APPENDIX F PUBLIC PARTICIPATION - SLR Consulting · concerns regarding the proposed project, please contact ena de villiers of slr at the below contact details. slr contact details
20170605Selected Clients Organisation and Name List (2 column)
Mr A WichtAA Gawne
Mr L VenterAECOM
Mr G VenterAfrisam
Mr Q DollmanAfrisam South Africa (Pty) Ltd
Mr F BurgerAnglo American Kumba Iron Ore
Ms S DeanAvedia Energy (Pty) Ltd
Mr R SeymourBay Steel
The ManagerBidfreight Port Operations (Pty) Ltd
Mr A WichtBlouwaterbaai Property Owners Association
Mr J WichtBlouwaterbaai Property Owners Association
Mrs M WichtBlue Bay Lodge
Mr P MalherbeBlue Water Bay
Mr JF PhillipsBrent Oil Service Station
Ms V PriestleyCape West Coast Biosphere Reserve
Ms A Duffell-CanhamCapeNature
Mr W CarstensCartol Beleggings Edms Bpk
Mr B WichtConlands Properties (Pty) Ltd
Ms E de BruynDuferco Steel Processing
Mr J HattinghDuferco Steel Processing
Mr C LouwDuferco Steel Processing
Mr B BlackbeardFerroMarine Africa (Pty) Ltd
Mr J Van VuurenGenwest Steel amp Industrial Services
Mr RD SaborGVJ Electrical and Instrumentation (Pty) Ltd
Mr A SeptemberHeritage Western Cape
Mr J KotzeLangebaan Residents and Ratepayers Association
Mr J SelbyLangebaan Residents and Ratepayers Association
Mr K CoetseeLangemeer Property Developer
Mr S BurgerMOGS
Mr P CoetzeeMOGS
Mr A MartinMOGS
Mr HA LindsayPienaarspoort Property Owners Association
Mr A VermaakRoyal HaskoningDHV
Mr A CarnegieSaldanha Bay Action Group
Ms M De BeerSaldanha Bay BBBEE
Ms K BeukesSaldanha Bay IDZ Licensing Company (SOC) Ltd
Mr H MaraisSaldanha Bay IDZ Licensing Company (SOC) Ltd
Mr D SouthgateSaldanha Bay IDZ Licensing Company (SOC) Ltd
Ms L van AchterberghSaldanha Bay Industrial Development Zone
Ms N DuarteSaldanha Bay Municipality
Mr L GaffleySaldanha Bay Municipality
Mr FJ SchippersSaldanha Bay Municipality
Mr G SmithSaldanha Bay Municipality
Mr C van WykSaldanha Bay Water Quality Forum Trust
Mr J WalshSaldanha Bay Water Quality Forum Trust
Mnr I LeeSaldanha Sakekamer
Mr J De WaalSaldanha Steel
Mr B SylvesterSaldanha Steel
The ChairmanSaldanha Tourism Bureau
Mr D MacleodSaldok (Pty) Ltd
Ms K McGregorSMEC South Africa(Pty) Ltd
Ms J BarkerSunrise Energy (Pty) Ltd
Mr B HarmseSunrise Energy (Pty) Ltd
Ms B MathibeTirisano Training Organisation
Mr R JuliesTransnet Freight Rail
Ms E CoetzeeTransnet National Ports Authority
Mr Q KordomTransnet National Ports Authority
Mr W RouxTransnet National Ports Authority
Mr D SamuelsTransnet National Ports Authority
Ms J SmitTransnet National Ports Authority
Mr R BillettTransnet Properties
Mr R Van der MerweVDM Transport
Mr C van der WaltWCG Department of Agriculture
Mr H JonkerWCG Department of Economic Development amp Tourism
Ms G SwanepoelWCG Department of Tranport and Public Works
Mr M WattersWCG Department of Transport amp Public Works
Mr R BoyesWCG Department of Transport and Public Works
Ms D MarthezeWCG Department of Transport and Public Works
Mr W M SilbernaglWCG Department of Transport and Public Works
Ms D KotzeWest Coast District Municipality
Ms P HaarhoffWest Coast Fossil Park
The ManagerYzervarkensrug Projects amp Development
APPENDIX F2
SITE NOTICE AND ADVERTISEMENT
PUBLIC PARTICIPATION PROCESS
PROPOSED NEW ACCESS ROAD TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE OF A PUBLIC PARTICIPATION PROCESS IN TERMS OF THE NEMA EIA REGULATIONS 2014
APPLICANT SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (SBIDZ) LICENCING COMPANY (ldquoLICOrdquo)
CONSULTING ENGINEER SMEC SOUTH AFRICA (PTY) LTD (ldquoSMECrdquo)
ENVIRONMENTAL ASSESSMENT PRACTITIONER SLR CONSULTING (SOUTH AFRICA) (PTY) LTD (ldquoSLRrdquo)
DESCRIPTION AND LOCATION LICO IS PROPOSING THE FOLLOWING ADDITIONS TO THE ROAD NETWORK FOR THE SBIDZ AREA bull CONSTRUCTION OF A NEW EAST-WEST ACCESS ROAD AND NEW INTERSECTION ON MINOR ROAD (OP) 7645 IN ORDER TO PROVIDE ACCESS TO THE
SBIDZ AREA TO THE NORTH OF MR559 THIS ROAD WOULD ALSO PROVIDE ACCESS TO THE NEW AFRISAM CEMENT PLANT AND bull EXTENSION OF THE SOUTH-NORTH ACCESS ROAD ALONG THE SBIDZ EASTERN BOUNDARY TO PROVIDE AN ALTERNATIVE ACCESS TO DUFERCO
APPLICATION FOR ENVIRONMENTAL AUTHORISATION TO UNDERTAKE THE FOLLOWING LISTED ACTIVITIES IN TERMS OF GOVERNMENT NOTICE R983 (LISTING NOTICE 1) 24(ii) AND IN TERMS OF GOVERNMENT NOTICE R985 (LISTING NOTICE 3) 12(a)
OPPORTUNITY TO PARTICIPATE NOTICE IS HEREBY GIVEN THAT A BASIC ASSESSMENT PROCESS IS BEING UNDERTAKEN FOR THIS PROPOSED PROJECT IF YOU ANDOR YOUR ORGANISATION WISH TO REGISTER ON THE PROJECT DATABASE REQUIRE ADDITIONAL INFORMATION ANDOR WISH TO RAISE ANY ISSUES OR CONCERNS REGARDING THE PROPOSED PROJECT PLEASE CONTACT ENA DE VILLIERS OF SLR AT THE BELOW CONTACT DETAILS
SLR CONTACT DETAILS UNIT 39 ROELAND SQUARE 30 DRURY LANE CAPE TOWN 8000 TEL (021) 461 11189 FAX (021) 461 1120 EMAIL edevilliersslrconsultingcom
SITE NOTICE PHOTOGRAPHS
Site notice placed at the eastern end of the proposed new eastern access road along the road reserve boundary of Minor Road 7645 (Port Road)
Site notice placed at the southern end of the proposed new north-south road western end of the proposed new eastern access road at the eastern entrance to the Saldanha Bay Industrial Development Zone
NOTICE OF PUBLIC PARTICIPATION PROCESS
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Notice is hereby given of a public participation process in terms of the National Environmental Management Act (No 107 of 1998) (NEMA) and Environmental Impact Assessment (EIA) Regulations 2014
Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) Environmental Assessment Practitioner SLR Consulting (South Africa) (Pty) Ltd (SLR)
Project description The SBIDZ-LC is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) namely bull A new eastern access road and new intersection on Minor Road 7645 (Port Road) to
provide access to the SBIDZ area north of Main Road 559 (Camp Road) as well as to a proposed new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
Application for Environmental Authorisation (EA) to undertake the following activities The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
SLR Consulting Contact Details Unit 39 Roeland Square 30 Drury Lane CAPE TOWN 8001 Tel (021) 461 1118 Fax (021) 461 1120 E-mail edevilliersslrconsultingcom Website wwwslrconsultingcomza Date of advertisement 9 March 2017
SMEC03ARStakeholder docsAdvert_Notice Advert ndash new access roads (March 2017)
22 Weslander GEKLASSIFISEERD CLASSIFIEDS 9 Maart 2017
DIRECTORATE ENGINEERING amp PLANNING SERVICES
DIRECTORATE FINANCE
DEPARTMENT SOLID WASTE
DEPARTMENT SUPPLY CHAIN MANAGEMENT
DEPARTMENT REVENUE
Superintendent Solid Waste Management Landfills
Senior Bid Administrator
Meter Reader
Applicants must be in possession of a National Diploma in Civil Engineering with Solid WasteManagement 4 as an additional subject bull 2 yearsrsquo relevant experience within Civil Engineering of which 1year should be on a supervisory level bull Computer Literacy bull Code B driverrsquos License bull Good communicationskills in two of the three official languages of the Western Cape
Duties will entail Perform administrative functions bull Communicate information to community memberswith regards to landfill sites and transfer stations bull Manage landfill sites and transfer stations bull Monitor toxicwaste as per the relevant regulations bull Manage the staff discipline and safety within the section bull Collectionof borehole water samples twice a year bull Follow-up on reported incidents bull Manage assets (equipment andmachinery) within the section bull Tender and contract administration
Applicants must be in possession of a Grade 12 bull 4 yearsrsquo relevant Supply Chain Managementexperience bull Computer literacy bull Code B driverrsquos license will serve as a recommendation bull Goodcommunication skills in two of the three official languages of the Western Cape
Duties will entail Administer Bid specifications process bull Administer the opening and registration oftenders bull Ensure that contracts do not lapse in terms of the validity period bull Administer the performance ofvendorsbidders above R200 000 bull Provide Human Resource support bull Report any irregularities to theSupply Chain Manager bull Internal and external communication
Salary Scale T11 (R220 16214 ndash R285 76824 p a)Enquiries Ms H Meeding Tel (022) 701 6916
Applicants must be in possession of a Grade 12 bull Code B driverrsquos license bull Good numerical skillsbull Physically fit and healthy bull Good communication skills in two of the three official languages of the WesternCape
Duties will entail The accurate reading and recording of meter readings to ensure that readings are beingprocessed and that all customers are charged with correct amounts bull Noting and reporting of complaints onfaulty water and electricity meters bull Update of route cards to ensure that new developments and areas arerecorded on the financial- and meter reading system
Salary scale T6 (R108 07992 ndash R140 29232 pa)Enquiries Mr H Smith Tel (022) 701 7011
Closing Date 23 March 2017 at 1200
NOTES TO APPLICANT
bull Thank you for your interest in seeking employment with usbull All applications should be accompanied by a completed application form (obtainable from our
Human Resource office or website wwwsbmgovza) clearly reflecting the name of the positionapplying for a comprehensive CV a certified copy of your ID driverrsquos license and educationalqualifications
bull No original documents attached to the application will be safe keptreturnedbull Applications without afore - mentioned will not be consideredbull Applications should be forwarded to Human Resource Services Private Bag X12 Vredenburg
7380 or via email to munsbmgovzabull ApplicationsSupporting documents larger that 2MB sent via email are not accommodatedbull For the implementation of the Employment Act candidates are encouraged to indicate their race
gender and disabilitybull No late applications will be consideredbull Further communication will be limited to shortlisted candidates If you have not received a
response within 3 (three) months of the closing date please consider your applicationunsuccessful
bull All appointments are subject to a medical assessment criminal record and reference checks fromprevious and current employer(s)
bull The Council beholds the right to make an appointment
Serve Grow and SucceedTogether
Saldanha Bay Municipality is a high profile municipality that takes care of its people to deliver thehighest quality of service to its residents and visitors We are also committed to the goals of ourEmployment Equity Plan If you are competent and committed and would like to work in aprofessional environment you are welcome to apply for the following positions on our staffestablishment
T (022) 701 7000 F (022) 715 1518 munsbmgovza wwwsbmgovzabull bull bull
00000000-DW090317
NOTICE OF PUBLIC PARTICIPATION PROCESS
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THESALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SMEC03AR 022017 DEAampDP REF NO 16331F417301117
Notice is hereby given of a public participation process in terms of the National Environmental ManagementAct (No 107 of 1998) (NEMA) and Environmental ImpactAssessment (EIA) Regulations 2014
Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC)EnvironmentalAssessment Practitioner SLR Consulting (SouthAfrica) (Pty) Ltd (SLR)
Project description The SBIDZ-LC is proposing to develop two new access roads to the Saldanha BayIndustrial Development Zone (SBIDZ) namelybull Anew eastern access road and new intersection on Minor Road 7645 (Port Road) to provide access to
the SBIDZ area north of Main Road 559 (Camp Road) as well as to a proposed new Afrisam cementplant and
bull Anew north-south access road along the SBIDZ eastern boundary to provide an alternative access tothe Duferco steel processing plant
Application for EnvironmentalAuthorisation (EA) to undertake the following activitiesThe proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in termsof NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (ListingNotice 3)Activities 12 and 18ABasicAssessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor yourorganisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on theBasic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-daycomment period from 10 March to 10 April 2017 (including an additional day to cover the intervening publicholiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Anycomment should be submitted by no later than 10April 2017
SLR Consulting Contact DetailsUnit 39 Roeland Square 30 Drury LaneCAPE TOWN 8001Tel (021) 461 1118 Fax (021) 461 1120E-mail edevilliersslrconsultingcomWebsite wwwslrconsultingcomza Date of advertisement 9 March 2017
0000000-DW090317
Serve Grow and SucceedTogether
ApplicantAansoeker amp OwnerEienaar CK RUMBOLL amp PARTNERS
TEL 022-4871661 ndash Zanellerumbollcoza
Reference numberVerwysingsnommer NR 12319
Property DescriptionEiendomsbeskrywing FARMPLAAS DE KLIP NR 12319
Physical AddressFisiese adres VREDENBURG
Notice is hereby given in terms of Sections 45 amp 46 of the
Saldanha Bay Municipal Land Use Planning By-law that
Saldanha Bay Municipality is considering the following
i) a Consent Use (special usage) in terms Section 15(2)(o) in
order to establish 4 additional residential units on Portion
19 of the Farm De Klip No 123
Details are available for scrutiny at the Municipal Managerrsquos
office during weekdays between 0830 and 1630 contact
the Town Planning Department at 17 Main Street
Vredenburg Any written comments may be addressed to
the Municipal Manager at Private Bag x 12 17 Main Street
Vredenburg doreendunnsbmgovza on or before 10
April 2017 quoting your name address or contact details
interest in the application and reasons for comments
Telephonic enquiries can be made to Bradley Rubidge at 022
- 701 7080 The Municipality may refuse to accept comment
received after the closing date Any person who cannot
write will be assisted by a Municipal official by transcribing
their comments Commentsobjections will be forwarded to
the applicant for hisher response
N1817 (09-03-2017)
K e n n i s w o r d h i e r m e e g e g e e i n g e v o l g e
Artikels 45 amp 46 van die Saldanhabaai Munisipale
Grondgebruikbeplanningsverordening dat Saldanhabaai
M u n i s i p a l i t e i t d i e v o l g e n d e o o r w e e g
i) lsquon Vergunningsgebruik (spesiale gebruik) in terme Artikel
15(2)(a) ten einde 4 addisionele residensieumlle eenhede op
Gedeelte 19 van die Plaas De Klip Nr 123 te
akkommodeer
Nadere besonderhede lecirc ter insae by die Munisipale
Bestuurder se kantoor gedurende weeksdae tussen 0830
and 1630 kontak die Departement Stadsbeplanning by
Hoofstraat 17 Vredenburg Enige skriftelike kommentaar
kan gerig word aan die Munisipale Bestuurder Privaatsak x
12 Hoofstraat 17 Vredenburg doreendunnsbmgovza
op of voor 10 April 2017 met vermelding van u naam adres
of kontakbesonderhede belangstelling in die aansoek en
redes vir kommentaar Telefoniese navrae kan gerig word
aan Bradley Rubidge by 022 - 701 7080 Die Munisipaliteit
mag weier om kommentaar te aanvaar wat na die
sluitingsdatum ontvang word Enige persoon wat nie kan
skryf sal bygestaan word deur n munisipale amptenaar vir
transkribering van hul kommentaar Besware sal aan die
applicant gestuur word vir syhaar repliek
K1817 (09-03-2017)
T (022) 701 7000 F (022) 715 1518 munsbmgovza wwwsbmgovzabull bull bull
0000000-DW090317
Madeleyn Ingelyf prokureurs vanVredenburg benodig die dienste van n
litigasie invorderings tikster
Die geskikte kandidaat moetrekenaarvaardig en tweetalig wees en
sal toepaslike ondervinding n sterkaanbeveling wees
Stuur asseblief u CV per e pos aanniekiemadeleyncoza
of lewer per hand af aanMadeleyn Ingelyf
Hoofstraat 6 Vredenburg
LITIGASIE
TIKSTER
000000-DW090317
BESTUURDER VIR
HOSPITALITEITSBEDRYF
Vorige ondervinding n vereisteGoeie menseverhoudings
Uitstekende kommunikasie vermoeumlnsMoet onder druk kan werk asook lang ure
Verkieslik manlik
Kontak 073 070 8414
Sluitingsdatum 16 Maart 2017
000000-DW090317
BRAAIKUIKEN
PLAASBESTUURDER(WORCESTER AREA)
bull Algemene bestuur van braaikuiken plaasbull Beheer en kontrole oor personeelbull Opdragte van bestuur aan personeel oordra en
toesien dat werk effektief uitgevoer wordbull Betroubaar eerlik en hardwerkendbull Moet onder druk kan funksioneerbull Moet bereid wees om oortyd en naweke te werkbull Bestuurderslisensie n vereistebull Geen ondervinding nodig
Gratis behuising op plaas ingesluitSluitingsdatum 20 Maart 2017
E-pos soverbycompnetcozaof faks na 086 4306 721
Indien geen reaksie teen 25 Maart 2017
was u aansoek onsuksesvol
0000000-DW090317
TIPPLER 3 PROJECT
All Local Building Contractors areencouraged to register their
companies on the Group Five Thulanda JV Vendor databaseThe database will be used to
Registration places your company in a better position tobe considered for various sub-contracts that need to beawarded for the Tippler 3 and other Group Five Thulanda Projects in the region
To register on our Supplier Development (SD)Database all local companies are required to completea Vendors Take on Form and to submit the dulycompleted form together with necessary documentrequirements to our SD Officer Nosi Hlulelo byemailing her at nosihlulelothulandacoza
MAKING A DIFFERENCE
000000-DW090317
APPENDIX F3
PROOF OF BAR NOTIFICATION
From Mandy KulaTo Mandy KulaBcc brianwichtcoza yolandaswartmwebcoza adminbluebaylodgecoza admin3bluebaylodgecoza aduffell-canhamcapenaturecoza
Subject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENT
Date 09 March 2017 012626 PMAttachments Exec Summary - Basic Assessment Report (9Mar17)pdf
Let ndash BAR Notification (9Mar17)pdfimage4981fbPNG
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposedproject for a 30-day review and comment period from 10 March to 10 April 2017 (including one additional day to coverthe intervening public holiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
SLR Consulting (South Africa) (Pty) Ltd Page iv
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
Proposed north-south access road
Proposed eastern access road
Trunk Road 85
Main Road 559 Minor Road 7645
Saldanha Bay Industrial Development Zone
Duferco
Future Afrisam cement plant
Proposed north-south access road
Proposed eastern access road
From Ena de VilliersTo Ena de VilliersBcc gerritsmithsbmgovza malcolmwatterswesterncapegovza corvdwelsenburgcom aduffell-canhamcapenaturecoza
melaneseschipperswesterncapegovzaSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
REMINDER OF CLOSURE OF BAR COMMENT PERIODDate 04 April 2017 110142 AMAttachments image6c48afPNG
Dear SirsMadams We would like to take this opportunity to remind you of the closure of the comment period for the above-mentioned projecton 10 April 2017 Kindly submit your comments to Mandy Kula (mkulaslrconsultingcom) or myself at the contact particularsbelow You are welcome to contact us regarding any enquiries Thanks and best regardsEna
Ena de VilliersEnvironmental ConsultantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
APPENDIX F4
DRAFT BAR COMMENTS AND RESPONSES REPORT
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
1
DRAFT BASIC ASSESSMENT REPORT (BAR)
COMMENTS AND RESPONSES REPORT
Written submissions were received from the following commenting authorities and other Interested and Affected Parties (IampAPs) during the BAR comment period
SUBMITTED BY METHOD AND DATE Authorities 1 West Coast District Municipality ndash Ms Doretha Kotze Email - 29 March 2017
2 Department of Environmental Affairs and Development Planning ndash Ms M Schippers Fax - 07 April 2017
3 Saldanha Bay Municipality ndash Mr E Mmbadi Email - 10 April 2017
4 CapeNature ndash Ms Alana Duffell-Canham Email - 11 April 2017
Other IampAPs 1 Phillips Group ndash Mr Jan Phillips Email - 10 March 2017
Copies of the written comments are attached as Attachment A to this report arranged according to the order indicated in the table above The comments received are presented in Table 1 below and have been categorised as follows A Authority comments and issues 1 Comments received from West Coast District Municipality
