Daily vehicle inspection to detect any leakages and or

spillages.


• Weekly visual inspection of plant and standing equipment. Y Noted and complied with.

• Weekly visual inspection of fuel tanks. Y Noted and complied with.

• A record of these inspections needs to be kept to demonstrate compliance. Y Noted and complied with.

• The contractor needs to provide a method statement for “emergency procedures

to deal with leakage and spillage of hazardous substances”.


• Spill remediation kits shall be kept on site and all staff members shall be informed

of where it is located.


SDEM 4.3.3 Shutter oil and curing compound (Subclause 2.4.9.1)

Shutter oil and curing compound shall be stored and dispensed within a bunded

area, and not located closer than 32m from the top of the riverbanks/water courses/drainage lines.


4.4 Requirements

SDEM 4.4.1 Ablution facilities (Subclause 2.4.20)

A sufficient number of chemical toilets shall be provided by the Contractor in the

construction camp area and at appropriate locations approved by the Engineer.


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Temporary/ portable toilets shall not be located within 100 m from the top of the

river banks/water courses/drainage lines. The ratio of ablution facilities for workers

should not be less than that required by the Construction Regulations of 2003 of the

Occupational Health and Safety Act. All temporary/ portable toilets shall be

secured to the ground to prevent them from toppling due to wind or any other

cause.

SDEM 4.4.2 Solid Waste Management (Subclause 2.4.9)

The contractor shall be required to prepare a method statement to indicate how

and where solid waste will be disposed of based on the following requirements:


• Hazardous waste

o Hazardous wastes shall only be disposed at landfill sites registered for hazardous

waste;


Spills or leaks of construction hazardous materials including, but not limited to,

concrete curing compounds, asphalt products, paints, petroleum products from

equipment operation and maintenance, pesticides and herbicides shall be

monitored and remediated immediately if detected.


All hazardous waste materials must be carefully stored as advised by the ECO, and

then disposed of at a licensed landfill site.


No hazardous waste may be buried or burned under any circumstances.




controlled manner.

A certificate of disposal by shall be obtained the Contractor and kept on file, if

relevant.


o MSDS shall be available for all hazardous substances stored on site. Y Noted and complied with.

o Appropriate hazardous waste spill kits shall be available on site. Y Noted and complied with.

o An approved waste disposal contractor must be employed to remove and

recycle waste oil, if practical.

Y Noted and complied with. Oil recycling not feasible.

o Burying or burning of solid waste shall not be allowed.




controlled manner.

• General waste

o Regular disposal of general waste to registered landfill sites shall be required to

prevent nuisance factors such as odours, vermin and flies. No burning of waste shall

be allowed.


o Provide adequate waste bins. Y Noted and complied with.

o Set up system for regular waste removal to an approved landfill facility. Y Noted and complied with.

o Minimise waste by sorting wastes into recyclable and non-recyclable wastes, if

practical.


o No waste may be buried or burned under any circumstances. Y Noted and complied with.

o A housekeeping team should be appointed to regularly maintain the litter and

rubble situation on the construction site.


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o Littering by the employees shall not be allowed under any circumstances. Y Noted and complied with.

o The ECO shall monitor the neatness of the work sites as well as the Contractor

campsite.


o Skip waste containers should be maintained on site. These should be kept covered

and arrangements made for them to be collected regularly to prevent vermin and

odours.


o A certificate of disposal by shall be obtained the Contractor and kept on file, if

relevant.


SDEM 4.4.3 Contaminated Water (Subclause 2.4.7)

The Contractor shall prevent the discharge of any pollutants, such as soaps,

detergents, cements, concrete, lime, chemicals, hydrocarbons, glues, solvents,

paints and wastewater into the surrounding terrestrial and aquatic environment. No

discharge would be allowed, and all contaminated soil, contaminated water and

hazardous materials shall be disposed at a registered facility.


SDEM 4.4.4 Site Structures (Subclause 2.3)

No site structures shall be located within 32 m from the top of the riverbanks/water

courses/drainage lines. Construction yards should be restricted in extent as far as

possible and should be screened by visually impermeable material. No structures to

be occupied or frequented by people shall be built within delineated servitude

areas.


Ensure the construction yards are neat and tidy at all times. Site offices, if required,

should be limited to single storey and should be sited carefully using temporary

screen fencing to screen from the wider landscape.


SDEM 4.4.5 Noise control (Subclause 2.4.4)

Construction traffic shall be routed as far as practically possible from potentially

sensitive receptors.


A good working relationship between the contractor and all potentially sensitive

receptors shall be ensured by establishing communication channels to ensure prior

notice to the sensitive receptor if work is to take place close to them. Information

that should be provided to the potential sensitive receptor(s) include:

Y Noted and complied with. No noise related

complaints were received during construction phase.

o Proposed working times; Y Noted and complied with.

o how long the activity is anticipated to take place; Y Noted and complied with.

o what is being done, or why the activity is taking place; Y Noted and complied with.

o contact details of a responsible person where any complaints can be lodged

should there be an issue of concern.


When working within 500 m of a potential sensitive receptor, the number of

simultaneous activities (e.g. construction of access roads, trenches, etc) shall be

limited to the minimum as far as possible. Furthermore, working time shall be co-

ordinated with periods when the receptors are not at home, where possible. An

example would be to work within the 08:00 to 14:00 timeslot to minimize the

significance of the impact because potential receptors are most likely at school or

at work, minimizing the probability of an impact happening.

Y Noted and complied with. Farm occupants were

>500m from activities.

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Use of the smallest/quietest equipment for the particular purpose shall be

considered.


Ensure that equipment is well-maintained and fitted with the correct and

appropriate noise abatement measures.


2.4.5 Lighting

*Apx B

The Contractor shall ensure that any lighting installed on the site for his activities does

not interfere with road traffic or cause a reasonably avoidable disturbance to the

surrounding community or other users of the area. Subject to meeting the minimum

requirements of the OHSA and general security, lighting shall be kept to the

minimum. Care will be taken to ensure lighting is task specific and does not spill into

the surrounding environment through appropriate placement and shielding.

Floodlighting of expansive work areas or up- or down lighting of vertical structures or

natural features shall only be permitted if approved by Engineer.


SDEM 4.4.6 Fuel (Petrol and Diesel) and oil (Subclause 2.4.6)

Fuels in the form of diesel and petrol shall not be stored within 32 m from the top of

the riverbanks/water courses/drainage lines.


SDEM 4.4.7 Equipment Maintenance and Storage (Subclause 2.4.10)

A designated area with an impermeable surface shall be available for the washing

of equipment and vehicles. Wastewater generated from the washing of vehicles

and equipment shall drain via an oil and water separator into a bunded area. The

oil should be removed as required by a registered service provider to a register

facility. The water accumulated in the bunded area can evaporate. If solids area

accumulated in the bunded area over time, if should be removed by a registered

contractor and disposed at a registered facility. Wastewater generated from

construction or the washing of vehicles shall not be permitted to enter water courses,

either directly or via a stormwater system.

Y Noted and complied with. Only wastewater from

concrete wash-bays were applicable.

SDEM 4.4.8 Stormwater Erosion Control (Add Section 2.4.8)

The Contractor shall take reasonable measures to control the erosive effects of

stormwater runoff. Any runnels or erosion channels developed during the

construction period or during the maintenance period shall be backfilled and

compacted to limit the impacts of sediment deposition into the surrounding aquatic

environment.


A stormwater management plan shall be implemented (see Appendix I). The plan

shall ensure compliance with applicable regulations and prevent off-site migration

of contaminated storm water or increased soil erosion. The plan shall include the

appropriate measures that allow surface and subsurface movement of water along

drainage lines so as not to impede natural surface and subsurface flows. Drainage

measures shall promote the dissipation of storm water run-off.


Run-off over any exposed areas should be mitigated to reduce the rate and volume

of run-off and prevent erosion occurring on the site and within the freshwater

features and drainage lines. Contaminated runoff from the construction site(s)

should be prevented from entering the rivers/streams.


SDEM 4.9 Method Statements (Subclause 2.2)

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The following additional method statements shall be provided by the Contractor

within 14 days of the receipt of the Letter of Acceptance and prior to the activity

covered by the Method Statement being undertaken: • Logistics for the

environmental awareness course for all the Contractors employees.


• Emergency procedures for fire, accidental leaks and spillages of hazardous

materials including:

o who shall be notified in the event of an emergency, including contact numbers

for the relevant local authority,

o where and how any hazardous spills will be disposed of,

o the size of spillage which the emergency procedures could contain,

o location of all emergency equipment and an indication of how regularly the

emergency equipment will be checked to ensure that it is working properly.


• Location and layout of the construction camp in the form of a plan showing

offices, stores for fuels, hazardous substances, vehicle parking, access point,

equipment cleaning areas and staff toilet placement.


• Location, layout and preparation of cement/concrete batching facilities including

the methods employed for the mixing of concrete and the management of runoff

water for such areas. An indication shall be given of how concrete spoil will be

minimised and cleared.


• Method of undertaking earthworks, including spoil management, erosion, dust

and noise controls.


• Method of undertaking blasting. Y Noted and complied with.

• Method to detect leakages based on Section 4.3.2. Y Noted and complied with.

• Management measures to be undertaken in instances where traffic flows may be

interrupted.


• Extent of areas to be cleared, the method of clearing and the preparation for this

clearing so as to ensure minimisation of exposed areas.


• Measures to be put in place during temporary closure periods, e.g. December

holidays.


• Measures to be put in place to limit sediment deposition into the surrounding

terrestrial and aquatic environment.


• Method statement on integrated waste management shall be compiled by the

contractor based on SDEM 4.4.2.


SDEM 4.4.10 Site Clearance (Subclause 2.7.1)

Removal of vegetation (uprooting) must be kept to a minimum. Only those areas

where it is imperative to remove vegetation i.e. construction areas, identified

storage areas, roads and minor tracks should be cleared. If uprooting is required,

the Contractor shall store the top


material and root material of cleared vegetation (top 300 mm layer), for subsequent

use during rehabilitation and re-vegetation. All other areas should remain

vegetated. If brush-cutting is required as a minimum intervention, this should be

applied with discretion; however, it would always be preferred to uprooting. If

vehicle movement is required off designated roads and tracks, it would be


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advisable to drive over the shrubs (crush) rather than to uproot them. This would

prevent loss of these shrubs since they would be able to regrow if not uprooted.

The Contractor shall not make use of herbicides or other chemical methods to clear

the proposed site especially near the identified water courses. In order to limit

erosion, the contractor shall retain original groundcover, as far as practically

possible, adjacent to the aquatic environment and to the trenching line as per the

Revegetation and Rehabilitation Plan in Appendix G.