11 Implications of Draft EMF for Saldanha region 12 Servitudes on the property
2 Comments received from Department of Environmental Affairs and Development Planning 21 Applicable listed Activities 22 Originally signed and dated declarations 23 Proof of Public Participation
3 Comments received from Saldanha Bay Municipality 31 Critical Biodiversity Areas 32 Cumulative impact of construction on ambient air quality 33 Road maintenance after completion 34 Water use during construction phase 35 Palaeontological and archaeological findings
4 Comments received from CapeNature 41 Status of vegetation types 42 Critical Biodiversity Areas 43 Implications for proposed eastern access route alignment 44 Proposed north-south access road 45 Rights reserved
B Other IampAP comments and issues 1 Comments received from Phillips Group
11 Effect of proposed project on traffic flow and businesses in the area 2 Comments received from Afrisam
21 Late submission of comments 22 South-north access road currently under construction 23 Zoning of Farm 1139 24 Suggestions for amending proposed mitigation measures 25 Details regarding activity information
No importance should be given to the order in which the categories are presented
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
2
Table 1 Summary table of comments received on the draft BAR with responses from SLR and the project technical team as appropriate
NO ISSUE NAME DATE COMMENT RESPONSE
A AUTHORITY COMMENTS AND ISSUES
1 COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY 11 Implications of
Draft EMF for Saldanha region
Doretha Kotze 20170329 1 Your letter dated 9 March 2017 and the information contained in the Draft BAR for the proposal refer
2 The Environmental Management Framework (EMF) for the Saldanha region is currently being revisited as part of the drafting of the Greater Saldanha Regional Spatial Implementation Framework by the Western Cape Provincial Department of Environmental Affairs and Development Planning It is recommended that this proposal be aligned with the outcomes of the different studies being undertaken as part of the finalisation of the EMF since Farm 1139 is situated in an area that has been identified as a Conflict Area in terms of the Urban Conservation Zone and Industrial Development Zone For more information of the EMF process kindly contact Ryan Nel at GIBB Consulting (rnelgibbcoza or Tel 011 519 4600)
We have taken the Draft EMF into consideration in the revised BAR (refer to Section D2(c)) However the document has not yet been formally adopted Thus the implied action by the Saldanha Municipality namely to resolve the conflict in the process of updating their Spatial Development Framework has not yet been undertaken Thus the formal land use status of the property remains intended for industrial development
12 Servitudes on the property
Doretha Kotze 20170329 3 Several servitudes had been registered over Farm 1139 over the years accommodating power lines water pipelines and rights of way Two bulk water pipelines of the West Coast District Municipality traversing the property in the northwest will be crossed by the proposed new access roads Care should be taken during the construction phase to prevent negative impacts on these pipelines
The project design engineers are aware of the existence of servitudes As necessary application would be made for wayleaves from the district and local municipalities if any works occur near water or other bulk services infrastructure
2 COMMENTS FROM DEPARTMENT OF ENVIRONMENTAL AFFAIRS AND DEVELOPMENT PLANNING 21 Applicable listed
activities M Schippers 20170407 The draft BAR dated March 2017 and received by this Department
on 09 March 2017 refer 1 Applicable listed activities 11 It is noted that Activity 12 of GN No R985 is being applied for 12 Please note that the abovementioned activity is not applicable
to the proposed development since the vegetation occurring on the proposed site has not been classified as a critically endangered or endangered ecosystem in terms of the National Environmental Management Biodiversity Act of 2004 (ldquoNEMBArdquo) List of Threatened Ecosystems in Need of Protection December 2011)
13 This activity must be excluded from the application
We have noted the comments in Item 1 and have amended the revised BAR accordingly ndash see Sections A1(c) and B5(c) and (d)
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3
NO ISSUE NAME DATE COMMENT RESPONSE 22 Originally signed
and dated declarations
M Schippers 07 April17 2 The duly dated and originally signed declarations as completed by the applicant the Environmental Assessment Practitioner and the specialists who compiled the specialist reports as part of the Environmental Impact Assessment Process must be included in the BAR to be submitted to the competent authority
The originally signed declarations will be included in the final BAR which will be submitted to your Department after the conclusion of the revised BAR comment period
23 Proof of public participation
M Schippers 07 April17 3 Proof of Public Participation 31 Proof of the public participation conducted must be included in
the BAR to be submitted to the competent authority please note that the proof must include inter alia the following
311 A copy of the newspaper advertisement (ldquonewspaper clippingrdquo) that was placed indicating the name of the newspaper and date of publication
312 Photographs showing the notice displayed on site and a copy of the text displayed on the notice and
313 With regards to the written notices provided please note the following
bull If registered mail was sent a list of the registered mail sent as obtained from the post office must be provided
bull If regular mail was sent a list of the mail sent as obtained from the post office must be provided
bull If a facsimile was sent a copy of the facsimile report must be provided
bull If an electronic mail was sent a copy of the electronic mail sent and delivery reports must be provided and
bull If a ldquomail droprdquo was done a signed register of ldquomail dropsrdquo must be provided
Proof of public participation has been included in the revised BAR as follows bull Newspaper advertisement ndash Appendix F2 bull Site notice ndash Appendix F2 and bull Written notifications ndash Appendix F3 Please note that as e-mail addresses were available for all IampAPs registered on the database the formal notification letter was sent by means of electronic mail However delivery reports were not requested as this requirement is not stated in the relevant legislation nor in any guideline document on public participation of which we are aware Thus we have included a copy of the e-mail notification sent as adequate proof of distribution Hard copies of letters were delivered to representatives of commenting authorities proof of which is also included in Appendix F3
3 COMMENTS FROM SALDANHA BAY MUNICIPALITY 31 Critical
Biodiversity Areas
Mr E Mmbadi 20170410 1 Basic Assessment Report for the Proposed New Access Roads to the Saldanha Bay Industrial Development Zone dated 07 March 2017 refers
2 Even though the site is located outside the Critical Biodiversity Area it may function as a ldquostepping stonerdquo corridor that allows for animal and plant movement across the landscape Development within such sites should consider ecological connectivity of the landscape and care should be taken not to disrupt this connectivity especially for a site surrounded by Critical Biodiversity Areas
The draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest Western Cape Biodiversity Spatial Plan became available in April 2017 and was taken into consideration in the revised BAR which will be made available for a further review and comment period
32 Cumulative Mr E Mmbadi 20170410 3 The report should highlight the potential cumulative impacts of These comments have been noted As the
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
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4
NO ISSUE NAME DATE COMMENT RESPONSE impact of construction on ambient air quality
several construction activities on ambient air quality Viewing the impacts of access roads construction in isolation may only reveal limited potential impacts on the ambient air quality The report should also look at the possible release of iron ore dust trapped on vegetation into the atmosphere
construction phase of the proposed project has not yet been scheduled it cannot be assumed that it will occur while other road construction projects in the area are in progress Reference to the implications of the possible release of iron ore dust trapped on vegetation for dust generation and control during the construction phase has been incorporated into the revised BAR (see Sections F2(b) and F615) and the Construction EMP (see Section 312(b))
33 Road maintenance after completion
Mr E Mmbadi 20170410 4 In most cases after the construction work is completed the roads are handed over to local authority to maintain and service If it is envisaged to hand over the proposed access roads to Saldanha Bay Municipality (ldquoSBMrdquo) the report should acknowledge such intention Also ensure that all the requirements from SBM with regard to roads are met Please contact Manager Roads amp Stormwater (jeremyjarvissbmgovza 022 701 7049) in this regard
The design engineers have engaged with SBM regarding the future management of the roads as is indicated by the following statement in the BAR ldquoSaldanha Bay Municipality has requested that the road reserve should be registered as a separate erf which would be a portion of this propertyrdquo (see Section A2)
34 Water use during construction phase
Mr E Mmbadi 20170410 5 SBM commenced with the implementation of level 3 water restriction Please advise if there is confirmation from the municipality with regard to the supply of water to the proposed development SBM discourages the use of potable water as a dust suppression measure or for any construction purpose please indicate the developmentrsquos potential water source The use of treated effluent from the waste water treatment works could be an option Please contact Manager of Bulk Water and Sanitation (gavinwilliamasbmgovza 022 701 7047) in this regard Also consult with the Department of Water and Sanitation with regard to the water use application process
These comments regarding water conservation have been noted and relevant measures to prevent the use of potable water for dust suppression have been included in the revised BAR (see Sections F2(b) F3 and E615 of the revised BAR and Section 312(a) of the Construction EMP) Please note that the road development would only require a limited supply of water during the construction phase which the Contractor would be required to source from available resources Consultation with DWS regarding a water use application may thus not be relevant
35 Palaeontological and archaeological findings
Mr E Mmbadi 20170410 6 Please inform the Environment amp Heritage Section of the SBM on any Palaeontological and Archaeological findings for our records
This request has been included in the revised BAR (see Section F617) as well as the Construction EMP (see Section 3102(e))
4 COMMENTS FROM CAPENATURE 41 Status of
vegetation types Alana Duffell-Canham
20170410 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road 1 The proposed eastern access road passes through an area
These comments regarding the status of the vegetation types on the project site have been noted On the basis of the botanical assessment undertaken as part of the Basic Assessment process the condition of the Saldahna Limestone
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
5
NO ISSUE NAME DATE COMMENT RESPONSE covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet [been] listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6 000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
Strandveld vegetation located on the limestone ridge has indeed been described as of high botanical sensitivity in the draft BAR As to the status of the vegetation please take cognisance of DEAampDPrsquos position that only the formal classification of vegetation in terms of NEMBA is considered applicable in relation to the NEMA EIA Regulations This was in response to our indication in the draft BAR that Saldahna Flats Strandveld which is classified ldquoVulnerablerdquo should be considered ldquoEndangeredrdquo on the basis of a 2014 CapeNature status report Please refer to Comment and Response 21 above We thus have to assume that DEAampDP would consider the formal classification of Saldahna Limestone Strandveld as ldquoLeast Threatenedrdquo in terms of NEMBA as applicable
42 Critical Biodiversity Areas
Alana Duffell-Canham
20170410 2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent land cover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truth where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data
A mentioned in Response 31 above the draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest WCBSP which became available in April 2017 has been taken into consideration in the revised BAR Our observation regarding the mapping of the CBAs is that this covers a large area on the specific property and extends notably further northwards than the intact vegetation on the limestone ridge According to the ground-truthing of the botanical
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
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8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
APPENDIX F1
PROJECT DATABASE
CCA Environmental (Pty) LtdPage 1 of 1
SMEC03AR - IampAP DATABASE
20170605Selected Clients Organisation and Name List (2 column)
Mr A WichtAA Gawne
Mr L VenterAECOM
Mr G VenterAfrisam
Mr Q DollmanAfrisam South Africa (Pty) Ltd
Mr F BurgerAnglo American Kumba Iron Ore
Ms S DeanAvedia Energy (Pty) Ltd
Mr R SeymourBay Steel
The ManagerBidfreight Port Operations (Pty) Ltd
Mr A WichtBlouwaterbaai Property Owners Association
Mr J WichtBlouwaterbaai Property Owners Association
Mrs M WichtBlue Bay Lodge
Mr P MalherbeBlue Water Bay
Mr JF PhillipsBrent Oil Service Station
Ms V PriestleyCape West Coast Biosphere Reserve
Ms A Duffell-CanhamCapeNature
Mr W CarstensCartol Beleggings Edms Bpk
Mr B WichtConlands Properties (Pty) Ltd
Ms E de BruynDuferco Steel Processing
Mr J HattinghDuferco Steel Processing
Mr C LouwDuferco Steel Processing
Mr B BlackbeardFerroMarine Africa (Pty) Ltd
Mr J Van VuurenGenwest Steel amp Industrial Services
Mr RD SaborGVJ Electrical and Instrumentation (Pty) Ltd
Mr A SeptemberHeritage Western Cape
Mr J KotzeLangebaan Residents and Ratepayers Association
Mr J SelbyLangebaan Residents and Ratepayers Association
Mr K CoetseeLangemeer Property Developer
Mr S BurgerMOGS
Mr P CoetzeeMOGS
Mr A MartinMOGS
Mr HA LindsayPienaarspoort Property Owners Association
Mr A VermaakRoyal HaskoningDHV
Mr A CarnegieSaldanha Bay Action Group
Ms M De BeerSaldanha Bay BBBEE
Ms K BeukesSaldanha Bay IDZ Licensing Company (SOC) Ltd
Mr H MaraisSaldanha Bay IDZ Licensing Company (SOC) Ltd
Mr D SouthgateSaldanha Bay IDZ Licensing Company (SOC) Ltd
Ms L van AchterberghSaldanha Bay Industrial Development Zone
Ms N DuarteSaldanha Bay Municipality
Mr L GaffleySaldanha Bay Municipality
Mr FJ SchippersSaldanha Bay Municipality
Mr G SmithSaldanha Bay Municipality
Mr C van WykSaldanha Bay Water Quality Forum Trust
Mr J WalshSaldanha Bay Water Quality Forum Trust
Mnr I LeeSaldanha Sakekamer
Mr J De WaalSaldanha Steel
Mr B SylvesterSaldanha Steel
The ChairmanSaldanha Tourism Bureau
Mr D MacleodSaldok (Pty) Ltd
Ms K McGregorSMEC South Africa(Pty) Ltd
Ms J BarkerSunrise Energy (Pty) Ltd
Mr B HarmseSunrise Energy (Pty) Ltd
Ms B MathibeTirisano Training Organisation
Mr R JuliesTransnet Freight Rail
Ms E CoetzeeTransnet National Ports Authority
Mr Q KordomTransnet National Ports Authority
Mr W RouxTransnet National Ports Authority
Mr D SamuelsTransnet National Ports Authority
Ms J SmitTransnet National Ports Authority
Mr R BillettTransnet Properties
Mr R Van der MerweVDM Transport
Mr C van der WaltWCG Department of Agriculture
Mr H JonkerWCG Department of Economic Development amp Tourism
Ms G SwanepoelWCG Department of Tranport and Public Works
Mr M WattersWCG Department of Transport amp Public Works
Mr R BoyesWCG Department of Transport and Public Works
Ms D MarthezeWCG Department of Transport and Public Works
Mr W M SilbernaglWCG Department of Transport and Public Works
Ms D KotzeWest Coast District Municipality
Ms P HaarhoffWest Coast Fossil Park
The ManagerYzervarkensrug Projects amp Development
APPENDIX F2
SITE NOTICE AND ADVERTISEMENT
PUBLIC PARTICIPATION PROCESS
PROPOSED NEW ACCESS ROAD TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE OF A PUBLIC PARTICIPATION PROCESS IN TERMS OF THE NEMA EIA REGULATIONS 2014
APPLICANT SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (SBIDZ) LICENCING COMPANY (ldquoLICOrdquo)
CONSULTING ENGINEER SMEC SOUTH AFRICA (PTY) LTD (ldquoSMECrdquo)
ENVIRONMENTAL ASSESSMENT PRACTITIONER SLR CONSULTING (SOUTH AFRICA) (PTY) LTD (ldquoSLRrdquo)
DESCRIPTION AND LOCATION LICO IS PROPOSING THE FOLLOWING ADDITIONS TO THE ROAD NETWORK FOR THE SBIDZ AREA bull CONSTRUCTION OF A NEW EAST-WEST ACCESS ROAD AND NEW INTERSECTION ON MINOR ROAD (OP) 7645 IN ORDER TO PROVIDE ACCESS TO THE
SBIDZ AREA TO THE NORTH OF MR559 THIS ROAD WOULD ALSO PROVIDE ACCESS TO THE NEW AFRISAM CEMENT PLANT AND bull EXTENSION OF THE SOUTH-NORTH ACCESS ROAD ALONG THE SBIDZ EASTERN BOUNDARY TO PROVIDE AN ALTERNATIVE ACCESS TO DUFERCO
APPLICATION FOR ENVIRONMENTAL AUTHORISATION TO UNDERTAKE THE FOLLOWING LISTED ACTIVITIES IN TERMS OF GOVERNMENT NOTICE R983 (LISTING NOTICE 1) 24(ii) AND IN TERMS OF GOVERNMENT NOTICE R985 (LISTING NOTICE 3) 12(a)
OPPORTUNITY TO PARTICIPATE NOTICE IS HEREBY GIVEN THAT A BASIC ASSESSMENT PROCESS IS BEING UNDERTAKEN FOR THIS PROPOSED PROJECT IF YOU ANDOR YOUR ORGANISATION WISH TO REGISTER ON THE PROJECT DATABASE REQUIRE ADDITIONAL INFORMATION ANDOR WISH TO RAISE ANY ISSUES OR CONCERNS REGARDING THE PROPOSED PROJECT PLEASE CONTACT ENA DE VILLIERS OF SLR AT THE BELOW CONTACT DETAILS
SLR CONTACT DETAILS UNIT 39 ROELAND SQUARE 30 DRURY LANE CAPE TOWN 8000 TEL (021) 461 11189 FAX (021) 461 1120 EMAIL edevilliersslrconsultingcom
SITE NOTICE PHOTOGRAPHS
Site notice placed at the eastern end of the proposed new eastern access road along the road reserve boundary of Minor Road 7645 (Port Road)
Site notice placed at the southern end of the proposed new north-south road western end of the proposed new eastern access road at the eastern entrance to the Saldanha Bay Industrial Development Zone
NOTICE OF PUBLIC PARTICIPATION PROCESS
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Notice is hereby given of a public participation process in terms of the National Environmental Management Act (No 107 of 1998) (NEMA) and Environmental Impact Assessment (EIA) Regulations 2014
Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) Environmental Assessment Practitioner SLR Consulting (South Africa) (Pty) Ltd (SLR)
Project description The SBIDZ-LC is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) namely bull A new eastern access road and new intersection on Minor Road 7645 (Port Road) to
provide access to the SBIDZ area north of Main Road 559 (Camp Road) as well as to a proposed new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
Application for Environmental Authorisation (EA) to undertake the following activities The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
SLR Consulting Contact Details Unit 39 Roeland Square 30 Drury Lane CAPE TOWN 8001 Tel (021) 461 1118 Fax (021) 461 1120 E-mail edevilliersslrconsultingcom Website wwwslrconsultingcomza Date of advertisement 9 March 2017
SMEC03ARStakeholder docsAdvert_Notice Advert ndash new access roads (March 2017)
22 Weslander GEKLASSIFISEERD CLASSIFIEDS 9 Maart 2017