SDEM 4.4.11 No go areas (Subclause 2.3.3)

All works to be undertaken shall be within the boundary of the site, refer to the Open

Space Management Plan in Appendix K. A “no go” area shall extend on either side

of the working area i.e. all areas outside of the defined working area and

designated access roads. The working area shall be demarcated in an appropriate

manner determined by the Engineer.


Based on the ecological importance, all construction activities shall remain outside

of all aquatic environments, with special efforts implemented to maintain a 32 m

buffer between construction related activities and any rivers/water

courses/drainage lines. These no go areas shall stay in place until construction of the

infrastructure within the buffer area must commence.


No equipment associated with earthworks shall be allowed outside of the site and

defined access routes, or within “no go” areas, unless expressly permitted by the

Engineer.


The recommended ecological sensitivity and buffer areas indicated in Figure 1 shall

be demarcated as “no go” areas and construction activities shall remain outside

these designated areas.


No mechanical equipment, including mechanical excavators or high lifting

machinery, shall be used in the vicinity of Eskom’s apparatus and/or services, without

prior written permission having been granted by Eskom. If such permission is granted

the Contractor must give at least seven working days’ notice prior to the

commencement of work. This allows time for arrangements to be made for

supervision and/or precautionary instructions to be issued by the relevant Eskom

Manager Note: Where and electrical outage is required, at least fourteen workdays

are required to arrange it.


2.3.2 Site fencing and demarcations

*Apx B

The Contractor shall not damage or remove any boundary fences without the

agreement of the adjoining landowner. Where property fences are replaced these

shall, at the minimum, meet specification of the fencing it replaces, in terms of top

height, sturdiness and rigidity (pole foundations and supports and strength and wire

gauge), security (barbed or razor wire) and size of the largest openings (i.e.

distances between horizontal wires or mesh dimensions.


2.4.1 Protection of natural features

*Apx B

The Contractor shall not deface, paint, damage or mark any natural features (e.g.

rock formations) situated in or around the Site for survey or other purposes unless

agreed beforehand with the Engineer. Any features affected by the Contractor in


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contravention of this clause shall be restored/ rehabilitated to the satisfaction of the

Engineer.

SDEM4.4.12 Protection of flora and fauna (Subclause 2.4.2)

A Revegetation and Rehabilitation Plan, included in Appendix G, shall be

implemented. The specialist shall recommend species to be used in rehabilitation as

well as any special measures for rehabilitation, such as shade-netting and alien

vegetation removal. Restoration shall be undertaken as soon as possible after

completion of construction activities to reduce the amount of habitat converted at

any one time and to speed up the recovery to natural habitats. A Plant Rescue and

Protection Plan, included in Appendix F, shall be implemented. This plan will be

compiled by a vegetation specialist familiar with the site and be implemented prior

to commencement of the construction phase.

Y Noted and complied with. Revegetation not feasible

because of the relatively small disturbed areas, but

ripping and top soiling occurred to restore natural

vegetation.

2.7.13 Temporary revegetation of the areas disturbed by construction

*Apx B

e) The prepared area shall be hydro- or hand-seeded at a rate of 40 kg/ha using a

suitable indigenous grass species or Rye grass (Lolium multiflorum). In the event of

hand-seeding, the seed mixture as specified shall be mixed with two parts per

volume of clean dry plaster sand, then divided in half and applied evenly in two

successive applications, one after the other, by means of an approved hand

seeding machine (known colloquially as a “tefsaaier”). On completion of the

seeding the surface shall be lightly raked to cover the seed with no more than 5 mm

of soil.


because of the relatively small disturbed areas, but

ripping and top soiling occurred to restore natural

vegetation.

No flora shall be removed or damaged, outside of the designated working area,

without specialist botanical input.


The collection of firewood by construction workers should be prohibited. Y Noted and complied with.

Any snakes found on site shall be removed from site and released into an area away

from the site, without harm.


The contractor shall ensure that the time a trench is left exposed is kept to a

minimum, and that open trenches are inspected on a daily basis for animals which

may have fallen or become trapped. Any animals found trapped in any trenches

shall be freed without harm.


The Alien Invasive Management Plan, included in Appendix H, shall be

implemented.

Y Noted and complied with. No aliens observed on site.

An Open Space Management Plan, included in Appendix K, shall be implemented. Y Noted and complied with.

Noise shall be reduced and maintained to a minimum particularly with regards to

blasting on the ridge-top associated with excavations for foundations. Blasting

should not take place during the breeding seasons of the resident avifaunal

community and in particular for priority species. Blasting shall be kept to a minimum

and, where possible, synchronized with neighbouring blasts.


Disturbance associated with the operation of the facility shall be minimised, by

scheduling maintenance activities to avoid and/or reduce disturbance in sensitive

areas at sensitive times – such areas will be identified during the pre-construction

and operational monitoring.


2.4 Mitigation measures during the construction phase

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Avifauna

Prior to construction commencing, an inspection should be performed by the

avifaunal specialist to record any large raptor nests on the existing transmission lines

that could be impacted by the construction of the proposed De Aar 1

Maanhaarberg 132 kV line.


All the spans, except those spans that are located adjacent to two or more high

voltage lines, should be marked with Bird Flight Diverters on the earth wire of the line,

ten metres apart, alternating black and white. Appendix B of the Avifauna report

indicates the preferred BFDs to be used.


The new transmission line should be marked with bird flight diverters along its entire

length and that all new power line infrastructure is adequately insulated and of a

configuration that is bird friendly.


SDEM 4.4.13 Protection of archaeological and palaeontological remains

Should substantial fossil remains be exposed during construction, these should be

safeguarded by the ECO, preferably in situ, and the South African Heritage

Resources Association (SAHRA) should be notified by the ECO immediately so that

appropriate mitigation can be undertaken.

Y Noted and complied with. No remains were exposed.

2.4. Mitigation measures during the construction phase

Paleontological mitigation measures

A palaeontologist must monitor all construction activities in the areas identified as

being moderate to highly palaeontological sensitive in Figure 21 of the submitted

heritage report. This palaeontologist must advise on pylon positions to limit negative

impact to significant palaeontological heritage. A monitoring report must be

submitted to SAHRA once work is completed.

Y Noted and complied with. A monitoring report was

submitted to

SAHRA.

A Palaeontologist should be appointed as part of the Environmental Construction

Team for preferably all identified paleontological sensitive areas but definitely for

the identified highly sensitive areas.


SDEM 4.4.14 Access routes/ haul roads (Subclause 2.4.18)

Eskom’s rights and services shall be acknowledged and respected at all times.

Unobstructed access shall be granted to Eskom to access their servitudes.


The contractor shall ensure that all regulations relating to traffic management are

observed and local traffic officials are informed of the proposed construction

activities. As far as possible, attempts shall be made to ensure that high construction

related road usage coincides with low traffic flow periods.


Signage and safety measures during the construction of the access roads shall

comply with the guidelines as set out in the latest issue of the SADC Road Traffic Signs

Manual. Standard “construction ahead” warning signs should be placed on all

relevant roads in the area. Ensure access roads are kept clean and storage of

materials is screened.


A traffic management plan for the site access roads shall be compiled and

implemented to ensure that no hazards would results from the increased truck traffic

and that traffic flow would not be adversely impacted. This plan shall include


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measures to minimize impacts on local commuters e.g. limiting construction vehicles

travelling on public roadways during the morning and late afternoon commute time

and avoid using roads through densely populated built-up areas so as not to disturb

existing retail and commercial operations.

2.4.18 Access routes / haul roads

*Apx B

Unless inside the urban edge or part of an environmental authorisation in terms of

NEMA R544 Activity No. 22. (II) no new construction road shall exceed 8m or where

such road already exists be widened by more than 6m or lengthened by more than

1000m.


SDEM 4.4.15 Cement and concrete batching (Subclause 2.7.3)

No cement and / or concrete batching shall occur within the “no-go” areas or within

32 m from the top of riverbanks/water courses/drainage lines. Reasonable measures

shall be implemented to limit contaminated surface run-off into the surrounding

vegetation.


SDEM 4.4.16 Earthworks (Subclause 2.7.4)

Any blasting is to be executed by a suitably qualified person. Y Noted and complied with.

Controlled blasting techniques shall be employed to minimise dust and fly rock

during blasting.


The use of explosives of any type within 500 m of Eskom’s services shall only occur

with Eskom’s previous written permission. If such permission is granted the Contractor

must give at least fourteen working days prior notice of the commencement of

blasting. This allows time for

Y

Noted and complied with. Blasting notifications given.

arrangements to be made for supervision and/or precautionary instructions to be

issued in terms of the blasting process. It is advisable to make application separately

in this regard.


Prior to blasting the Contractor shall notify the relevant occupants/ owners of

surrounding land and address any concerns. Buildings within the potential

damaging zone of the blast shall be surveyed preferably with the owner present,

and any cracks or latent defects pointed out and recorded either using

photographs or video. All Local Authority regulations are to be adhered to and all

service infrastructures are to be located prior to commencement of blasting

activities.


Blasting or drilling shall take place during normal working hours. The Contractor shall

notify emergency services, in writing, a minimum of 24 hours prior to any blasting

activities commencing on site. Adequate warning must be issued to all personnel on

site prior to blasting activities taking place. All legally required signals are to be

clearly indicated. The Engineer shall be issued daily updates of the days intended

blasting activities.


The Contractor shall prevent damage to special features and the general

environment, which includes the removal of flyrock. Damage caused by blasting /

drilling shall be repaired to the satisfaction of the Engineer.


Minimise areas disturbed at any one time and protect exposed soil against wind

erosion, e.g. by dampening with water or covering with hessian.


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Changes in ground level may not infringe statutory ground to conductor clearances

or statutory visibility clearances with respect to existing powerlines onsite.

Clearances between Eskom’s live electrical equipment and the proposed

construction work shall be observed as stipulated in terms of Regulation 15 of the

Electrical Machinery Regulations of the Occupational Health and Safety Act, 1993

(Act 85 of 1993) at all times.


SDEM 4.4.17 Community relations (Subclause 2.6)

Maintain a register that shall contain details of the measures taken to resolve

complaints and the details of the communication of these measures to the person

who raised the complaint.


*DENC EA 16 Any complaints must be brought to the attention of the Dept within 24h and a

complaints register kept up to date.


2.4.13 Aesthetics

*Apx B

The Contractor shall take reasonable measures to ensure that construction activities

do not have an unreasonable impact on the aesthetics of the area. Measures will

be taken to obscure construction yards and associated plant and equipment from

onlookers as far as is reasonable. Refer also to 2.4.4 regarding requirements for

lighting.