DIRECTORATE ENGINEERING amp PLANNING SERVICES
DIRECTORATE FINANCE
DEPARTMENT SOLID WASTE
DEPARTMENT SUPPLY CHAIN MANAGEMENT
DEPARTMENT REVENUE
Superintendent Solid Waste Management Landfills
Senior Bid Administrator
Meter Reader
Applicants must be in possession of a National Diploma in Civil Engineering with Solid WasteManagement 4 as an additional subject bull 2 yearsrsquo relevant experience within Civil Engineering of which 1year should be on a supervisory level bull Computer Literacy bull Code B driverrsquos License bull Good communicationskills in two of the three official languages of the Western Cape
Duties will entail Perform administrative functions bull Communicate information to community memberswith regards to landfill sites and transfer stations bull Manage landfill sites and transfer stations bull Monitor toxicwaste as per the relevant regulations bull Manage the staff discipline and safety within the section bull Collectionof borehole water samples twice a year bull Follow-up on reported incidents bull Manage assets (equipment andmachinery) within the section bull Tender and contract administration
Applicants must be in possession of a Grade 12 bull 4 yearsrsquo relevant Supply Chain Managementexperience bull Computer literacy bull Code B driverrsquos license will serve as a recommendation bull Goodcommunication skills in two of the three official languages of the Western Cape
Duties will entail Administer Bid specifications process bull Administer the opening and registration oftenders bull Ensure that contracts do not lapse in terms of the validity period bull Administer the performance ofvendorsbidders above R200 000 bull Provide Human Resource support bull Report any irregularities to theSupply Chain Manager bull Internal and external communication
Salary Scale T11 (R220 16214 ndash R285 76824 p a)Enquiries Ms H Meeding Tel (022) 701 6916
Applicants must be in possession of a Grade 12 bull Code B driverrsquos license bull Good numerical skillsbull Physically fit and healthy bull Good communication skills in two of the three official languages of the WesternCape
Duties will entail The accurate reading and recording of meter readings to ensure that readings are beingprocessed and that all customers are charged with correct amounts bull Noting and reporting of complaints onfaulty water and electricity meters bull Update of route cards to ensure that new developments and areas arerecorded on the financial- and meter reading system
Salary scale T6 (R108 07992 ndash R140 29232 pa)Enquiries Mr H Smith Tel (022) 701 7011
Closing Date 23 March 2017 at 1200
NOTES TO APPLICANT
bull Thank you for your interest in seeking employment with usbull All applications should be accompanied by a completed application form (obtainable from our
Human Resource office or website wwwsbmgovza) clearly reflecting the name of the positionapplying for a comprehensive CV a certified copy of your ID driverrsquos license and educationalqualifications
bull No original documents attached to the application will be safe keptreturnedbull Applications without afore - mentioned will not be consideredbull Applications should be forwarded to Human Resource Services Private Bag X12 Vredenburg
7380 or via email to munsbmgovzabull ApplicationsSupporting documents larger that 2MB sent via email are not accommodatedbull For the implementation of the Employment Act candidates are encouraged to indicate their race
gender and disabilitybull No late applications will be consideredbull Further communication will be limited to shortlisted candidates If you have not received a
response within 3 (three) months of the closing date please consider your applicationunsuccessful
bull All appointments are subject to a medical assessment criminal record and reference checks fromprevious and current employer(s)
bull The Council beholds the right to make an appointment
Serve Grow and SucceedTogether
Saldanha Bay Municipality is a high profile municipality that takes care of its people to deliver thehighest quality of service to its residents and visitors We are also committed to the goals of ourEmployment Equity Plan If you are competent and committed and would like to work in aprofessional environment you are welcome to apply for the following positions on our staffestablishment
T (022) 701 7000 F (022) 715 1518 munsbmgovza wwwsbmgovzabull bull bull
00000000-DW090317
NOTICE OF PUBLIC PARTICIPATION PROCESS
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THESALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SMEC03AR 022017 DEAampDP REF NO 16331F417301117
Notice is hereby given of a public participation process in terms of the National Environmental ManagementAct (No 107 of 1998) (NEMA) and Environmental ImpactAssessment (EIA) Regulations 2014
Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC)EnvironmentalAssessment Practitioner SLR Consulting (SouthAfrica) (Pty) Ltd (SLR)
Project description The SBIDZ-LC is proposing to develop two new access roads to the Saldanha BayIndustrial Development Zone (SBIDZ) namelybull Anew eastern access road and new intersection on Minor Road 7645 (Port Road) to provide access to
the SBIDZ area north of Main Road 559 (Camp Road) as well as to a proposed new Afrisam cementplant and
bull Anew north-south access road along the SBIDZ eastern boundary to provide an alternative access tothe Duferco steel processing plant
Application for EnvironmentalAuthorisation (EA) to undertake the following activitiesThe proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in termsof NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (ListingNotice 3)Activities 12 and 18ABasicAssessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor yourorganisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on theBasic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-daycomment period from 10 March to 10 April 2017 (including an additional day to cover the intervening publicholiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Anycomment should be submitted by no later than 10April 2017
SLR Consulting Contact DetailsUnit 39 Roeland Square 30 Drury LaneCAPE TOWN 8001Tel (021) 461 1118 Fax (021) 461 1120E-mail edevilliersslrconsultingcomWebsite wwwslrconsultingcomza Date of advertisement 9 March 2017
0000000-DW090317
Serve Grow and SucceedTogether
ApplicantAansoeker amp OwnerEienaar CK RUMBOLL amp PARTNERS
TEL 022-4871661 ndash Zanellerumbollcoza
Reference numberVerwysingsnommer NR 12319
Property DescriptionEiendomsbeskrywing FARMPLAAS DE KLIP NR 12319
Physical AddressFisiese adres VREDENBURG
Notice is hereby given in terms of Sections 45 amp 46 of the
Saldanha Bay Municipal Land Use Planning By-law that
Saldanha Bay Municipality is considering the following
i) a Consent Use (special usage) in terms Section 15(2)(o) in
order to establish 4 additional residential units on Portion
19 of the Farm De Klip No 123
Details are available for scrutiny at the Municipal Managerrsquos
office during weekdays between 0830 and 1630 contact
the Town Planning Department at 17 Main Street
Vredenburg Any written comments may be addressed to
the Municipal Manager at Private Bag x 12 17 Main Street
Vredenburg doreendunnsbmgovza on or before 10
April 2017 quoting your name address or contact details
interest in the application and reasons for comments
Telephonic enquiries can be made to Bradley Rubidge at 022
- 701 7080 The Municipality may refuse to accept comment
received after the closing date Any person who cannot
write will be assisted by a Municipal official by transcribing
their comments Commentsobjections will be forwarded to
the applicant for hisher response
N1817 (09-03-2017)
K e n n i s w o r d h i e r m e e g e g e e i n g e v o l g e
Artikels 45 amp 46 van die Saldanhabaai Munisipale
Grondgebruikbeplanningsverordening dat Saldanhabaai
M u n i s i p a l i t e i t d i e v o l g e n d e o o r w e e g
i) lsquon Vergunningsgebruik (spesiale gebruik) in terme Artikel
15(2)(a) ten einde 4 addisionele residensieumlle eenhede op
Gedeelte 19 van die Plaas De Klip Nr 123 te
akkommodeer
Nadere besonderhede lecirc ter insae by die Munisipale
Bestuurder se kantoor gedurende weeksdae tussen 0830
and 1630 kontak die Departement Stadsbeplanning by
Hoofstraat 17 Vredenburg Enige skriftelike kommentaar
kan gerig word aan die Munisipale Bestuurder Privaatsak x
12 Hoofstraat 17 Vredenburg doreendunnsbmgovza
op of voor 10 April 2017 met vermelding van u naam adres
of kontakbesonderhede belangstelling in die aansoek en
redes vir kommentaar Telefoniese navrae kan gerig word
aan Bradley Rubidge by 022 - 701 7080 Die Munisipaliteit
mag weier om kommentaar te aanvaar wat na die
sluitingsdatum ontvang word Enige persoon wat nie kan
skryf sal bygestaan word deur n munisipale amptenaar vir
transkribering van hul kommentaar Besware sal aan die
applicant gestuur word vir syhaar repliek
K1817 (09-03-2017)
T (022) 701 7000 F (022) 715 1518 munsbmgovza wwwsbmgovzabull bull bull
0000000-DW090317
Madeleyn Ingelyf prokureurs vanVredenburg benodig die dienste van n
litigasie invorderings tikster
Die geskikte kandidaat moetrekenaarvaardig en tweetalig wees en
sal toepaslike ondervinding n sterkaanbeveling wees
Stuur asseblief u CV per e pos aanniekiemadeleyncoza
of lewer per hand af aanMadeleyn Ingelyf
Hoofstraat 6 Vredenburg
LITIGASIE
TIKSTER
000000-DW090317
BESTUURDER VIR
HOSPITALITEITSBEDRYF
Vorige ondervinding n vereisteGoeie menseverhoudings
Uitstekende kommunikasie vermoeumlnsMoet onder druk kan werk asook lang ure
Verkieslik manlik
Kontak 073 070 8414
Sluitingsdatum 16 Maart 2017
000000-DW090317
BRAAIKUIKEN
PLAASBESTUURDER(WORCESTER AREA)
bull Algemene bestuur van braaikuiken plaasbull Beheer en kontrole oor personeelbull Opdragte van bestuur aan personeel oordra en
toesien dat werk effektief uitgevoer wordbull Betroubaar eerlik en hardwerkendbull Moet onder druk kan funksioneerbull Moet bereid wees om oortyd en naweke te werkbull Bestuurderslisensie n vereistebull Geen ondervinding nodig
Gratis behuising op plaas ingesluitSluitingsdatum 20 Maart 2017
E-pos soverbycompnetcozaof faks na 086 4306 721
Indien geen reaksie teen 25 Maart 2017
was u aansoek onsuksesvol
0000000-DW090317
TIPPLER 3 PROJECT
All Local Building Contractors areencouraged to register their
companies on the Group Five Thulanda JV Vendor databaseThe database will be used to
Registration places your company in a better position tobe considered for various sub-contracts that need to beawarded for the Tippler 3 and other Group Five Thulanda Projects in the region
To register on our Supplier Development (SD)Database all local companies are required to completea Vendors Take on Form and to submit the dulycompleted form together with necessary documentrequirements to our SD Officer Nosi Hlulelo byemailing her at nosihlulelothulandacoza
MAKING A DIFFERENCE
000000-DW090317
APPENDIX F3
PROOF OF BAR NOTIFICATION
From Mandy KulaTo Mandy KulaBcc brianwichtcoza yolandaswartmwebcoza adminbluebaylodgecoza admin3bluebaylodgecoza aduffell-canhamcapenaturecoza
Subject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENT
Date 09 March 2017 012626 PMAttachments Exec Summary - Basic Assessment Report (9Mar17)pdf
Let ndash BAR Notification (9Mar17)pdfimage4981fbPNG
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposedproject for a 30-day review and comment period from 10 March to 10 April 2017 (including one additional day to coverthe intervening public holiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
SLR Consulting (South Africa) (Pty) Ltd Page iv
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
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Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
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Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
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Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
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Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
Proposed north-south access road
Proposed eastern access road
Trunk Road 85
Main Road 559 Minor Road 7645
Saldanha Bay Industrial Development Zone
Duferco
Future Afrisam cement plant
Proposed north-south access road
Proposed eastern access road
From Ena de VilliersTo Ena de VilliersBcc gerritsmithsbmgovza malcolmwatterswesterncapegovza corvdwelsenburgcom aduffell-canhamcapenaturecoza
melaneseschipperswesterncapegovzaSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
REMINDER OF CLOSURE OF BAR COMMENT PERIODDate 04 April 2017 110142 AMAttachments image6c48afPNG
Dear SirsMadams We would like to take this opportunity to remind you of the closure of the comment period for the above-mentioned projecton 10 April 2017 Kindly submit your comments to Mandy Kula (mkulaslrconsultingcom) or myself at the contact particularsbelow You are welcome to contact us regarding any enquiries Thanks and best regardsEna
Ena de VilliersEnvironmental ConsultantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
APPENDIX F4
DRAFT BAR COMMENTS AND RESPONSES REPORT
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
1
DRAFT BASIC ASSESSMENT REPORT (BAR)
COMMENTS AND RESPONSES REPORT
Written submissions were received from the following commenting authorities and other Interested and Affected Parties (IampAPs) during the BAR comment period
SUBMITTED BY METHOD AND DATE Authorities 1 West Coast District Municipality ndash Ms Doretha Kotze Email - 29 March 2017
2 Department of Environmental Affairs and Development Planning ndash Ms M Schippers Fax - 07 April 2017
3 Saldanha Bay Municipality ndash Mr E Mmbadi Email - 10 April 2017
4 CapeNature ndash Ms Alana Duffell-Canham Email - 11 April 2017
Other IampAPs 1 Phillips Group ndash Mr Jan Phillips Email - 10 March 2017
Copies of the written comments are attached as Attachment A to this report arranged according to the order indicated in the table above The comments received are presented in Table 1 below and have been categorised as follows A Authority comments and issues 1 Comments received from West Coast District Municipality
11 Implications of Draft EMF for Saldanha region 12 Servitudes on the property
2 Comments received from Department of Environmental Affairs and Development Planning 21 Applicable listed Activities 22 Originally signed and dated declarations 23 Proof of Public Participation
3 Comments received from Saldanha Bay Municipality 31 Critical Biodiversity Areas 32 Cumulative impact of construction on ambient air quality 33 Road maintenance after completion 34 Water use during construction phase 35 Palaeontological and archaeological findings
4 Comments received from CapeNature 41 Status of vegetation types 42 Critical Biodiversity Areas 43 Implications for proposed eastern access route alignment 44 Proposed north-south access road 45 Rights reserved
B Other IampAP comments and issues 1 Comments received from Phillips Group
11 Effect of proposed project on traffic flow and businesses in the area 2 Comments received from Afrisam
21 Late submission of comments 22 South-north access road currently under construction 23 Zoning of Farm 1139 24 Suggestions for amending proposed mitigation measures 25 Details regarding activity information
No importance should be given to the order in which the categories are presented
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
2
Table 1 Summary table of comments received on the draft BAR with responses from SLR and the project technical team as appropriate
NO ISSUE NAME DATE COMMENT RESPONSE
A AUTHORITY COMMENTS AND ISSUES
1 COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY 11 Implications of
Draft EMF for Saldanha region
Doretha Kotze 20170329 1 Your letter dated 9 March 2017 and the information contained in the Draft BAR for the proposal refer
2 The Environmental Management Framework (EMF) for the Saldanha region is currently being revisited as part of the drafting of the Greater Saldanha Regional Spatial Implementation Framework by the Western Cape Provincial Department of Environmental Affairs and Development Planning It is recommended that this proposal be aligned with the outcomes of the different studies being undertaken as part of the finalisation of the EMF since Farm 1139 is situated in an area that has been identified as a Conflict Area in terms of the Urban Conservation Zone and Industrial Development Zone For more information of the EMF process kindly contact Ryan Nel at GIBB Consulting (rnelgibbcoza or Tel 011 519 4600)
We have taken the Draft EMF into consideration in the revised BAR (refer to Section D2(c)) However the document has not yet been formally adopted Thus the implied action by the Saldanha Municipality namely to resolve the conflict in the process of updating their Spatial Development Framework has not yet been undertaken Thus the formal land use status of the property remains intended for industrial development
12 Servitudes on the property
Doretha Kotze 20170329 3 Several servitudes had been registered over Farm 1139 over the years accommodating power lines water pipelines and rights of way Two bulk water pipelines of the West Coast District Municipality traversing the property in the northwest will be crossed by the proposed new access roads Care should be taken during the construction phase to prevent negative impacts on these pipelines
The project design engineers are aware of the existence of servitudes As necessary application would be made for wayleaves from the district and local municipalities if any works occur near water or other bulk services infrastructure
2 COMMENTS FROM DEPARTMENT OF ENVIRONMENTAL AFFAIRS AND DEVELOPMENT PLANNING 21 Applicable listed
activities M Schippers 20170407 The draft BAR dated March 2017 and received by this Department
on 09 March 2017 refer 1 Applicable listed activities 11 It is noted that Activity 12 of GN No R985 is being applied for 12 Please note that the abovementioned activity is not applicable
to the proposed development since the vegetation occurring on the proposed site has not been classified as a critically endangered or endangered ecosystem in terms of the National Environmental Management Biodiversity Act of 2004 (ldquoNEMBArdquo) List of Threatened Ecosystems in Need of Protection December 2011)
13 This activity must be excluded from the application
We have noted the comments in Item 1 and have amended the revised BAR accordingly ndash see Sections A1(c) and B5(c) and (d)
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3
NO ISSUE NAME DATE COMMENT RESPONSE 22 Originally signed
and dated declarations
M Schippers 07 April17 2 The duly dated and originally signed declarations as completed by the applicant the Environmental Assessment Practitioner and the specialists who compiled the specialist reports as part of the Environmental Impact Assessment Process must be included in the BAR to be submitted to the competent authority
The originally signed declarations will be included in the final BAR which will be submitted to your Department after the conclusion of the revised BAR comment period
23 Proof of public participation
M Schippers 07 April17 3 Proof of Public Participation 31 Proof of the public participation conducted must be included in
the BAR to be submitted to the competent authority please note that the proof must include inter alia the following
311 A copy of the newspaper advertisement (ldquonewspaper clippingrdquo) that was placed indicating the name of the newspaper and date of publication
312 Photographs showing the notice displayed on site and a copy of the text displayed on the notice and
313 With regards to the written notices provided please note the following
bull If registered mail was sent a list of the registered mail sent as obtained from the post office must be provided
bull If regular mail was sent a list of the mail sent as obtained from the post office must be provided
bull If a facsimile was sent a copy of the facsimile report must be provided
bull If an electronic mail was sent a copy of the electronic mail sent and delivery reports must be provided and
bull If a ldquomail droprdquo was done a signed register of ldquomail dropsrdquo must be provided
Proof of public participation has been included in the revised BAR as follows bull Newspaper advertisement ndash Appendix F2 bull Site notice ndash Appendix F2 and bull Written notifications ndash Appendix F3 Please note that as e-mail addresses were available for all IampAPs registered on the database the formal notification letter was sent by means of electronic mail However delivery reports were not requested as this requirement is not stated in the relevant legislation nor in any guideline document on public participation of which we are aware Thus we have included a copy of the e-mail notification sent as adequate proof of distribution Hard copies of letters were delivered to representatives of commenting authorities proof of which is also included in Appendix F3
3 COMMENTS FROM SALDANHA BAY MUNICIPALITY 31 Critical
Biodiversity Areas
Mr E Mmbadi 20170410 1 Basic Assessment Report for the Proposed New Access Roads to the Saldanha Bay Industrial Development Zone dated 07 March 2017 refers
2 Even though the site is located outside the Critical Biodiversity Area it may function as a ldquostepping stonerdquo corridor that allows for animal and plant movement across the landscape Development within such sites should consider ecological connectivity of the landscape and care should be taken not to disrupt this connectivity especially for a site surrounded by Critical Biodiversity Areas
The draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest Western Cape Biodiversity Spatial Plan became available in April 2017 and was taken into consideration in the revised BAR which will be made available for a further review and comment period
32 Cumulative Mr E Mmbadi 20170410 3 The report should highlight the potential cumulative impacts of These comments have been noted As the
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
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4
NO ISSUE NAME DATE COMMENT RESPONSE impact of construction on ambient air quality
several construction activities on ambient air quality Viewing the impacts of access roads construction in isolation may only reveal limited potential impacts on the ambient air quality The report should also look at the possible release of iron ore dust trapped on vegetation into the atmosphere
construction phase of the proposed project has not yet been scheduled it cannot be assumed that it will occur while other road construction projects in the area are in progress Reference to the implications of the possible release of iron ore dust trapped on vegetation for dust generation and control during the construction phase has been incorporated into the revised BAR (see Sections F2(b) and F615) and the Construction EMP (see Section 312(b))
33 Road maintenance after completion
Mr E Mmbadi 20170410 4 In most cases after the construction work is completed the roads are handed over to local authority to maintain and service If it is envisaged to hand over the proposed access roads to Saldanha Bay Municipality (ldquoSBMrdquo) the report should acknowledge such intention Also ensure that all the requirements from SBM with regard to roads are met Please contact Manager Roads amp Stormwater (jeremyjarvissbmgovza 022 701 7049) in this regard
The design engineers have engaged with SBM regarding the future management of the roads as is indicated by the following statement in the BAR ldquoSaldanha Bay Municipality has requested that the road reserve should be registered as a separate erf which would be a portion of this propertyrdquo (see Section A2)
34 Water use during construction phase
Mr E Mmbadi 20170410 5 SBM commenced with the implementation of level 3 water restriction Please advise if there is confirmation from the municipality with regard to the supply of water to the proposed development SBM discourages the use of potable water as a dust suppression measure or for any construction purpose please indicate the developmentrsquos potential water source The use of treated effluent from the waste water treatment works could be an option Please contact Manager of Bulk Water and Sanitation (gavinwilliamasbmgovza 022 701 7047) in this regard Also consult with the Department of Water and Sanitation with regard to the water use application process
These comments regarding water conservation have been noted and relevant measures to prevent the use of potable water for dust suppression have been included in the revised BAR (see Sections F2(b) F3 and E615 of the revised BAR and Section 312(a) of the Construction EMP) Please note that the road development would only require a limited supply of water during the construction phase which the Contractor would be required to source from available resources Consultation with DWS regarding a water use application may thus not be relevant
35 Palaeontological and archaeological findings
Mr E Mmbadi 20170410 6 Please inform the Environment amp Heritage Section of the SBM on any Palaeontological and Archaeological findings for our records
This request has been included in the revised BAR (see Section F617) as well as the Construction EMP (see Section 3102(e))
4 COMMENTS FROM CAPENATURE 41 Status of
vegetation types Alana Duffell-Canham
20170410 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road 1 The proposed eastern access road passes through an area
These comments regarding the status of the vegetation types on the project site have been noted On the basis of the botanical assessment undertaken as part of the Basic Assessment process the condition of the Saldahna Limestone
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
5
NO ISSUE NAME DATE COMMENT RESPONSE covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet [been] listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6 000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
Strandveld vegetation located on the limestone ridge has indeed been described as of high botanical sensitivity in the draft BAR As to the status of the vegetation please take cognisance of DEAampDPrsquos position that only the formal classification of vegetation in terms of NEMBA is considered applicable in relation to the NEMA EIA Regulations This was in response to our indication in the draft BAR that Saldahna Flats Strandveld which is classified ldquoVulnerablerdquo should be considered ldquoEndangeredrdquo on the basis of a 2014 CapeNature status report Please refer to Comment and Response 21 above We thus have to assume that DEAampDP would consider the formal classification of Saldahna Limestone Strandveld as ldquoLeast Threatenedrdquo in terms of NEMBA as applicable
42 Critical Biodiversity Areas
Alana Duffell-Canham
20170410 2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent land cover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truth where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data
A mentioned in Response 31 above the draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest WCBSP which became available in April 2017 has been taken into consideration in the revised BAR Our observation regarding the mapping of the CBAs is that this covers a large area on the specific property and extends notably further northwards than the intact vegetation on the limestone ridge According to the ground-truthing of the botanical
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
CCA Environmental (Pty) LtdPage 1 of 1
SMEC03AR - IampAP DATABASE
20170605Selected Clients Organisation and Name List (2 column)
Mr A WichtAA Gawne
Mr L VenterAECOM
Mr G VenterAfrisam
Mr Q DollmanAfrisam South Africa (Pty) Ltd
Mr F BurgerAnglo American Kumba Iron Ore
Ms S DeanAvedia Energy (Pty) Ltd
Mr R SeymourBay Steel
The ManagerBidfreight Port Operations (Pty) Ltd
Mr A WichtBlouwaterbaai Property Owners Association
Mr J WichtBlouwaterbaai Property Owners Association
Mrs M WichtBlue Bay Lodge
Mr P MalherbeBlue Water Bay
Mr JF PhillipsBrent Oil Service Station
Ms V PriestleyCape West Coast Biosphere Reserve
Ms A Duffell-CanhamCapeNature
Mr W CarstensCartol Beleggings Edms Bpk
Mr B WichtConlands Properties (Pty) Ltd
Ms E de BruynDuferco Steel Processing
Mr J HattinghDuferco Steel Processing
Mr C LouwDuferco Steel Processing
Mr B BlackbeardFerroMarine Africa (Pty) Ltd
Mr J Van VuurenGenwest Steel amp Industrial Services
Mr RD SaborGVJ Electrical and Instrumentation (Pty) Ltd
Mr A SeptemberHeritage Western Cape
Mr J KotzeLangebaan Residents and Ratepayers Association
Mr J SelbyLangebaan Residents and Ratepayers Association
Mr K CoetseeLangemeer Property Developer
Mr S BurgerMOGS
Mr P CoetzeeMOGS
Mr A MartinMOGS
Mr HA LindsayPienaarspoort Property Owners Association
Mr A VermaakRoyal HaskoningDHV
Mr A CarnegieSaldanha Bay Action Group
Ms M De BeerSaldanha Bay BBBEE
Ms K BeukesSaldanha Bay IDZ Licensing Company (SOC) Ltd
Mr H MaraisSaldanha Bay IDZ Licensing Company (SOC) Ltd
Mr D SouthgateSaldanha Bay IDZ Licensing Company (SOC) Ltd
Ms L van AchterberghSaldanha Bay Industrial Development Zone
Ms N DuarteSaldanha Bay Municipality
Mr L GaffleySaldanha Bay Municipality
Mr FJ SchippersSaldanha Bay Municipality
Mr G SmithSaldanha Bay Municipality
Mr C van WykSaldanha Bay Water Quality Forum Trust
Mr J WalshSaldanha Bay Water Quality Forum Trust
Mnr I LeeSaldanha Sakekamer
Mr J De WaalSaldanha Steel
Mr B SylvesterSaldanha Steel
The ChairmanSaldanha Tourism Bureau
Mr D MacleodSaldok (Pty) Ltd
Ms K McGregorSMEC South Africa(Pty) Ltd
Ms J BarkerSunrise Energy (Pty) Ltd
Mr B HarmseSunrise Energy (Pty) Ltd
Ms B MathibeTirisano Training Organisation
Mr R JuliesTransnet Freight Rail
Ms E CoetzeeTransnet National Ports Authority
Mr Q KordomTransnet National Ports Authority
Mr W RouxTransnet National Ports Authority
Mr D SamuelsTransnet National Ports Authority
Ms J SmitTransnet National Ports Authority
Mr R BillettTransnet Properties
Mr R Van der MerweVDM Transport
Mr C van der WaltWCG Department of Agriculture
Mr H JonkerWCG Department of Economic Development amp Tourism
Ms G SwanepoelWCG Department of Tranport and Public Works
Mr M WattersWCG Department of Transport amp Public Works
Mr R BoyesWCG Department of Transport and Public Works
Ms D MarthezeWCG Department of Transport and Public Works
Mr W M SilbernaglWCG Department of Transport and Public Works
Ms D KotzeWest Coast District Municipality
Ms P HaarhoffWest Coast Fossil Park
The ManagerYzervarkensrug Projects amp Development
APPENDIX F2
SITE NOTICE AND ADVERTISEMENT
PUBLIC PARTICIPATION PROCESS
PROPOSED NEW ACCESS ROAD TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE OF A PUBLIC PARTICIPATION PROCESS IN TERMS OF THE NEMA EIA REGULATIONS 2014
APPLICANT SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (SBIDZ) LICENCING COMPANY (ldquoLICOrdquo)
CONSULTING ENGINEER SMEC SOUTH AFRICA (PTY) LTD (ldquoSMECrdquo)
ENVIRONMENTAL ASSESSMENT PRACTITIONER SLR CONSULTING (SOUTH AFRICA) (PTY) LTD (ldquoSLRrdquo)
DESCRIPTION AND LOCATION LICO IS PROPOSING THE FOLLOWING ADDITIONS TO THE ROAD NETWORK FOR THE SBIDZ AREA bull CONSTRUCTION OF A NEW EAST-WEST ACCESS ROAD AND NEW INTERSECTION ON MINOR ROAD (OP) 7645 IN ORDER TO PROVIDE ACCESS TO THE
SBIDZ AREA TO THE NORTH OF MR559 THIS ROAD WOULD ALSO PROVIDE ACCESS TO THE NEW AFRISAM CEMENT PLANT AND bull EXTENSION OF THE SOUTH-NORTH ACCESS ROAD ALONG THE SBIDZ EASTERN BOUNDARY TO PROVIDE AN ALTERNATIVE ACCESS TO DUFERCO
APPLICATION FOR ENVIRONMENTAL AUTHORISATION TO UNDERTAKE THE FOLLOWING LISTED ACTIVITIES IN TERMS OF GOVERNMENT NOTICE R983 (LISTING NOTICE 1) 24(ii) AND IN TERMS OF GOVERNMENT NOTICE R985 (LISTING NOTICE 3) 12(a)
OPPORTUNITY TO PARTICIPATE NOTICE IS HEREBY GIVEN THAT A BASIC ASSESSMENT PROCESS IS BEING UNDERTAKEN FOR THIS PROPOSED PROJECT IF YOU ANDOR YOUR ORGANISATION WISH TO REGISTER ON THE PROJECT DATABASE REQUIRE ADDITIONAL INFORMATION ANDOR WISH TO RAISE ANY ISSUES OR CONCERNS REGARDING THE PROPOSED PROJECT PLEASE CONTACT ENA DE VILLIERS OF SLR AT THE BELOW CONTACT DETAILS
SLR CONTACT DETAILS UNIT 39 ROELAND SQUARE 30 DRURY LANE CAPE TOWN 8000 TEL (021) 461 11189 FAX (021) 461 1120 EMAIL edevilliersslrconsultingcom
SITE NOTICE PHOTOGRAPHS
Site notice placed at the eastern end of the proposed new eastern access road along the road reserve boundary of Minor Road 7645 (Port Road)
Site notice placed at the southern end of the proposed new north-south road western end of the proposed new eastern access road at the eastern entrance to the Saldanha Bay Industrial Development Zone
NOTICE OF PUBLIC PARTICIPATION PROCESS
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Notice is hereby given of a public participation process in terms of the National Environmental Management Act (No 107 of 1998) (NEMA) and Environmental Impact Assessment (EIA) Regulations 2014
Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) Environmental Assessment Practitioner SLR Consulting (South Africa) (Pty) Ltd (SLR)
Project description The SBIDZ-LC is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) namely bull A new eastern access road and new intersection on Minor Road 7645 (Port Road) to
provide access to the SBIDZ area north of Main Road 559 (Camp Road) as well as to a proposed new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
Application for Environmental Authorisation (EA) to undertake the following activities The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
SLR Consulting Contact Details Unit 39 Roeland Square 30 Drury Lane CAPE TOWN 8001 Tel (021) 461 1118 Fax (021) 461 1120 E-mail edevilliersslrconsultingcom Website wwwslrconsultingcomza Date of advertisement 9 March 2017
SMEC03ARStakeholder docsAdvert_Notice Advert ndash new access roads (March 2017)
22 Weslander GEKLASSIFISEERD CLASSIFIEDS 9 Maart 2017
DIRECTORATE ENGINEERING amp PLANNING SERVICES
DIRECTORATE FINANCE
DEPARTMENT SOLID WASTE
DEPARTMENT SUPPLY CHAIN MANAGEMENT
DEPARTMENT REVENUE
Superintendent Solid Waste Management Landfills
Senior Bid Administrator
Meter Reader
Applicants must be in possession of a National Diploma in Civil Engineering with Solid WasteManagement 4 as an additional subject bull 2 yearsrsquo relevant experience within Civil Engineering of which 1year should be on a supervisory level bull Computer Literacy bull Code B driverrsquos License bull Good communicationskills in two of the three official languages of the Western Cape
Duties will entail Perform administrative functions bull Communicate information to community memberswith regards to landfill sites and transfer stations bull Manage landfill sites and transfer stations bull Monitor toxicwaste as per the relevant regulations bull Manage the staff discipline and safety within the section bull Collectionof borehole water samples twice a year bull Follow-up on reported incidents bull Manage assets (equipment andmachinery) within the section bull Tender and contract administration
Applicants must be in possession of a Grade 12 bull 4 yearsrsquo relevant Supply Chain Managementexperience bull Computer literacy bull Code B driverrsquos license will serve as a recommendation bull Goodcommunication skills in two of the three official languages of the Western Cape
Duties will entail Administer Bid specifications process bull Administer the opening and registration oftenders bull Ensure that contracts do not lapse in terms of the validity period bull Administer the performance ofvendorsbidders above R200 000 bull Provide Human Resource support bull Report any irregularities to theSupply Chain Manager bull Internal and external communication
Salary Scale T11 (R220 16214 ndash R285 76824 p a)Enquiries Ms H Meeding Tel (022) 701 6916
Applicants must be in possession of a Grade 12 bull Code B driverrsquos license bull Good numerical skillsbull Physically fit and healthy bull Good communication skills in two of the three official languages of the WesternCape
Duties will entail The accurate reading and recording of meter readings to ensure that readings are beingprocessed and that all customers are charged with correct amounts bull Noting and reporting of complaints onfaulty water and electricity meters bull Update of route cards to ensure that new developments and areas arerecorded on the financial- and meter reading system
Salary scale T6 (R108 07992 ndash R140 29232 pa)Enquiries Mr H Smith Tel (022) 701 7011
Closing Date 23 March 2017 at 1200
NOTES TO APPLICANT
bull Thank you for your interest in seeking employment with usbull All applications should be accompanied by a completed application form (obtainable from our
Human Resource office or website wwwsbmgovza) clearly reflecting the name of the positionapplying for a comprehensive CV a certified copy of your ID driverrsquos license and educationalqualifications
bull No original documents attached to the application will be safe keptreturnedbull Applications without afore - mentioned will not be consideredbull Applications should be forwarded to Human Resource Services Private Bag X12 Vredenburg
7380 or via email to munsbmgovzabull ApplicationsSupporting documents larger that 2MB sent via email are not accommodatedbull For the implementation of the Employment Act candidates are encouraged to indicate their race
gender and disabilitybull No late applications will be consideredbull Further communication will be limited to shortlisted candidates If you have not received a
response within 3 (three) months of the closing date please consider your applicationunsuccessful
bull All appointments are subject to a medical assessment criminal record and reference checks fromprevious and current employer(s)
bull The Council beholds the right to make an appointment
Serve Grow and SucceedTogether
Saldanha Bay Municipality is a high profile municipality that takes care of its people to deliver thehighest quality of service to its residents and visitors We are also committed to the goals of ourEmployment Equity Plan If you are competent and committed and would like to work in aprofessional environment you are welcome to apply for the following positions on our staffestablishment
T (022) 701 7000 F (022) 715 1518 munsbmgovza wwwsbmgovzabull bull bull
00000000-DW090317
NOTICE OF PUBLIC PARTICIPATION PROCESS
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THESALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SMEC03AR 022017 DEAampDP REF NO 16331F417301117
Notice is hereby given of a public participation process in terms of the National Environmental ManagementAct (No 107 of 1998) (NEMA) and Environmental ImpactAssessment (EIA) Regulations 2014
Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC)EnvironmentalAssessment Practitioner SLR Consulting (SouthAfrica) (Pty) Ltd (SLR)
Project description The SBIDZ-LC is proposing to develop two new access roads to the Saldanha BayIndustrial Development Zone (SBIDZ) namelybull Anew eastern access road and new intersection on Minor Road 7645 (Port Road) to provide access to
the SBIDZ area north of Main Road 559 (Camp Road) as well as to a proposed new Afrisam cementplant and
bull Anew north-south access road along the SBIDZ eastern boundary to provide an alternative access tothe Duferco steel processing plant
Application for EnvironmentalAuthorisation (EA) to undertake the following activitiesThe proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in termsof NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (ListingNotice 3)Activities 12 and 18ABasicAssessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor yourorganisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on theBasic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-daycomment period from 10 March to 10 April 2017 (including an additional day to cover the intervening publicholiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Anycomment should be submitted by no later than 10April 2017