2.4.14 Disruption to existing and neighbouring land use activities

*Apx B The Contractor shall take measures to limit the disruption of any existing land use

activities occurring on the site or neighbouring sites as far as reasonable.


2.4.15 Temporary site closure

*Apx B If the site is closed for a period exceeding one week, the Contractor, in consultation

with the Engineer shall carry out [the specified] checklist procedure.


2.4.16 Public roads

*Apx B

Where road safety may be impacted on the Contractor shall notify the relevant

roads authority and arrange for the necessary road warning signage and appoint

trained points men to control traffic around any hazards. Any damage caused to

the public road system as a result of construction or as a direct result of construction

vehicles and equipment shall be repaired to the satisfaction of the Engineer.


*Apx B

On gravel or earth roads on Site and within 500 m of the Site, the vehicles of the

Contractor and his suppliers shall not exceed a speed of 20 km/h. Mud and sand

deposited onto public roads by construction activities shall be cleared on a daily

basis.


2.4.17 Security and access control

*Apx B

The Contractor shall ensure that access to the Site and associated infrastructure and

equipment is off-limits to the public at all times during construction. If so required, as

directed by the Engineer, the Contractor shall fence the site to ensure effective

control of access to the site.


SDEM 4.4.18 Erosion and sedimentation control (Subclause 2.7.7)

Erosion control measures, as included in Appendix I, shall be implemented to

minimise erosion at excavation / clearing sites or aggregate storage sites. Where necessary, sedimentation barriers shall be laid between the Work Area and the “no-

Y Noted and complied with. Storm water berms were

reinstated on servitude roads.

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go” areas to limit sediment deposition. The sedimentation barrier shall consist of a

geotextile fabric stretched across and attached to supporting posts and stabilised

with sandbags. The barrier shall be inspected daily and any damage shall be

repaired immediately. Sediment deposits shall be removed once they reach half the

height of the barrier.

Minimise duration and extent of construction activities in the river. Construction shall

also preferably take place in the low flow season. Where access routes need to be

constructed through ephemeral streams, disturbance of the channel should be

limited.


Clearing of debris, sediment and hard rubble associated with the construction

activities should be undertaken post construction to ensure that flow within the

drainage channels are not impeded or diverted. Rehabilitate disturbed stream bed

and banks and revegetation with suitable indigenous vegetation.


SDEM 4.4.19 Site closure and rehabilitation (Subclause 2.7.12)

All construction debris found within the disturbed areas shall be removed and

disposed of at a registered landfill site.


A Vegetation Rehabilitation Plan, included in Appendix G, shall be implemented.

The construction footprint associated with the activity shall be re-vegetated with

indigenous vegetation, as directed by this rehabilitation plan. Rehabilitation of

disturbed areas shall commence as soon construction of the specific section have

been completed.


because of the relatively small disturbed areas around

monopoles, however ripping and top soiling occurred

to restore natural vegetation.

SDEM 4.4.20 Labour requirements

Equipment shall be regarded electrically live and therefore dangerous at all times.

Safety and best practice standards with regards to all safety hazards related to

electrical plant shall be employed for the development.


Recruitment shall be based on sound labour practices and with gender equality in

mind. Obtain a list of locally available labour and skills. Preference shall be given to

local communities.


Appropriate training shall be provided to enable individuals to apply their skills to

other construction and development projects in the region once the construction

phase is completed.


Operational Phase EMP (OEMP): Operational Management Programme Framework

Environmental Management documentation and procedures

Page No. Aspect

Impact

Mitigation Measure:

(Objective and Mechanism) Performance Indicator

Y/X/NA Findings & Recommendations

4

Environmental

Management

documentation

and procedures.

No framework

within which to

locate the

management

of the

operational

phase.

No procedures

against which to

assess

environmental

performance

during the

operational

phase and thus

no measure of

compliance

Objective:

To ensure that the operation of the WEF does not result in avoidable impacts on the environment and that any

impacts that do occur are anticipated and managed.

Mechanism:

1. Appoint a suitably qualified

Environmental Manager (EM) to

monitor compliance (either

independent on in- house).

Environmental impacts

effectively monitored and

managed during the

operational phase.

Comprehensive record of

compliance and

remedial actions

available to the

authorities

Y

Andrew Doughty has been appointed

as the designated EM on site, De Aar.

2. Audit the compliance with the

requirements of the environmental

specification contained within the

OEMP

Y

BI Annual Audits are conducted by

an external party as is conducted in

terms of this checklist and report for

August 2018. The previous audit

conducted was during May 2019.

5

Protection of the

surrounding

Impacts of the

operation and

maintenance of

the WEF on the

surrounding

Objective:

To maintain minimised footprints of disturbance of vegetation/habitats on-site.

To ensure and encourage plant regrowth in areas of post-construction rehabilitation.

Mechanism:

1. Vehicle movements will be

restricted to designated roadways

No further disturbance to

Y Vehicles strictly stayed inbounds of the

roads network within the WEF.

Page No. Aspect

Impact

Mitigation Measure:



environment (aquatic and

terrestrial)

environment (including local

flora, fauna, bats,

avifauna and

watercourses

around the

proposed

development)

2. Existing roads will be maintained

to ensure limited erosion and

impact on areas adjacent to

roadways.

vegetation.

Continued improvement

in rehabilitation

efforts.

Y The roads within the project area

were observed to be in good

condition throughout the full

geographic scope of the project.