SLR Consulting Contact DetailsUnit 39 Roeland Square 30 Drury LaneCAPE TOWN 8001Tel (021) 461 1118 Fax (021) 461 1120E-mail edevilliersslrconsultingcomWebsite wwwslrconsultingcomza Date of advertisement 9 March 2017
0000000-DW090317
Serve Grow and SucceedTogether
ApplicantAansoeker amp OwnerEienaar CK RUMBOLL amp PARTNERS
TEL 022-4871661 ndash Zanellerumbollcoza
Reference numberVerwysingsnommer NR 12319
Property DescriptionEiendomsbeskrywing FARMPLAAS DE KLIP NR 12319
Physical AddressFisiese adres VREDENBURG
Notice is hereby given in terms of Sections 45 amp 46 of the
Saldanha Bay Municipal Land Use Planning By-law that
Saldanha Bay Municipality is considering the following
i) a Consent Use (special usage) in terms Section 15(2)(o) in
order to establish 4 additional residential units on Portion
19 of the Farm De Klip No 123
Details are available for scrutiny at the Municipal Managerrsquos
office during weekdays between 0830 and 1630 contact
the Town Planning Department at 17 Main Street
Vredenburg Any written comments may be addressed to
the Municipal Manager at Private Bag x 12 17 Main Street
Vredenburg doreendunnsbmgovza on or before 10
April 2017 quoting your name address or contact details
interest in the application and reasons for comments
Telephonic enquiries can be made to Bradley Rubidge at 022
- 701 7080 The Municipality may refuse to accept comment
received after the closing date Any person who cannot
write will be assisted by a Municipal official by transcribing
their comments Commentsobjections will be forwarded to
the applicant for hisher response
N1817 (09-03-2017)
K e n n i s w o r d h i e r m e e g e g e e i n g e v o l g e
Artikels 45 amp 46 van die Saldanhabaai Munisipale
Grondgebruikbeplanningsverordening dat Saldanhabaai
M u n i s i p a l i t e i t d i e v o l g e n d e o o r w e e g
i) lsquon Vergunningsgebruik (spesiale gebruik) in terme Artikel
15(2)(a) ten einde 4 addisionele residensieumlle eenhede op
Gedeelte 19 van die Plaas De Klip Nr 123 te
akkommodeer
Nadere besonderhede lecirc ter insae by die Munisipale
Bestuurder se kantoor gedurende weeksdae tussen 0830
and 1630 kontak die Departement Stadsbeplanning by
Hoofstraat 17 Vredenburg Enige skriftelike kommentaar
kan gerig word aan die Munisipale Bestuurder Privaatsak x
12 Hoofstraat 17 Vredenburg doreendunnsbmgovza
op of voor 10 April 2017 met vermelding van u naam adres
of kontakbesonderhede belangstelling in die aansoek en
redes vir kommentaar Telefoniese navrae kan gerig word
aan Bradley Rubidge by 022 - 701 7080 Die Munisipaliteit
mag weier om kommentaar te aanvaar wat na die
sluitingsdatum ontvang word Enige persoon wat nie kan
skryf sal bygestaan word deur n munisipale amptenaar vir
transkribering van hul kommentaar Besware sal aan die
applicant gestuur word vir syhaar repliek
K1817 (09-03-2017)
T (022) 701 7000 F (022) 715 1518 munsbmgovza wwwsbmgovzabull bull bull
0000000-DW090317
Madeleyn Ingelyf prokureurs vanVredenburg benodig die dienste van n
litigasie invorderings tikster
Die geskikte kandidaat moetrekenaarvaardig en tweetalig wees en
sal toepaslike ondervinding n sterkaanbeveling wees
Stuur asseblief u CV per e pos aanniekiemadeleyncoza
of lewer per hand af aanMadeleyn Ingelyf
Hoofstraat 6 Vredenburg
LITIGASIE
TIKSTER
000000-DW090317
BESTUURDER VIR
HOSPITALITEITSBEDRYF
Vorige ondervinding n vereisteGoeie menseverhoudings
Uitstekende kommunikasie vermoeumlnsMoet onder druk kan werk asook lang ure
Verkieslik manlik
Kontak 073 070 8414
Sluitingsdatum 16 Maart 2017
000000-DW090317
BRAAIKUIKEN
PLAASBESTUURDER(WORCESTER AREA)
bull Algemene bestuur van braaikuiken plaasbull Beheer en kontrole oor personeelbull Opdragte van bestuur aan personeel oordra en
toesien dat werk effektief uitgevoer wordbull Betroubaar eerlik en hardwerkendbull Moet onder druk kan funksioneerbull Moet bereid wees om oortyd en naweke te werkbull Bestuurderslisensie n vereistebull Geen ondervinding nodig
Gratis behuising op plaas ingesluitSluitingsdatum 20 Maart 2017
E-pos soverbycompnetcozaof faks na 086 4306 721
Indien geen reaksie teen 25 Maart 2017
was u aansoek onsuksesvol
0000000-DW090317
TIPPLER 3 PROJECT
All Local Building Contractors areencouraged to register their
companies on the Group Five Thulanda JV Vendor databaseThe database will be used to
Registration places your company in a better position tobe considered for various sub-contracts that need to beawarded for the Tippler 3 and other Group Five Thulanda Projects in the region
To register on our Supplier Development (SD)Database all local companies are required to completea Vendors Take on Form and to submit the dulycompleted form together with necessary documentrequirements to our SD Officer Nosi Hlulelo byemailing her at nosihlulelothulandacoza
MAKING A DIFFERENCE
000000-DW090317
APPENDIX F3
PROOF OF BAR NOTIFICATION
From Mandy KulaTo Mandy KulaBcc brianwichtcoza yolandaswartmwebcoza adminbluebaylodgecoza admin3bluebaylodgecoza aduffell-canhamcapenaturecoza
Subject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENT
Date 09 March 2017 012626 PMAttachments Exec Summary - Basic Assessment Report (9Mar17)pdf
Let ndash BAR Notification (9Mar17)pdfimage4981fbPNG
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposedproject for a 30-day review and comment period from 10 March to 10 April 2017 (including one additional day to coverthe intervening public holiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
SLR Consulting (South Africa) (Pty) Ltd Page iv
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
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Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
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5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
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economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
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Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
Proposed north-south access road
Proposed eastern access road
Trunk Road 85
Main Road 559 Minor Road 7645
Saldanha Bay Industrial Development Zone
Duferco
Future Afrisam cement plant
Proposed north-south access road
Proposed eastern access road
From Ena de VilliersTo Ena de VilliersBcc gerritsmithsbmgovza malcolmwatterswesterncapegovza corvdwelsenburgcom aduffell-canhamcapenaturecoza
melaneseschipperswesterncapegovzaSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
REMINDER OF CLOSURE OF BAR COMMENT PERIODDate 04 April 2017 110142 AMAttachments image6c48afPNG
Dear SirsMadams We would like to take this opportunity to remind you of the closure of the comment period for the above-mentioned projecton 10 April 2017 Kindly submit your comments to Mandy Kula (mkulaslrconsultingcom) or myself at the contact particularsbelow You are welcome to contact us regarding any enquiries Thanks and best regardsEna
Ena de VilliersEnvironmental ConsultantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
APPENDIX F4
DRAFT BAR COMMENTS AND RESPONSES REPORT
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SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
1
DRAFT BASIC ASSESSMENT REPORT (BAR)
COMMENTS AND RESPONSES REPORT
Written submissions were received from the following commenting authorities and other Interested and Affected Parties (IampAPs) during the BAR comment period
SUBMITTED BY METHOD AND DATE Authorities 1 West Coast District Municipality ndash Ms Doretha Kotze Email - 29 March 2017
2 Department of Environmental Affairs and Development Planning ndash Ms M Schippers Fax - 07 April 2017
3 Saldanha Bay Municipality ndash Mr E Mmbadi Email - 10 April 2017
4 CapeNature ndash Ms Alana Duffell-Canham Email - 11 April 2017
Other IampAPs 1 Phillips Group ndash Mr Jan Phillips Email - 10 March 2017
Copies of the written comments are attached as Attachment A to this report arranged according to the order indicated in the table above The comments received are presented in Table 1 below and have been categorised as follows A Authority comments and issues 1 Comments received from West Coast District Municipality
11 Implications of Draft EMF for Saldanha region 12 Servitudes on the property
2 Comments received from Department of Environmental Affairs and Development Planning 21 Applicable listed Activities 22 Originally signed and dated declarations 23 Proof of Public Participation
3 Comments received from Saldanha Bay Municipality 31 Critical Biodiversity Areas 32 Cumulative impact of construction on ambient air quality 33 Road maintenance after completion 34 Water use during construction phase 35 Palaeontological and archaeological findings
4 Comments received from CapeNature 41 Status of vegetation types 42 Critical Biodiversity Areas 43 Implications for proposed eastern access route alignment 44 Proposed north-south access road 45 Rights reserved
B Other IampAP comments and issues 1 Comments received from Phillips Group
11 Effect of proposed project on traffic flow and businesses in the area 2 Comments received from Afrisam
21 Late submission of comments 22 South-north access road currently under construction 23 Zoning of Farm 1139 24 Suggestions for amending proposed mitigation measures 25 Details regarding activity information
No importance should be given to the order in which the categories are presented
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
2
Table 1 Summary table of comments received on the draft BAR with responses from SLR and the project technical team as appropriate
NO ISSUE NAME DATE COMMENT RESPONSE
A AUTHORITY COMMENTS AND ISSUES
1 COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY 11 Implications of
Draft EMF for Saldanha region
Doretha Kotze 20170329 1 Your letter dated 9 March 2017 and the information contained in the Draft BAR for the proposal refer
2 The Environmental Management Framework (EMF) for the Saldanha region is currently being revisited as part of the drafting of the Greater Saldanha Regional Spatial Implementation Framework by the Western Cape Provincial Department of Environmental Affairs and Development Planning It is recommended that this proposal be aligned with the outcomes of the different studies being undertaken as part of the finalisation of the EMF since Farm 1139 is situated in an area that has been identified as a Conflict Area in terms of the Urban Conservation Zone and Industrial Development Zone For more information of the EMF process kindly contact Ryan Nel at GIBB Consulting (rnelgibbcoza or Tel 011 519 4600)
We have taken the Draft EMF into consideration in the revised BAR (refer to Section D2(c)) However the document has not yet been formally adopted Thus the implied action by the Saldanha Municipality namely to resolve the conflict in the process of updating their Spatial Development Framework has not yet been undertaken Thus the formal land use status of the property remains intended for industrial development
12 Servitudes on the property
Doretha Kotze 20170329 3 Several servitudes had been registered over Farm 1139 over the years accommodating power lines water pipelines and rights of way Two bulk water pipelines of the West Coast District Municipality traversing the property in the northwest will be crossed by the proposed new access roads Care should be taken during the construction phase to prevent negative impacts on these pipelines
The project design engineers are aware of the existence of servitudes As necessary application would be made for wayleaves from the district and local municipalities if any works occur near water or other bulk services infrastructure
2 COMMENTS FROM DEPARTMENT OF ENVIRONMENTAL AFFAIRS AND DEVELOPMENT PLANNING 21 Applicable listed
activities M Schippers 20170407 The draft BAR dated March 2017 and received by this Department
on 09 March 2017 refer 1 Applicable listed activities 11 It is noted that Activity 12 of GN No R985 is being applied for 12 Please note that the abovementioned activity is not applicable
to the proposed development since the vegetation occurring on the proposed site has not been classified as a critically endangered or endangered ecosystem in terms of the National Environmental Management Biodiversity Act of 2004 (ldquoNEMBArdquo) List of Threatened Ecosystems in Need of Protection December 2011)
13 This activity must be excluded from the application
We have noted the comments in Item 1 and have amended the revised BAR accordingly ndash see Sections A1(c) and B5(c) and (d)
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3
NO ISSUE NAME DATE COMMENT RESPONSE 22 Originally signed
and dated declarations
M Schippers 07 April17 2 The duly dated and originally signed declarations as completed by the applicant the Environmental Assessment Practitioner and the specialists who compiled the specialist reports as part of the Environmental Impact Assessment Process must be included in the BAR to be submitted to the competent authority
The originally signed declarations will be included in the final BAR which will be submitted to your Department after the conclusion of the revised BAR comment period
23 Proof of public participation
M Schippers 07 April17 3 Proof of Public Participation 31 Proof of the public participation conducted must be included in
the BAR to be submitted to the competent authority please note that the proof must include inter alia the following
311 A copy of the newspaper advertisement (ldquonewspaper clippingrdquo) that was placed indicating the name of the newspaper and date of publication
312 Photographs showing the notice displayed on site and a copy of the text displayed on the notice and
313 With regards to the written notices provided please note the following
bull If registered mail was sent a list of the registered mail sent as obtained from the post office must be provided
bull If regular mail was sent a list of the mail sent as obtained from the post office must be provided
bull If a facsimile was sent a copy of the facsimile report must be provided
bull If an electronic mail was sent a copy of the electronic mail sent and delivery reports must be provided and
bull If a ldquomail droprdquo was done a signed register of ldquomail dropsrdquo must be provided
Proof of public participation has been included in the revised BAR as follows bull Newspaper advertisement ndash Appendix F2 bull Site notice ndash Appendix F2 and bull Written notifications ndash Appendix F3 Please note that as e-mail addresses were available for all IampAPs registered on the database the formal notification letter was sent by means of electronic mail However delivery reports were not requested as this requirement is not stated in the relevant legislation nor in any guideline document on public participation of which we are aware Thus we have included a copy of the e-mail notification sent as adequate proof of distribution Hard copies of letters were delivered to representatives of commenting authorities proof of which is also included in Appendix F3
3 COMMENTS FROM SALDANHA BAY MUNICIPALITY 31 Critical
Biodiversity Areas
Mr E Mmbadi 20170410 1 Basic Assessment Report for the Proposed New Access Roads to the Saldanha Bay Industrial Development Zone dated 07 March 2017 refers
2 Even though the site is located outside the Critical Biodiversity Area it may function as a ldquostepping stonerdquo corridor that allows for animal and plant movement across the landscape Development within such sites should consider ecological connectivity of the landscape and care should be taken not to disrupt this connectivity especially for a site surrounded by Critical Biodiversity Areas
The draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest Western Cape Biodiversity Spatial Plan became available in April 2017 and was taken into consideration in the revised BAR which will be made available for a further review and comment period
32 Cumulative Mr E Mmbadi 20170410 3 The report should highlight the potential cumulative impacts of These comments have been noted As the
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4
NO ISSUE NAME DATE COMMENT RESPONSE impact of construction on ambient air quality
several construction activities on ambient air quality Viewing the impacts of access roads construction in isolation may only reveal limited potential impacts on the ambient air quality The report should also look at the possible release of iron ore dust trapped on vegetation into the atmosphere
construction phase of the proposed project has not yet been scheduled it cannot be assumed that it will occur while other road construction projects in the area are in progress Reference to the implications of the possible release of iron ore dust trapped on vegetation for dust generation and control during the construction phase has been incorporated into the revised BAR (see Sections F2(b) and F615) and the Construction EMP (see Section 312(b))
33 Road maintenance after completion
Mr E Mmbadi 20170410 4 In most cases after the construction work is completed the roads are handed over to local authority to maintain and service If it is envisaged to hand over the proposed access roads to Saldanha Bay Municipality (ldquoSBMrdquo) the report should acknowledge such intention Also ensure that all the requirements from SBM with regard to roads are met Please contact Manager Roads amp Stormwater (jeremyjarvissbmgovza 022 701 7049) in this regard
The design engineers have engaged with SBM regarding the future management of the roads as is indicated by the following statement in the BAR ldquoSaldanha Bay Municipality has requested that the road reserve should be registered as a separate erf which would be a portion of this propertyrdquo (see Section A2)
34 Water use during construction phase
Mr E Mmbadi 20170410 5 SBM commenced with the implementation of level 3 water restriction Please advise if there is confirmation from the municipality with regard to the supply of water to the proposed development SBM discourages the use of potable water as a dust suppression measure or for any construction purpose please indicate the developmentrsquos potential water source The use of treated effluent from the waste water treatment works could be an option Please contact Manager of Bulk Water and Sanitation (gavinwilliamasbmgovza 022 701 7047) in this regard Also consult with the Department of Water and Sanitation with regard to the water use application process
These comments regarding water conservation have been noted and relevant measures to prevent the use of potable water for dust suppression have been included in the revised BAR (see Sections F2(b) F3 and E615 of the revised BAR and Section 312(a) of the Construction EMP) Please note that the road development would only require a limited supply of water during the construction phase which the Contractor would be required to source from available resources Consultation with DWS regarding a water use application may thus not be relevant
35 Palaeontological and archaeological findings
Mr E Mmbadi 20170410 6 Please inform the Environment amp Heritage Section of the SBM on any Palaeontological and Archaeological findings for our records
This request has been included in the revised BAR (see Section F617) as well as the Construction EMP (see Section 3102(e))
4 COMMENTS FROM CAPENATURE 41 Status of
vegetation types Alana Duffell-Canham
20170410 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road 1 The proposed eastern access road passes through an area
These comments regarding the status of the vegetation types on the project site have been noted On the basis of the botanical assessment undertaken as part of the Basic Assessment process the condition of the Saldahna Limestone
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
5
NO ISSUE NAME DATE COMMENT RESPONSE covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet [been] listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6 000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
Strandveld vegetation located on the limestone ridge has indeed been described as of high botanical sensitivity in the draft BAR As to the status of the vegetation please take cognisance of DEAampDPrsquos position that only the formal classification of vegetation in terms of NEMBA is considered applicable in relation to the NEMA EIA Regulations This was in response to our indication in the draft BAR that Saldahna Flats Strandveld which is classified ldquoVulnerablerdquo should be considered ldquoEndangeredrdquo on the basis of a 2014 CapeNature status report Please refer to Comment and Response 21 above We thus have to assume that DEAampDP would consider the formal classification of Saldahna Limestone Strandveld as ldquoLeast Threatenedrdquo in terms of NEMBA as applicable
42 Critical Biodiversity Areas
Alana Duffell-Canham
20170410 2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent land cover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truth where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data
A mentioned in Response 31 above the draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest WCBSP which became available in April 2017 has been taken into consideration in the revised BAR Our observation regarding the mapping of the CBAs is that this covers a large area on the specific property and extends notably further northwards than the intact vegetation on the limestone ridge According to the ground-truthing of the botanical
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
APPENDIX F2
SITE NOTICE AND ADVERTISEMENT
PUBLIC PARTICIPATION PROCESS
PROPOSED NEW ACCESS ROAD TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE OF A PUBLIC PARTICIPATION PROCESS IN TERMS OF THE NEMA EIA REGULATIONS 2014
APPLICANT SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (SBIDZ) LICENCING COMPANY (ldquoLICOrdquo)
CONSULTING ENGINEER SMEC SOUTH AFRICA (PTY) LTD (ldquoSMECrdquo)
ENVIRONMENTAL ASSESSMENT PRACTITIONER SLR CONSULTING (SOUTH AFRICA) (PTY) LTD (ldquoSLRrdquo)
DESCRIPTION AND LOCATION LICO IS PROPOSING THE FOLLOWING ADDITIONS TO THE ROAD NETWORK FOR THE SBIDZ AREA bull CONSTRUCTION OF A NEW EAST-WEST ACCESS ROAD AND NEW INTERSECTION ON MINOR ROAD (OP) 7645 IN ORDER TO PROVIDE ACCESS TO THE
SBIDZ AREA TO THE NORTH OF MR559 THIS ROAD WOULD ALSO PROVIDE ACCESS TO THE NEW AFRISAM CEMENT PLANT AND bull EXTENSION OF THE SOUTH-NORTH ACCESS ROAD ALONG THE SBIDZ EASTERN BOUNDARY TO PROVIDE AN ALTERNATIVE ACCESS TO DUFERCO
APPLICATION FOR ENVIRONMENTAL AUTHORISATION TO UNDERTAKE THE FOLLOWING LISTED ACTIVITIES IN TERMS OF GOVERNMENT NOTICE R983 (LISTING NOTICE 1) 24(ii) AND IN TERMS OF GOVERNMENT NOTICE R985 (LISTING NOTICE 3) 12(a)
OPPORTUNITY TO PARTICIPATE NOTICE IS HEREBY GIVEN THAT A BASIC ASSESSMENT PROCESS IS BEING UNDERTAKEN FOR THIS PROPOSED PROJECT IF YOU ANDOR YOUR ORGANISATION WISH TO REGISTER ON THE PROJECT DATABASE REQUIRE ADDITIONAL INFORMATION ANDOR WISH TO RAISE ANY ISSUES OR CONCERNS REGARDING THE PROPOSED PROJECT PLEASE CONTACT ENA DE VILLIERS OF SLR AT THE BELOW CONTACT DETAILS
SLR CONTACT DETAILS UNIT 39 ROELAND SQUARE 30 DRURY LANE CAPE TOWN 8000 TEL (021) 461 11189 FAX (021) 461 1120 EMAIL edevilliersslrconsultingcom
SITE NOTICE PHOTOGRAPHS
Site notice placed at the eastern end of the proposed new eastern access road along the road reserve boundary of Minor Road 7645 (Port Road)
Site notice placed at the southern end of the proposed new north-south road western end of the proposed new eastern access road at the eastern entrance to the Saldanha Bay Industrial Development Zone
NOTICE OF PUBLIC PARTICIPATION PROCESS
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Notice is hereby given of a public participation process in terms of the National Environmental Management Act (No 107 of 1998) (NEMA) and Environmental Impact Assessment (EIA) Regulations 2014
Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) Environmental Assessment Practitioner SLR Consulting (South Africa) (Pty) Ltd (SLR)
Project description The SBIDZ-LC is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) namely bull A new eastern access road and new intersection on Minor Road 7645 (Port Road) to
provide access to the SBIDZ area north of Main Road 559 (Camp Road) as well as to a proposed new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
Application for Environmental Authorisation (EA) to undertake the following activities The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
SLR Consulting Contact Details Unit 39 Roeland Square 30 Drury Lane CAPE TOWN 8001 Tel (021) 461 1118 Fax (021) 461 1120 E-mail edevilliersslrconsultingcom Website wwwslrconsultingcomza Date of advertisement 9 March 2017
SMEC03ARStakeholder docsAdvert_Notice Advert ndash new access roads (March 2017)
22 Weslander GEKLASSIFISEERD CLASSIFIEDS 9 Maart 2017
DIRECTORATE ENGINEERING amp PLANNING SERVICES
DIRECTORATE FINANCE
DEPARTMENT SOLID WASTE
DEPARTMENT SUPPLY CHAIN MANAGEMENT
DEPARTMENT REVENUE
Superintendent Solid Waste Management Landfills
Senior Bid Administrator
Meter Reader
Applicants must be in possession of a National Diploma in Civil Engineering with Solid WasteManagement 4 as an additional subject bull 2 yearsrsquo relevant experience within Civil Engineering of which 1year should be on a supervisory level bull Computer Literacy bull Code B driverrsquos License bull Good communicationskills in two of the three official languages of the Western Cape
Duties will entail Perform administrative functions bull Communicate information to community memberswith regards to landfill sites and transfer stations bull Manage landfill sites and transfer stations bull Monitor toxicwaste as per the relevant regulations bull Manage the staff discipline and safety within the section bull Collectionof borehole water samples twice a year bull Follow-up on reported incidents bull Manage assets (equipment andmachinery) within the section bull Tender and contract administration
Applicants must be in possession of a Grade 12 bull 4 yearsrsquo relevant Supply Chain Managementexperience bull Computer literacy bull Code B driverrsquos license will serve as a recommendation bull Goodcommunication skills in two of the three official languages of the Western Cape
Duties will entail Administer Bid specifications process bull Administer the opening and registration oftenders bull Ensure that contracts do not lapse in terms of the validity period bull Administer the performance ofvendorsbidders above R200 000 bull Provide Human Resource support bull Report any irregularities to theSupply Chain Manager bull Internal and external communication
Salary Scale T11 (R220 16214 ndash R285 76824 p a)Enquiries Ms H Meeding Tel (022) 701 6916
Applicants must be in possession of a Grade 12 bull Code B driverrsquos license bull Good numerical skillsbull Physically fit and healthy bull Good communication skills in two of the three official languages of the WesternCape
Duties will entail The accurate reading and recording of meter readings to ensure that readings are beingprocessed and that all customers are charged with correct amounts bull Noting and reporting of complaints onfaulty water and electricity meters bull Update of route cards to ensure that new developments and areas arerecorded on the financial- and meter reading system
Salary scale T6 (R108 07992 ndash R140 29232 pa)Enquiries Mr H Smith Tel (022) 701 7011
Closing Date 23 March 2017 at 1200
NOTES TO APPLICANT
bull Thank you for your interest in seeking employment with usbull All applications should be accompanied by a completed application form (obtainable from our
Human Resource office or website wwwsbmgovza) clearly reflecting the name of the positionapplying for a comprehensive CV a certified copy of your ID driverrsquos license and educationalqualifications
bull No original documents attached to the application will be safe keptreturnedbull Applications without afore - mentioned will not be consideredbull Applications should be forwarded to Human Resource Services Private Bag X12 Vredenburg
7380 or via email to munsbmgovzabull ApplicationsSupporting documents larger that 2MB sent via email are not accommodatedbull For the implementation of the Employment Act candidates are encouraged to indicate their race
gender and disabilitybull No late applications will be consideredbull Further communication will be limited to shortlisted candidates If you have not received a
response within 3 (three) months of the closing date please consider your applicationunsuccessful
bull All appointments are subject to a medical assessment criminal record and reference checks fromprevious and current employer(s)
bull The Council beholds the right to make an appointment
Serve Grow and SucceedTogether
Saldanha Bay Municipality is a high profile municipality that takes care of its people to deliver thehighest quality of service to its residents and visitors We are also committed to the goals of ourEmployment Equity Plan If you are competent and committed and would like to work in aprofessional environment you are welcome to apply for the following positions on our staffestablishment
T (022) 701 7000 F (022) 715 1518 munsbmgovza wwwsbmgovzabull bull bull
00000000-DW090317
NOTICE OF PUBLIC PARTICIPATION PROCESS
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THESALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SMEC03AR 022017 DEAampDP REF NO 16331F417301117
Notice is hereby given of a public participation process in terms of the National Environmental ManagementAct (No 107 of 1998) (NEMA) and Environmental ImpactAssessment (EIA) Regulations 2014
Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC)EnvironmentalAssessment Practitioner SLR Consulting (SouthAfrica) (Pty) Ltd (SLR)
Project description The SBIDZ-LC is proposing to develop two new access roads to the Saldanha BayIndustrial Development Zone (SBIDZ) namelybull Anew eastern access road and new intersection on Minor Road 7645 (Port Road) to provide access to
the SBIDZ area north of Main Road 559 (Camp Road) as well as to a proposed new Afrisam cementplant and
bull Anew north-south access road along the SBIDZ eastern boundary to provide an alternative access tothe Duferco steel processing plant
Application for EnvironmentalAuthorisation (EA) to undertake the following activitiesThe proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in termsof NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (ListingNotice 3)Activities 12 and 18ABasicAssessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor yourorganisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on theBasic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-daycomment period from 10 March to 10 April 2017 (including an additional day to cover the intervening publicholiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Anycomment should be submitted by no later than 10April 2017
SLR Consulting Contact DetailsUnit 39 Roeland Square 30 Drury LaneCAPE TOWN 8001Tel (021) 461 1118 Fax (021) 461 1120E-mail edevilliersslrconsultingcomWebsite wwwslrconsultingcomza Date of advertisement 9 March 2017
0000000-DW090317
Serve Grow and SucceedTogether
ApplicantAansoeker amp OwnerEienaar CK RUMBOLL amp PARTNERS
TEL 022-4871661 ndash Zanellerumbollcoza
Reference numberVerwysingsnommer NR 12319
Property DescriptionEiendomsbeskrywing FARMPLAAS DE KLIP NR 12319
Physical AddressFisiese adres VREDENBURG
Notice is hereby given in terms of Sections 45 amp 46 of the
Saldanha Bay Municipal Land Use Planning By-law that
Saldanha Bay Municipality is considering the following
i) a Consent Use (special usage) in terms Section 15(2)(o) in
order to establish 4 additional residential units on Portion
19 of the Farm De Klip No 123
Details are available for scrutiny at the Municipal Managerrsquos
office during weekdays between 0830 and 1630 contact
the Town Planning Department at 17 Main Street
Vredenburg Any written comments may be addressed to
the Municipal Manager at Private Bag x 12 17 Main Street
Vredenburg doreendunnsbmgovza on or before 10
April 2017 quoting your name address or contact details
interest in the application and reasons for comments
Telephonic enquiries can be made to Bradley Rubidge at 022
- 701 7080 The Municipality may refuse to accept comment
received after the closing date Any person who cannot
write will be assisted by a Municipal official by transcribing
their comments Commentsobjections will be forwarded to
the applicant for hisher response
N1817 (09-03-2017)
K e n n i s w o r d h i e r m e e g e g e e i n g e v o l g e
Artikels 45 amp 46 van die Saldanhabaai Munisipale
Grondgebruikbeplanningsverordening dat Saldanhabaai
M u n i s i p a l i t e i t d i e v o l g e n d e o o r w e e g
i) lsquon Vergunningsgebruik (spesiale gebruik) in terme Artikel
15(2)(a) ten einde 4 addisionele residensieumlle eenhede op
Gedeelte 19 van die Plaas De Klip Nr 123 te
akkommodeer
Nadere besonderhede lecirc ter insae by die Munisipale
Bestuurder se kantoor gedurende weeksdae tussen 0830
and 1630 kontak die Departement Stadsbeplanning by
Hoofstraat 17 Vredenburg Enige skriftelike kommentaar
kan gerig word aan die Munisipale Bestuurder Privaatsak x
12 Hoofstraat 17 Vredenburg doreendunnsbmgovza
op of voor 10 April 2017 met vermelding van u naam adres
of kontakbesonderhede belangstelling in die aansoek en
redes vir kommentaar Telefoniese navrae kan gerig word
aan Bradley Rubidge by 022 - 701 7080 Die Munisipaliteit
mag weier om kommentaar te aanvaar wat na die
sluitingsdatum ontvang word Enige persoon wat nie kan
skryf sal bygestaan word deur n munisipale amptenaar vir
transkribering van hul kommentaar Besware sal aan die
applicant gestuur word vir syhaar repliek
K1817 (09-03-2017)
T (022) 701 7000 F (022) 715 1518 munsbmgovza wwwsbmgovzabull bull bull
0000000-DW090317
Madeleyn Ingelyf prokureurs vanVredenburg benodig die dienste van n
litigasie invorderings tikster
Die geskikte kandidaat moetrekenaarvaardig en tweetalig wees en
sal toepaslike ondervinding n sterkaanbeveling wees
Stuur asseblief u CV per e pos aanniekiemadeleyncoza
of lewer per hand af aanMadeleyn Ingelyf
Hoofstraat 6 Vredenburg
LITIGASIE
TIKSTER
000000-DW090317
BESTUURDER VIR
HOSPITALITEITSBEDRYF
Vorige ondervinding n vereisteGoeie menseverhoudings
Uitstekende kommunikasie vermoeumlnsMoet onder druk kan werk asook lang ure
Verkieslik manlik
Kontak 073 070 8414
Sluitingsdatum 16 Maart 2017
000000-DW090317
BRAAIKUIKEN
PLAASBESTUURDER(WORCESTER AREA)
bull Algemene bestuur van braaikuiken plaasbull Beheer en kontrole oor personeelbull Opdragte van bestuur aan personeel oordra en
toesien dat werk effektief uitgevoer wordbull Betroubaar eerlik en hardwerkendbull Moet onder druk kan funksioneerbull Moet bereid wees om oortyd en naweke te werkbull Bestuurderslisensie n vereistebull Geen ondervinding nodig
Gratis behuising op plaas ingesluitSluitingsdatum 20 Maart 2017
E-pos soverbycompnetcozaof faks na 086 4306 721
Indien geen reaksie teen 25 Maart 2017
was u aansoek onsuksesvol
0000000-DW090317
TIPPLER 3 PROJECT
All Local Building Contractors areencouraged to register their
companies on the Group Five Thulanda JV Vendor databaseThe database will be used to
Registration places your company in a better position tobe considered for various sub-contracts that need to beawarded for the Tippler 3 and other Group Five Thulanda Projects in the region
To register on our Supplier Development (SD)Database all local companies are required to completea Vendors Take on Form and to submit the dulycompleted form together with necessary documentrequirements to our SD Officer Nosi Hlulelo byemailing her at nosihlulelothulandacoza
MAKING A DIFFERENCE
000000-DW090317
APPENDIX F3
PROOF OF BAR NOTIFICATION
From Mandy KulaTo Mandy KulaBcc brianwichtcoza yolandaswartmwebcoza adminbluebaylodgecoza admin3bluebaylodgecoza aduffell-canhamcapenaturecoza
Subject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENT
Date 09 March 2017 012626 PMAttachments Exec Summary - Basic Assessment Report (9Mar17)pdf
Let ndash BAR Notification (9Mar17)pdfimage4981fbPNG
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposedproject for a 30-day review and comment period from 10 March to 10 April 2017 (including one additional day to coverthe intervening public holiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
SLR Consulting (South Africa) (Pty) Ltd Page iv
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
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Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
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Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
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Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
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Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
Proposed north-south access road
Proposed eastern access road
Trunk Road 85
Main Road 559 Minor Road 7645
Saldanha Bay Industrial Development Zone
Duferco
Future Afrisam cement plant
Proposed north-south access road
Proposed eastern access road
From Ena de VilliersTo Ena de VilliersBcc gerritsmithsbmgovza malcolmwatterswesterncapegovza corvdwelsenburgcom aduffell-canhamcapenaturecoza
melaneseschipperswesterncapegovzaSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
REMINDER OF CLOSURE OF BAR COMMENT PERIODDate 04 April 2017 110142 AMAttachments image6c48afPNG
Dear SirsMadams We would like to take this opportunity to remind you of the closure of the comment period for the above-mentioned projecton 10 April 2017 Kindly submit your comments to Mandy Kula (mkulaslrconsultingcom) or myself at the contact particularsbelow You are welcome to contact us regarding any enquiries Thanks and best regardsEna
Ena de VilliersEnvironmental ConsultantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
APPENDIX F4
DRAFT BAR COMMENTS AND RESPONSES REPORT
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
1
DRAFT BASIC ASSESSMENT REPORT (BAR)
COMMENTS AND RESPONSES REPORT
Written submissions were received from the following commenting authorities and other Interested and Affected Parties (IampAPs) during the BAR comment period
SUBMITTED BY METHOD AND DATE Authorities 1 West Coast District Municipality ndash Ms Doretha Kotze Email - 29 March 2017
2 Department of Environmental Affairs and Development Planning ndash Ms M Schippers Fax - 07 April 2017
3 Saldanha Bay Municipality ndash Mr E Mmbadi Email - 10 April 2017
4 CapeNature ndash Ms Alana Duffell-Canham Email - 11 April 2017
Other IampAPs 1 Phillips Group ndash Mr Jan Phillips Email - 10 March 2017
Copies of the written comments are attached as Attachment A to this report arranged according to the order indicated in the table above The comments received are presented in Table 1 below and have been categorised as follows A Authority comments and issues 1 Comments received from West Coast District Municipality
11 Implications of Draft EMF for Saldanha region 12 Servitudes on the property
2 Comments received from Department of Environmental Affairs and Development Planning 21 Applicable listed Activities 22 Originally signed and dated declarations 23 Proof of Public Participation
3 Comments received from Saldanha Bay Municipality 31 Critical Biodiversity Areas 32 Cumulative impact of construction on ambient air quality 33 Road maintenance after completion 34 Water use during construction phase 35 Palaeontological and archaeological findings
4 Comments received from CapeNature 41 Status of vegetation types 42 Critical Biodiversity Areas 43 Implications for proposed eastern access route alignment 44 Proposed north-south access road 45 Rights reserved
B Other IampAP comments and issues 1 Comments received from Phillips Group
11 Effect of proposed project on traffic flow and businesses in the area 2 Comments received from Afrisam
21 Late submission of comments 22 South-north access road currently under construction 23 Zoning of Farm 1139 24 Suggestions for amending proposed mitigation measures 25 Details regarding activity information