3. Implementation of the

Revegetation and Rehabilitation Plan

(Appendix 10).

Y It was observed that the area in

which rehab and revegetation was

conducted in the areas required. An

annual botanical inspection has

been conducted on the 25th of May

2018.

Previous batch plant and site camp

rehabilitated.

Former stockpile area with some

vegetation recovery

Page No. Aspect

Impact

Mitigation Measure:



4. Implementation of the Alien

Vegetation Removal Programme

Y A local contractor (de Aar Electric)

has been appointed (co-signed

appointment on the 8th of March

2018 to conduct alien clearing on the

WEF site.

This is on an as and when required

basis as there is a low concentration of

invasive plants present on site.

Areas are monitored by Longyuan

EM and De Aar Electric and removal

of vegetation is conducted on as

and when required basis.

5. Ongoing implementation of the

Storm Water Management Plan

(Appendix 14) to ensure compliance

with applicable regulations and

prevent off-site migration of

contaminated storm water or

increased soil erosion.

Y A storm water management system

was observed in the vicinity of the

substation. Various potentially

hazardous areas are either bunded off

or separate from the storm water

system. It was also observed that cut

off V- drains existed in the area.

6. Ensure ongoing implementation of

Open Space Management Plan

(Appendix 15).

Y

Various recommended measures

have been implemented on site

such as no-go areas, designated

roads, etc.

6 Protection of

avifauna

Disturbance to

or loss of birds

as a result

collision with

the turbine

blades.

Disturbance to or

loss of birds as a

result of collision

with the

overhead power

line.

Objective:

To reduce the impact of the operating WEF on priority bird species

Mechanisms: Displacement

1) The results of the pre-construction

monitoring have already been

incorporated into the final turbine

layout, resulting in an 800m turbine

exclusion zone around the core

Verreaux’s Eagle nest cluster. This

exclusion zone must be respected

at all times.

No additional disturbance

to avifaunal populations

on the WEF site.


to avifaunal populations

along the length of the

power line route.

Y Buffers are maintained.

Page No. Aspect

Impact

Mitigation Measure:



Electrocution as a result of the

power line.

2) Formal monitoring should be resumed

once the turbines become operational,

as per the Birdlife SA/EWT best practice

guidelines. The purpose of this would be

to establish if displacement of priority

species has occurred and to what

extent. The exact time when post-

construction monitoring should

commence, will depend on the

construction schedule, and will be

agreed upon with the developer once

these timelines have been finalised

(Avifaunal Post- Construction Monitoring

Programme included in Appendix D).


of avifaunal protection

efforts

Y Weekly inspections are currently being undertaken by Ladybirds

(Pty) Ltd along with a weekly report

being compiled which highlights

any collisions/mortalities.

Weekly reports as well as a

Quarterly report and a collision

register.

Bird and bat carcasses are labelled and

stored in a freezer

3) The duration of the post-

construction monitoring (i.e. the

replication of the baseline

monitoring) would need to be for at

least an equivalent period to the pre-

construction monitoring (four seasons), and another two years

thereafter. During the initial four

seasons period the scope for the

subsequent monitoring will be

determined and agreed to with the

developer

Y

It has been indicated in the Scope of

Works agreed upon with the Avifaunal Specialist that monitoring will be

conducted for the first two years.

This audit cycle constitutes the 2nd

year of monitoring.

4) Construction activity should be

restricted to the immediate footprint

of the infrastructure, and in particular

to the proposed road network.

Access to the remainder of the site

should be strictly prohibited to

prevent unnecessary disturbance of

priority species.

Y

A dedicated network of internal roads

is used to access the site.

All construction activity footprints have

been kept to a minimum.

No additional construction has been

conducted.

5) It is strongly recommended that the

construction of turbines S05, S30 and

NA Noted.

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S35, especially blasting activities,

should take place in the period

November to April i.e. outside the

core breeding season for Verreaux’s

Eagle.

Protection of

avifauna

Collisions with Turbines

6) The results of the pre-construction

monitoring have already been

incorporated into the final turbine

layout, resulting in a 100m setback

from the plateau edge. This exclusion

zones must be respected at all times.

Y It has been indicated that no further

construction has occurred on site to

date, hence no encroachment with in

the 100m plateau setback line as

indicated in the site layout map.

7) Formal monitoring should be

resumed once the turbines become

operational, as per the Birdlife

SA/EWT best practice guidelines

(see previous section

Displacement). The duration of the

post-construction monitoring would

need to be for at least an

equivalent period to the pre-

construction monitoring (four

seasons); and for at least two years

thereafter. Thereafter the need for

additional monitoring will be

determined and agreed to with the

developer. The purpose of this

would be (a) to establish if

displacement of priority species has

occurred and to what extent

through the altering of flight

patterns post-construction, and

(b) to search for carcasses at

turbines (Avifaunal Post-

Construction Monitoring

Programme included in

Appendix D).

Y

Weekly inspections are currently

being undertaken by Ladybirds (Pty)

Ltd along with a weekly report being

compiled which highlights any

collisions/mortalities. Weekly reports

as well as a Quarterly report has been

observed by the auditor.

Evidence of monitoring taking place

was provided for in the form of a

collision register.

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8) The environmental management plan should provide for the on-

going inputs of a suitable

experienced ornithological

consultant to oversee the post-

construction monitoring and assist

with the on-going management of

bird impacts that may emerge as

the post-construction monitoring

programme progresses (adaptive

management). Depending on the

results of the carcass searches, a

range of mitigation measures will

have to be considered if mortality

levels turn out to be significant. This

may include the selective

curtailment of specific turbines

during high risk periods e.g. in the

three-month post-fledging

period when the juvenile Verreaux’s

Eagle is learning to fly and hunt.

Y A proposed strategy for the mitigation of raptor- unfriendly poles on the 33kv

network was compiled where

recommendations were provided.

.

Mortality with the associated power lines

9) Prior to the electrification of the

wind farm, an on-site “walk-through”

should be conducted by the

ornithological consultant to identify

the sections of power line between

the turbines which require marking

with Bird Flight Diverters as an anti-

collision measure.

Y A walk through was conducted on

the 26th July and 10 August 2016

where various areas were identified

for Bird Diverters to be installed. Bird

diverters were observed to be in

place on identified lines. This was

addressed in the audit report

compiled in February 2018.

10) During the operational phase,

regular surveys of the intra-turbine

power lines will be conducted as part

of the post-construction monitoring

programme to assess if there are

collision mortalities, and any additional

spans identified as high risk should be

marked with Bird Flight Diverters. In

addition to that, the 132kV grid

Y

Weekly inspections are undertaken by

Ladybirds (Pty) Ltd along with a weekly

report being compiled.

A collision monitoring report was

provided for highlighting collision

occurrences.

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connection will also be inspected at

least once a quarter to establish if

there are any significant collision

mortality.

11) The ornithological consultant

should communicate on a constant

basis with the design engineers to

ensure that the proposed pole design for the intra-turbine power lines will

not pose an electrocution risk to large

raptors. The final pole design should

be submitted to the ornithological

consultant for approval.

Y

Consultation with the avifaunal

specialist was continual throughout.

A proposed strategy for the

mitigation of raptor- unfriendly poles

on the 33kv network was compiled

where recommendations were

provided. Perches have been installed.

Protection of

bats and fauna

Disturbance to or

loss of fauna

including bats,

and/or habitat.

Direct mortalities

Objective:

To minimise impacts on fauna, including bats.

Mechanisms:

1) Vehicle movements to be

restricted to designated roadways.


to fauna populations on

the WEF site.


of fauna protection

efforts

Y There was no evidence of vehicles

deviating from designated access

roads. The landowner also accesses

the area in order to conducting

farming.

2) Adherence to reduced vehicle

speeds by all vehicles moving on

site.

Y Site induction is conducted with

all visitors to site in which vehicle

restrictions are conveyed.

3) A buffer area of 100 m should

apply to all high sensitivity areas

(refer to Figure 1).

Y

The 100m buffer was still in place.

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4) Operational monitoring must be

carried out for a minimum period of 2

years as soon as the first turbine is

turning, regardless of whether it is

freewheeling during construction or

connected to the grid (Post-

Construction Bat Monitoring

Programme included in Appendix E).

Y

Installation of bat detector

microphones has been

undertaken and weekly surveys

are undertaken to assess bat

mortalities.

Quarterly reports with regards to

bat monitoring that are

compiled.

5) Operational monitoring must

always comply with methodology

and sampling standards laid out in

the latest version of the SABAAP

Operational Guidelines at Wind

Energy Facilities.

Y

The correct equipment has been

installed as per the requirements.

6) If it is found during operation that

mitigation is required, a preliminary

recommendation would be that

curtailment mitigation initiates at

Level 2 (see below) for the periods,

times and weather conditions

determined from operational and

pre- construction monitoring to be

causing significant bat mortalities.

Y

Due to the low impact no mitigation

measures are currently required.

7) If such mitigation is undertaken,

then depending on the results of the

post construction mortality

monitoring, the mitigation may be

relaxed or intensified (moving down

or up in the levels listed below) up to

a maximum intensity of Level 4 (see

below).

Y

Noted.

8) An adaptive mitigation management

approach must be taken that requires

changes in the mitigation plan to be

implemented immediately and in real

time during the post construction

monitoring.

Y Noted.

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9) Missing climatic data over periods that is significant for bat activity must

be gathered by the developer, these

climatic data gaps are indicated in

the Final Preconstruction Monitoring

report.

Y Missing climactic data has been

retrieved

A basic "5 levels of mitigation" (by blade manipulation or curtailment), from light to aggressive mitigation is presented

below:

1. No curtailment (freewheeling is

unhindered below manufacturers cut

in speed, so all momentum is retained,

thus, normal operation).

Y As per engineering design

2. 90 Degree feathering of blades

below manufacturers cut-in speed, so

it is exactly parallel to the wind

direction as to minimise free-wheeling

blade rotation as much as possible

without locking the blades.


3. 90 Degree feathering of blades

below manufacturers cut in speed,

with reduced power mode settings

between manufacturer’s cut-in speed

and mitigation cut-in conditions.


4. 90 Degree feathering of blades below mitigation cut in conditions.


5. 90 Degree feathering throughout the

entire night.

Y Noted.

Appropriate

handling and

management of

Litter of

contamination

of the site or

Objective:

To minimise the production of waste. To ensure appropriate waste disposal. To avoid environmental harm from waste

disposal.

Mechanisms:

1.) Hazardous substances must be stored in sealed containers within a

clearly demarcated bunded area.

No complaints received regarding waste on site or

indiscriminate dumping.