No importance should be given to the order in which the categories are presented
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
2
Table 1 Summary table of comments received on the draft BAR with responses from SLR and the project technical team as appropriate
NO ISSUE NAME DATE COMMENT RESPONSE
A AUTHORITY COMMENTS AND ISSUES
1 COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY 11 Implications of
Draft EMF for Saldanha region
Doretha Kotze 20170329 1 Your letter dated 9 March 2017 and the information contained in the Draft BAR for the proposal refer
2 The Environmental Management Framework (EMF) for the Saldanha region is currently being revisited as part of the drafting of the Greater Saldanha Regional Spatial Implementation Framework by the Western Cape Provincial Department of Environmental Affairs and Development Planning It is recommended that this proposal be aligned with the outcomes of the different studies being undertaken as part of the finalisation of the EMF since Farm 1139 is situated in an area that has been identified as a Conflict Area in terms of the Urban Conservation Zone and Industrial Development Zone For more information of the EMF process kindly contact Ryan Nel at GIBB Consulting (rnelgibbcoza or Tel 011 519 4600)
We have taken the Draft EMF into consideration in the revised BAR (refer to Section D2(c)) However the document has not yet been formally adopted Thus the implied action by the Saldanha Municipality namely to resolve the conflict in the process of updating their Spatial Development Framework has not yet been undertaken Thus the formal land use status of the property remains intended for industrial development
12 Servitudes on the property
Doretha Kotze 20170329 3 Several servitudes had been registered over Farm 1139 over the years accommodating power lines water pipelines and rights of way Two bulk water pipelines of the West Coast District Municipality traversing the property in the northwest will be crossed by the proposed new access roads Care should be taken during the construction phase to prevent negative impacts on these pipelines
The project design engineers are aware of the existence of servitudes As necessary application would be made for wayleaves from the district and local municipalities if any works occur near water or other bulk services infrastructure
2 COMMENTS FROM DEPARTMENT OF ENVIRONMENTAL AFFAIRS AND DEVELOPMENT PLANNING 21 Applicable listed
activities M Schippers 20170407 The draft BAR dated March 2017 and received by this Department
on 09 March 2017 refer 1 Applicable listed activities 11 It is noted that Activity 12 of GN No R985 is being applied for 12 Please note that the abovementioned activity is not applicable
to the proposed development since the vegetation occurring on the proposed site has not been classified as a critically endangered or endangered ecosystem in terms of the National Environmental Management Biodiversity Act of 2004 (ldquoNEMBArdquo) List of Threatened Ecosystems in Need of Protection December 2011)
13 This activity must be excluded from the application
We have noted the comments in Item 1 and have amended the revised BAR accordingly ndash see Sections A1(c) and B5(c) and (d)
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3
NO ISSUE NAME DATE COMMENT RESPONSE 22 Originally signed
and dated declarations
M Schippers 07 April17 2 The duly dated and originally signed declarations as completed by the applicant the Environmental Assessment Practitioner and the specialists who compiled the specialist reports as part of the Environmental Impact Assessment Process must be included in the BAR to be submitted to the competent authority
The originally signed declarations will be included in the final BAR which will be submitted to your Department after the conclusion of the revised BAR comment period
23 Proof of public participation
M Schippers 07 April17 3 Proof of Public Participation 31 Proof of the public participation conducted must be included in
the BAR to be submitted to the competent authority please note that the proof must include inter alia the following
311 A copy of the newspaper advertisement (ldquonewspaper clippingrdquo) that was placed indicating the name of the newspaper and date of publication
312 Photographs showing the notice displayed on site and a copy of the text displayed on the notice and
313 With regards to the written notices provided please note the following
bull If registered mail was sent a list of the registered mail sent as obtained from the post office must be provided
bull If regular mail was sent a list of the mail sent as obtained from the post office must be provided
bull If a facsimile was sent a copy of the facsimile report must be provided
bull If an electronic mail was sent a copy of the electronic mail sent and delivery reports must be provided and
bull If a ldquomail droprdquo was done a signed register of ldquomail dropsrdquo must be provided
Proof of public participation has been included in the revised BAR as follows bull Newspaper advertisement ndash Appendix F2 bull Site notice ndash Appendix F2 and bull Written notifications ndash Appendix F3 Please note that as e-mail addresses were available for all IampAPs registered on the database the formal notification letter was sent by means of electronic mail However delivery reports were not requested as this requirement is not stated in the relevant legislation nor in any guideline document on public participation of which we are aware Thus we have included a copy of the e-mail notification sent as adequate proof of distribution Hard copies of letters were delivered to representatives of commenting authorities proof of which is also included in Appendix F3
3 COMMENTS FROM SALDANHA BAY MUNICIPALITY 31 Critical
Biodiversity Areas
Mr E Mmbadi 20170410 1 Basic Assessment Report for the Proposed New Access Roads to the Saldanha Bay Industrial Development Zone dated 07 March 2017 refers
2 Even though the site is located outside the Critical Biodiversity Area it may function as a ldquostepping stonerdquo corridor that allows for animal and plant movement across the landscape Development within such sites should consider ecological connectivity of the landscape and care should be taken not to disrupt this connectivity especially for a site surrounded by Critical Biodiversity Areas
The draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest Western Cape Biodiversity Spatial Plan became available in April 2017 and was taken into consideration in the revised BAR which will be made available for a further review and comment period
32 Cumulative Mr E Mmbadi 20170410 3 The report should highlight the potential cumulative impacts of These comments have been noted As the
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
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4
NO ISSUE NAME DATE COMMENT RESPONSE impact of construction on ambient air quality
several construction activities on ambient air quality Viewing the impacts of access roads construction in isolation may only reveal limited potential impacts on the ambient air quality The report should also look at the possible release of iron ore dust trapped on vegetation into the atmosphere
construction phase of the proposed project has not yet been scheduled it cannot be assumed that it will occur while other road construction projects in the area are in progress Reference to the implications of the possible release of iron ore dust trapped on vegetation for dust generation and control during the construction phase has been incorporated into the revised BAR (see Sections F2(b) and F615) and the Construction EMP (see Section 312(b))
33 Road maintenance after completion
Mr E Mmbadi 20170410 4 In most cases after the construction work is completed the roads are handed over to local authority to maintain and service If it is envisaged to hand over the proposed access roads to Saldanha Bay Municipality (ldquoSBMrdquo) the report should acknowledge such intention Also ensure that all the requirements from SBM with regard to roads are met Please contact Manager Roads amp Stormwater (jeremyjarvissbmgovza 022 701 7049) in this regard
The design engineers have engaged with SBM regarding the future management of the roads as is indicated by the following statement in the BAR ldquoSaldanha Bay Municipality has requested that the road reserve should be registered as a separate erf which would be a portion of this propertyrdquo (see Section A2)
34 Water use during construction phase
Mr E Mmbadi 20170410 5 SBM commenced with the implementation of level 3 water restriction Please advise if there is confirmation from the municipality with regard to the supply of water to the proposed development SBM discourages the use of potable water as a dust suppression measure or for any construction purpose please indicate the developmentrsquos potential water source The use of treated effluent from the waste water treatment works could be an option Please contact Manager of Bulk Water and Sanitation (gavinwilliamasbmgovza 022 701 7047) in this regard Also consult with the Department of Water and Sanitation with regard to the water use application process
These comments regarding water conservation have been noted and relevant measures to prevent the use of potable water for dust suppression have been included in the revised BAR (see Sections F2(b) F3 and E615 of the revised BAR and Section 312(a) of the Construction EMP) Please note that the road development would only require a limited supply of water during the construction phase which the Contractor would be required to source from available resources Consultation with DWS regarding a water use application may thus not be relevant
35 Palaeontological and archaeological findings
Mr E Mmbadi 20170410 6 Please inform the Environment amp Heritage Section of the SBM on any Palaeontological and Archaeological findings for our records
This request has been included in the revised BAR (see Section F617) as well as the Construction EMP (see Section 3102(e))
4 COMMENTS FROM CAPENATURE 41 Status of
vegetation types Alana Duffell-Canham
20170410 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road 1 The proposed eastern access road passes through an area
These comments regarding the status of the vegetation types on the project site have been noted On the basis of the botanical assessment undertaken as part of the Basic Assessment process the condition of the Saldahna Limestone
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
5
NO ISSUE NAME DATE COMMENT RESPONSE covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet [been] listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6 000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
Strandveld vegetation located on the limestone ridge has indeed been described as of high botanical sensitivity in the draft BAR As to the status of the vegetation please take cognisance of DEAampDPrsquos position that only the formal classification of vegetation in terms of NEMBA is considered applicable in relation to the NEMA EIA Regulations This was in response to our indication in the draft BAR that Saldahna Flats Strandveld which is classified ldquoVulnerablerdquo should be considered ldquoEndangeredrdquo on the basis of a 2014 CapeNature status report Please refer to Comment and Response 21 above We thus have to assume that DEAampDP would consider the formal classification of Saldahna Limestone Strandveld as ldquoLeast Threatenedrdquo in terms of NEMBA as applicable
42 Critical Biodiversity Areas
Alana Duffell-Canham
20170410 2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent land cover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truth where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data
A mentioned in Response 31 above the draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest WCBSP which became available in April 2017 has been taken into consideration in the revised BAR Our observation regarding the mapping of the CBAs is that this covers a large area on the specific property and extends notably further northwards than the intact vegetation on the limestone ridge According to the ground-truthing of the botanical
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
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Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
PUBLIC PARTICIPATION PROCESS
PROPOSED NEW ACCESS ROAD TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE OF A PUBLIC PARTICIPATION PROCESS IN TERMS OF THE NEMA EIA REGULATIONS 2014
APPLICANT SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (SBIDZ) LICENCING COMPANY (ldquoLICOrdquo)
CONSULTING ENGINEER SMEC SOUTH AFRICA (PTY) LTD (ldquoSMECrdquo)
ENVIRONMENTAL ASSESSMENT PRACTITIONER SLR CONSULTING (SOUTH AFRICA) (PTY) LTD (ldquoSLRrdquo)
DESCRIPTION AND LOCATION LICO IS PROPOSING THE FOLLOWING ADDITIONS TO THE ROAD NETWORK FOR THE SBIDZ AREA bull CONSTRUCTION OF A NEW EAST-WEST ACCESS ROAD AND NEW INTERSECTION ON MINOR ROAD (OP) 7645 IN ORDER TO PROVIDE ACCESS TO THE
SBIDZ AREA TO THE NORTH OF MR559 THIS ROAD WOULD ALSO PROVIDE ACCESS TO THE NEW AFRISAM CEMENT PLANT AND bull EXTENSION OF THE SOUTH-NORTH ACCESS ROAD ALONG THE SBIDZ EASTERN BOUNDARY TO PROVIDE AN ALTERNATIVE ACCESS TO DUFERCO
APPLICATION FOR ENVIRONMENTAL AUTHORISATION TO UNDERTAKE THE FOLLOWING LISTED ACTIVITIES IN TERMS OF GOVERNMENT NOTICE R983 (LISTING NOTICE 1) 24(ii) AND IN TERMS OF GOVERNMENT NOTICE R985 (LISTING NOTICE 3) 12(a)
OPPORTUNITY TO PARTICIPATE NOTICE IS HEREBY GIVEN THAT A BASIC ASSESSMENT PROCESS IS BEING UNDERTAKEN FOR THIS PROPOSED PROJECT IF YOU ANDOR YOUR ORGANISATION WISH TO REGISTER ON THE PROJECT DATABASE REQUIRE ADDITIONAL INFORMATION ANDOR WISH TO RAISE ANY ISSUES OR CONCERNS REGARDING THE PROPOSED PROJECT PLEASE CONTACT ENA DE VILLIERS OF SLR AT THE BELOW CONTACT DETAILS
SLR CONTACT DETAILS UNIT 39 ROELAND SQUARE 30 DRURY LANE CAPE TOWN 8000 TEL (021) 461 11189 FAX (021) 461 1120 EMAIL edevilliersslrconsultingcom
SITE NOTICE PHOTOGRAPHS
Site notice placed at the eastern end of the proposed new eastern access road along the road reserve boundary of Minor Road 7645 (Port Road)
Site notice placed at the southern end of the proposed new north-south road western end of the proposed new eastern access road at the eastern entrance to the Saldanha Bay Industrial Development Zone
NOTICE OF PUBLIC PARTICIPATION PROCESS
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Notice is hereby given of a public participation process in terms of the National Environmental Management Act (No 107 of 1998) (NEMA) and Environmental Impact Assessment (EIA) Regulations 2014
Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) Environmental Assessment Practitioner SLR Consulting (South Africa) (Pty) Ltd (SLR)
Project description The SBIDZ-LC is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) namely bull A new eastern access road and new intersection on Minor Road 7645 (Port Road) to
provide access to the SBIDZ area north of Main Road 559 (Camp Road) as well as to a proposed new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
Application for Environmental Authorisation (EA) to undertake the following activities The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
SLR Consulting Contact Details Unit 39 Roeland Square 30 Drury Lane CAPE TOWN 8001 Tel (021) 461 1118 Fax (021) 461 1120 E-mail edevilliersslrconsultingcom Website wwwslrconsultingcomza Date of advertisement 9 March 2017
SMEC03ARStakeholder docsAdvert_Notice Advert ndash new access roads (March 2017)
22 Weslander GEKLASSIFISEERD CLASSIFIEDS 9 Maart 2017
DIRECTORATE ENGINEERING amp PLANNING SERVICES
DIRECTORATE FINANCE
DEPARTMENT SOLID WASTE
DEPARTMENT SUPPLY CHAIN MANAGEMENT
DEPARTMENT REVENUE
Superintendent Solid Waste Management Landfills
Senior Bid Administrator
Meter Reader
Applicants must be in possession of a National Diploma in Civil Engineering with Solid WasteManagement 4 as an additional subject bull 2 yearsrsquo relevant experience within Civil Engineering of which 1year should be on a supervisory level bull Computer Literacy bull Code B driverrsquos License bull Good communicationskills in two of the three official languages of the Western Cape
Duties will entail Perform administrative functions bull Communicate information to community memberswith regards to landfill sites and transfer stations bull Manage landfill sites and transfer stations bull Monitor toxicwaste as per the relevant regulations bull Manage the staff discipline and safety within the section bull Collectionof borehole water samples twice a year bull Follow-up on reported incidents bull Manage assets (equipment andmachinery) within the section bull Tender and contract administration
Applicants must be in possession of a Grade 12 bull 4 yearsrsquo relevant Supply Chain Managementexperience bull Computer literacy bull Code B driverrsquos license will serve as a recommendation bull Goodcommunication skills in two of the three official languages of the Western Cape
Duties will entail Administer Bid specifications process bull Administer the opening and registration oftenders bull Ensure that contracts do not lapse in terms of the validity period bull Administer the performance ofvendorsbidders above R200 000 bull Provide Human Resource support bull Report any irregularities to theSupply Chain Manager bull Internal and external communication
Salary Scale T11 (R220 16214 ndash R285 76824 p a)Enquiries Ms H Meeding Tel (022) 701 6916
Applicants must be in possession of a Grade 12 bull Code B driverrsquos license bull Good numerical skillsbull Physically fit and healthy bull Good communication skills in two of the three official languages of the WesternCape
Duties will entail The accurate reading and recording of meter readings to ensure that readings are beingprocessed and that all customers are charged with correct amounts bull Noting and reporting of complaints onfaulty water and electricity meters bull Update of route cards to ensure that new developments and areas arerecorded on the financial- and meter reading system
Salary scale T6 (R108 07992 ndash R140 29232 pa)Enquiries Mr H Smith Tel (022) 701 7011
Closing Date 23 March 2017 at 1200
NOTES TO APPLICANT
bull Thank you for your interest in seeking employment with usbull All applications should be accompanied by a completed application form (obtainable from our
Human Resource office or website wwwsbmgovza) clearly reflecting the name of the positionapplying for a comprehensive CV a certified copy of your ID driverrsquos license and educationalqualifications
bull No original documents attached to the application will be safe keptreturnedbull Applications without afore - mentioned will not be consideredbull Applications should be forwarded to Human Resource Services Private Bag X12 Vredenburg
7380 or via email to munsbmgovzabull ApplicationsSupporting documents larger that 2MB sent via email are not accommodatedbull For the implementation of the Employment Act candidates are encouraged to indicate their race
gender and disabilitybull No late applications will be consideredbull Further communication will be limited to shortlisted candidates If you have not received a
response within 3 (three) months of the closing date please consider your applicationunsuccessful
bull All appointments are subject to a medical assessment criminal record and reference checks fromprevious and current employer(s)
bull The Council beholds the right to make an appointment
Serve Grow and SucceedTogether
Saldanha Bay Municipality is a high profile municipality that takes care of its people to deliver thehighest quality of service to its residents and visitors We are also committed to the goals of ourEmployment Equity Plan If you are competent and committed and would like to work in aprofessional environment you are welcome to apply for the following positions on our staffestablishment
T (022) 701 7000 F (022) 715 1518 munsbmgovza wwwsbmgovzabull bull bull