Internal site audits identifying

Y No hazardous chemicals are stored on site except for the operational oil

within the transformer stations.

All transformers on situated on an

impermeable bunded surface.

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hazardous substances and

waste.

water through poor waste

management

practices

2.) All structures and/or components

replaced during maintenance

activities must be appropriately

disposed of at an appropriately

licenced waste disposal site or sold to

a recycling merchant for recycling.

that waste segregation recycling and re-use is taking

place.

No contamination of soil or

water.

Y No large-scale component

replacement has as yet been

conducted.

3.) Care must be taken to ensure that

spillage of oils and other hazardous

substances are limited during

maintenance. Handling of these

materials should take place within an

appropriately sealed and bunded

area. Should any accidental spillage

take place, it will be cleared up

according to specified standards for

bioremediation.

Y

Spill kits are available on site for small

spill.

Spill kits on site

The project has an agreement in

place with a specialist service

provider to handle larger spills.

4.) Used oil and chemicals will be

appropriately disposed at a licenced

facility.

Y

No hazardous substances have been

disposed of to date.

5.) General waste will be recycled

where possible or disposed of at a licenced facility.

Y Due to the small volumes of waste

recycling is deemed not to be viable,

at present waste is disposed of at the

local municipal landfill facility, if the

amount of waste increases over time

the Licence Holder will explore the

option of recycling.

6.) Hazardous waste (including

hydrocarbons) and general

waste will be stored and

disposed of separately.

Y

General and Hazardous Waste

Stored separately.

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7.) Disposal of waste will be in

accordance with relevant legislative

requirements, including the use of

licenced contractors.

Y General waste is disposed of at the

municipality with records being kept

on site

Visual Aesthetics

Impact of the

proposed

development on

the surrounding

visual aesthetics

of the area

Objectives:

To ensure that impacts on the visual aesthetics are minimised during the operational phase.

Mechanisms:

1.) During operation, the maintenance

of the turbines, the internal roads, the

power line servitude and other

ancillary structures and infrastructure

will ensure that the facility does not

degrade, thus aggravating visual

impact.

Condition of the project

infrastructure and roads.

Y

Ongoing maintenance occurs daily.

2.) Turbines should not display brand

names.

Y

No branding visible.

Environmental

management of

the operational

phase

Positive impacts

on socio-

economic

environment

during operation

Objectives:

To ensure that the operation of the wind energy facility maximises positive impacts on the socio-economic environment.

Mechanisms:

1) Train local people for operation

and maintenance of facility.

Consult annual skills and

training records,

employment records and

proof of staff residency in the

area prior to employment.

Y The Lady Birds (Pty) Ltd is a local

company which is involved in bird

collision monitoring who received

training from the Project Specialist. De

Aar Electric (Pty) Ltd has received

training for to various skills and activities

relevant to site.

2) Employ local labour for the

operational phase, where possible,

and particularly for day to day

operations and maintenance.

Y

The Lady Birds (Pty) Ltd is a local

company which is involved in bird

collision monitoring.

Adenco is a local electrical contractor

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employed on site. De Aar Electric is a company that has been locally

sourced and is responsible for general

site maintenance and alien vegetation

clearing.

11

Protection of

Eskom

infrastructure

Impact of the

proposed

development on

the Eskom

powerlines

Objectives:

To ensure that the operation of the WEF does not result in avoidable impacts on the Eskom powerlines.

Mechanisms:

1.) Liaise with Eskom to come to an

agreement regarding suitable risk

mitigation measures to be put into

place for operational management.

Compliance with Eskom’s

guidelines.

Y

Bird Diverters have been placed on

the 132kV line as a mitigation

measure prior to being handed over

to ESKOM.

2.) No mechanical equipment,

including mechanical excavators or

high lifting machinery, shall be used

in the vicinity of Eskom’s apparatus

and/or services, without prior written

permission having been granted by

Eskom.

If such permission is granted the

Contractor must give at least seven

working days’ notice prior to the

commencement of work. This allows

time for arrangements to be made

for supervision and/or precautionary

instructions to be issued by the

relevant Eskom Manager.

Note: Where and electrical outage

is required, at least fourteen

workdays are required to arrange it.

Y

Work permit required when working on

site, when working in vicinity of

ESKOM powerlines the Project notifies

accordingly.

No communication regarding this

condition to date.

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3.) Unobstructed access shall be

granted to Eskom to access their

servitudes.

Y Dedicated ESKOM lock and key system

on all access gates which allow ESKOM

free access were observed during site

visit.

4.) Equipment shall be regarded

electrically live and therefore

dangerous at all times. Safety and

best practice standards with regards

to all safety hazards related to

electrical plant shall be employed for

the projects.

NA

Noted

APPENDIX 2: DECLARATION OF INDEPENDENCE

APPENDIX 1: DECLARATION

THE INDEPENDENT ENVIRONMENTAL CONTROL OFFICER (ECO)

I, B Wiesner, as the appointed independent environmental practitioner (“ECO”) hereby declare that I:

• act/ed as the independent ECO in this audit report;

• regard the information contained in this report to be true and correct;

• do not have and will not have any financial interest in the undertaking of the activity, other than remuneration for work performed in terms of the NEMA, the Environmental Impact Assessment Regulations, 2017 and any specific environmental management Act; and

• have and will not have no vested interest in the activity;

Signature of the environmental assessment practitioner:

Amathemba Environmental management Consulting CC

Name of company:

Date: 7 December 2019