00000000-DW090317
NOTICE OF PUBLIC PARTICIPATION PROCESS
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THESALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SMEC03AR 022017 DEAampDP REF NO 16331F417301117
Notice is hereby given of a public participation process in terms of the National Environmental ManagementAct (No 107 of 1998) (NEMA) and Environmental ImpactAssessment (EIA) Regulations 2014
Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC)EnvironmentalAssessment Practitioner SLR Consulting (SouthAfrica) (Pty) Ltd (SLR)
Project description The SBIDZ-LC is proposing to develop two new access roads to the Saldanha BayIndustrial Development Zone (SBIDZ) namelybull Anew eastern access road and new intersection on Minor Road 7645 (Port Road) to provide access to
the SBIDZ area north of Main Road 559 (Camp Road) as well as to a proposed new Afrisam cementplant and
bull Anew north-south access road along the SBIDZ eastern boundary to provide an alternative access tothe Duferco steel processing plant
Application for EnvironmentalAuthorisation (EA) to undertake the following activitiesThe proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in termsof NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (ListingNotice 3)Activities 12 and 18ABasicAssessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor yourorganisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on theBasic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-daycomment period from 10 March to 10 April 2017 (including an additional day to cover the intervening publicholiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Anycomment should be submitted by no later than 10April 2017
SLR Consulting Contact DetailsUnit 39 Roeland Square 30 Drury LaneCAPE TOWN 8001Tel (021) 461 1118 Fax (021) 461 1120E-mail edevilliersslrconsultingcomWebsite wwwslrconsultingcomza Date of advertisement 9 March 2017
0000000-DW090317
Serve Grow and SucceedTogether
ApplicantAansoeker amp OwnerEienaar CK RUMBOLL amp PARTNERS
TEL 022-4871661 ndash Zanellerumbollcoza
Reference numberVerwysingsnommer NR 12319
Property DescriptionEiendomsbeskrywing FARMPLAAS DE KLIP NR 12319
Physical AddressFisiese adres VREDENBURG
Notice is hereby given in terms of Sections 45 amp 46 of the
Saldanha Bay Municipal Land Use Planning By-law that
Saldanha Bay Municipality is considering the following
i) a Consent Use (special usage) in terms Section 15(2)(o) in
order to establish 4 additional residential units on Portion
19 of the Farm De Klip No 123
Details are available for scrutiny at the Municipal Managerrsquos
office during weekdays between 0830 and 1630 contact
the Town Planning Department at 17 Main Street
Vredenburg Any written comments may be addressed to
the Municipal Manager at Private Bag x 12 17 Main Street
Vredenburg doreendunnsbmgovza on or before 10
April 2017 quoting your name address or contact details
interest in the application and reasons for comments
Telephonic enquiries can be made to Bradley Rubidge at 022
- 701 7080 The Municipality may refuse to accept comment
received after the closing date Any person who cannot
write will be assisted by a Municipal official by transcribing
their comments Commentsobjections will be forwarded to
the applicant for hisher response
N1817 (09-03-2017)
K e n n i s w o r d h i e r m e e g e g e e i n g e v o l g e
Artikels 45 amp 46 van die Saldanhabaai Munisipale
Grondgebruikbeplanningsverordening dat Saldanhabaai
M u n i s i p a l i t e i t d i e v o l g e n d e o o r w e e g
i) lsquon Vergunningsgebruik (spesiale gebruik) in terme Artikel
15(2)(a) ten einde 4 addisionele residensieumlle eenhede op
Gedeelte 19 van die Plaas De Klip Nr 123 te
akkommodeer
Nadere besonderhede lecirc ter insae by die Munisipale
Bestuurder se kantoor gedurende weeksdae tussen 0830
and 1630 kontak die Departement Stadsbeplanning by
Hoofstraat 17 Vredenburg Enige skriftelike kommentaar
kan gerig word aan die Munisipale Bestuurder Privaatsak x
12 Hoofstraat 17 Vredenburg doreendunnsbmgovza
op of voor 10 April 2017 met vermelding van u naam adres
of kontakbesonderhede belangstelling in die aansoek en
redes vir kommentaar Telefoniese navrae kan gerig word
aan Bradley Rubidge by 022 - 701 7080 Die Munisipaliteit
mag weier om kommentaar te aanvaar wat na die
sluitingsdatum ontvang word Enige persoon wat nie kan
skryf sal bygestaan word deur n munisipale amptenaar vir
transkribering van hul kommentaar Besware sal aan die
applicant gestuur word vir syhaar repliek
K1817 (09-03-2017)
T (022) 701 7000 F (022) 715 1518 munsbmgovza wwwsbmgovzabull bull bull
0000000-DW090317
Madeleyn Ingelyf prokureurs vanVredenburg benodig die dienste van n
litigasie invorderings tikster
Die geskikte kandidaat moetrekenaarvaardig en tweetalig wees en
sal toepaslike ondervinding n sterkaanbeveling wees
Stuur asseblief u CV per e pos aanniekiemadeleyncoza
of lewer per hand af aanMadeleyn Ingelyf
Hoofstraat 6 Vredenburg
LITIGASIE
TIKSTER
000000-DW090317
BESTUURDER VIR
HOSPITALITEITSBEDRYF
Vorige ondervinding n vereisteGoeie menseverhoudings
Uitstekende kommunikasie vermoeumlnsMoet onder druk kan werk asook lang ure
Verkieslik manlik
Kontak 073 070 8414
Sluitingsdatum 16 Maart 2017
000000-DW090317
BRAAIKUIKEN
PLAASBESTUURDER(WORCESTER AREA)
bull Algemene bestuur van braaikuiken plaasbull Beheer en kontrole oor personeelbull Opdragte van bestuur aan personeel oordra en
toesien dat werk effektief uitgevoer wordbull Betroubaar eerlik en hardwerkendbull Moet onder druk kan funksioneerbull Moet bereid wees om oortyd en naweke te werkbull Bestuurderslisensie n vereistebull Geen ondervinding nodig
Gratis behuising op plaas ingesluitSluitingsdatum 20 Maart 2017
E-pos soverbycompnetcozaof faks na 086 4306 721
Indien geen reaksie teen 25 Maart 2017
was u aansoek onsuksesvol
0000000-DW090317
TIPPLER 3 PROJECT
All Local Building Contractors areencouraged to register their
companies on the Group Five Thulanda JV Vendor databaseThe database will be used to
Registration places your company in a better position tobe considered for various sub-contracts that need to beawarded for the Tippler 3 and other Group Five Thulanda Projects in the region
To register on our Supplier Development (SD)Database all local companies are required to completea Vendors Take on Form and to submit the dulycompleted form together with necessary documentrequirements to our SD Officer Nosi Hlulelo byemailing her at nosihlulelothulandacoza
MAKING A DIFFERENCE
000000-DW090317
APPENDIX F3
PROOF OF BAR NOTIFICATION
From Mandy KulaTo Mandy KulaBcc brianwichtcoza yolandaswartmwebcoza adminbluebaylodgecoza admin3bluebaylodgecoza aduffell-canhamcapenaturecoza
Subject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENT
Date 09 March 2017 012626 PMAttachments Exec Summary - Basic Assessment Report (9Mar17)pdf
Let ndash BAR Notification (9Mar17)pdfimage4981fbPNG
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposedproject for a 30-day review and comment period from 10 March to 10 April 2017 (including one additional day to coverthe intervening public holiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
SLR Consulting (South Africa) (Pty) Ltd Page iv
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
Proposed north-south access road
Proposed eastern access road
Trunk Road 85
Main Road 559 Minor Road 7645
Saldanha Bay Industrial Development Zone
Duferco
Future Afrisam cement plant
Proposed north-south access road
Proposed eastern access road
From Ena de VilliersTo Ena de VilliersBcc gerritsmithsbmgovza malcolmwatterswesterncapegovza corvdwelsenburgcom aduffell-canhamcapenaturecoza
melaneseschipperswesterncapegovzaSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
REMINDER OF CLOSURE OF BAR COMMENT PERIODDate 04 April 2017 110142 AMAttachments image6c48afPNG
Dear SirsMadams We would like to take this opportunity to remind you of the closure of the comment period for the above-mentioned projecton 10 April 2017 Kindly submit your comments to Mandy Kula (mkulaslrconsultingcom) or myself at the contact particularsbelow You are welcome to contact us regarding any enquiries Thanks and best regardsEna
Ena de VilliersEnvironmental ConsultantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
APPENDIX F4
DRAFT BAR COMMENTS AND RESPONSES REPORT
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
1
DRAFT BASIC ASSESSMENT REPORT (BAR)
COMMENTS AND RESPONSES REPORT
Written submissions were received from the following commenting authorities and other Interested and Affected Parties (IampAPs) during the BAR comment period
SUBMITTED BY METHOD AND DATE Authorities 1 West Coast District Municipality ndash Ms Doretha Kotze Email - 29 March 2017
2 Department of Environmental Affairs and Development Planning ndash Ms M Schippers Fax - 07 April 2017
3 Saldanha Bay Municipality ndash Mr E Mmbadi Email - 10 April 2017
4 CapeNature ndash Ms Alana Duffell-Canham Email - 11 April 2017
Other IampAPs 1 Phillips Group ndash Mr Jan Phillips Email - 10 March 2017
Copies of the written comments are attached as Attachment A to this report arranged according to the order indicated in the table above The comments received are presented in Table 1 below and have been categorised as follows A Authority comments and issues 1 Comments received from West Coast District Municipality
11 Implications of Draft EMF for Saldanha region 12 Servitudes on the property
2 Comments received from Department of Environmental Affairs and Development Planning 21 Applicable listed Activities 22 Originally signed and dated declarations 23 Proof of Public Participation
3 Comments received from Saldanha Bay Municipality 31 Critical Biodiversity Areas 32 Cumulative impact of construction on ambient air quality 33 Road maintenance after completion 34 Water use during construction phase 35 Palaeontological and archaeological findings
4 Comments received from CapeNature 41 Status of vegetation types 42 Critical Biodiversity Areas 43 Implications for proposed eastern access route alignment 44 Proposed north-south access road 45 Rights reserved
B Other IampAP comments and issues 1 Comments received from Phillips Group
11 Effect of proposed project on traffic flow and businesses in the area 2 Comments received from Afrisam
21 Late submission of comments 22 South-north access road currently under construction 23 Zoning of Farm 1139 24 Suggestions for amending proposed mitigation measures 25 Details regarding activity information
No importance should be given to the order in which the categories are presented
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
2
Table 1 Summary table of comments received on the draft BAR with responses from SLR and the project technical team as appropriate
NO ISSUE NAME DATE COMMENT RESPONSE
A AUTHORITY COMMENTS AND ISSUES
1 COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY 11 Implications of
Draft EMF for Saldanha region
Doretha Kotze 20170329 1 Your letter dated 9 March 2017 and the information contained in the Draft BAR for the proposal refer
2 The Environmental Management Framework (EMF) for the Saldanha region is currently being revisited as part of the drafting of the Greater Saldanha Regional Spatial Implementation Framework by the Western Cape Provincial Department of Environmental Affairs and Development Planning It is recommended that this proposal be aligned with the outcomes of the different studies being undertaken as part of the finalisation of the EMF since Farm 1139 is situated in an area that has been identified as a Conflict Area in terms of the Urban Conservation Zone and Industrial Development Zone For more information of the EMF process kindly contact Ryan Nel at GIBB Consulting (rnelgibbcoza or Tel 011 519 4600)
We have taken the Draft EMF into consideration in the revised BAR (refer to Section D2(c)) However the document has not yet been formally adopted Thus the implied action by the Saldanha Municipality namely to resolve the conflict in the process of updating their Spatial Development Framework has not yet been undertaken Thus the formal land use status of the property remains intended for industrial development
12 Servitudes on the property
Doretha Kotze 20170329 3 Several servitudes had been registered over Farm 1139 over the years accommodating power lines water pipelines and rights of way Two bulk water pipelines of the West Coast District Municipality traversing the property in the northwest will be crossed by the proposed new access roads Care should be taken during the construction phase to prevent negative impacts on these pipelines
The project design engineers are aware of the existence of servitudes As necessary application would be made for wayleaves from the district and local municipalities if any works occur near water or other bulk services infrastructure
2 COMMENTS FROM DEPARTMENT OF ENVIRONMENTAL AFFAIRS AND DEVELOPMENT PLANNING 21 Applicable listed
activities M Schippers 20170407 The draft BAR dated March 2017 and received by this Department
on 09 March 2017 refer 1 Applicable listed activities 11 It is noted that Activity 12 of GN No R985 is being applied for 12 Please note that the abovementioned activity is not applicable
to the proposed development since the vegetation occurring on the proposed site has not been classified as a critically endangered or endangered ecosystem in terms of the National Environmental Management Biodiversity Act of 2004 (ldquoNEMBArdquo) List of Threatened Ecosystems in Need of Protection December 2011)
13 This activity must be excluded from the application
We have noted the comments in Item 1 and have amended the revised BAR accordingly ndash see Sections A1(c) and B5(c) and (d)
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3
NO ISSUE NAME DATE COMMENT RESPONSE 22 Originally signed
and dated declarations
M Schippers 07 April17 2 The duly dated and originally signed declarations as completed by the applicant the Environmental Assessment Practitioner and the specialists who compiled the specialist reports as part of the Environmental Impact Assessment Process must be included in the BAR to be submitted to the competent authority
The originally signed declarations will be included in the final BAR which will be submitted to your Department after the conclusion of the revised BAR comment period
23 Proof of public participation
M Schippers 07 April17 3 Proof of Public Participation 31 Proof of the public participation conducted must be included in
the BAR to be submitted to the competent authority please note that the proof must include inter alia the following
311 A copy of the newspaper advertisement (ldquonewspaper clippingrdquo) that was placed indicating the name of the newspaper and date of publication
312 Photographs showing the notice displayed on site and a copy of the text displayed on the notice and
313 With regards to the written notices provided please note the following
bull If registered mail was sent a list of the registered mail sent as obtained from the post office must be provided
bull If regular mail was sent a list of the mail sent as obtained from the post office must be provided
bull If a facsimile was sent a copy of the facsimile report must be provided
bull If an electronic mail was sent a copy of the electronic mail sent and delivery reports must be provided and
bull If a ldquomail droprdquo was done a signed register of ldquomail dropsrdquo must be provided
Proof of public participation has been included in the revised BAR as follows bull Newspaper advertisement ndash Appendix F2 bull Site notice ndash Appendix F2 and bull Written notifications ndash Appendix F3 Please note that as e-mail addresses were available for all IampAPs registered on the database the formal notification letter was sent by means of electronic mail However delivery reports were not requested as this requirement is not stated in the relevant legislation nor in any guideline document on public participation of which we are aware Thus we have included a copy of the e-mail notification sent as adequate proof of distribution Hard copies of letters were delivered to representatives of commenting authorities proof of which is also included in Appendix F3
3 COMMENTS FROM SALDANHA BAY MUNICIPALITY 31 Critical
Biodiversity Areas
Mr E Mmbadi 20170410 1 Basic Assessment Report for the Proposed New Access Roads to the Saldanha Bay Industrial Development Zone dated 07 March 2017 refers
2 Even though the site is located outside the Critical Biodiversity Area it may function as a ldquostepping stonerdquo corridor that allows for animal and plant movement across the landscape Development within such sites should consider ecological connectivity of the landscape and care should be taken not to disrupt this connectivity especially for a site surrounded by Critical Biodiversity Areas
The draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest Western Cape Biodiversity Spatial Plan became available in April 2017 and was taken into consideration in the revised BAR which will be made available for a further review and comment period
32 Cumulative Mr E Mmbadi 20170410 3 The report should highlight the potential cumulative impacts of These comments have been noted As the
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NO ISSUE NAME DATE COMMENT RESPONSE impact of construction on ambient air quality
several construction activities on ambient air quality Viewing the impacts of access roads construction in isolation may only reveal limited potential impacts on the ambient air quality The report should also look at the possible release of iron ore dust trapped on vegetation into the atmosphere
construction phase of the proposed project has not yet been scheduled it cannot be assumed that it will occur while other road construction projects in the area are in progress Reference to the implications of the possible release of iron ore dust trapped on vegetation for dust generation and control during the construction phase has been incorporated into the revised BAR (see Sections F2(b) and F615) and the Construction EMP (see Section 312(b))
33 Road maintenance after completion
Mr E Mmbadi 20170410 4 In most cases after the construction work is completed the roads are handed over to local authority to maintain and service If it is envisaged to hand over the proposed access roads to Saldanha Bay Municipality (ldquoSBMrdquo) the report should acknowledge such intention Also ensure that all the requirements from SBM with regard to roads are met Please contact Manager Roads amp Stormwater (jeremyjarvissbmgovza 022 701 7049) in this regard
The design engineers have engaged with SBM regarding the future management of the roads as is indicated by the following statement in the BAR ldquoSaldanha Bay Municipality has requested that the road reserve should be registered as a separate erf which would be a portion of this propertyrdquo (see Section A2)
34 Water use during construction phase
Mr E Mmbadi 20170410 5 SBM commenced with the implementation of level 3 water restriction Please advise if there is confirmation from the municipality with regard to the supply of water to the proposed development SBM discourages the use of potable water as a dust suppression measure or for any construction purpose please indicate the developmentrsquos potential water source The use of treated effluent from the waste water treatment works could be an option Please contact Manager of Bulk Water and Sanitation (gavinwilliamasbmgovza 022 701 7047) in this regard Also consult with the Department of Water and Sanitation with regard to the water use application process
These comments regarding water conservation have been noted and relevant measures to prevent the use of potable water for dust suppression have been included in the revised BAR (see Sections F2(b) F3 and E615 of the revised BAR and Section 312(a) of the Construction EMP) Please note that the road development would only require a limited supply of water during the construction phase which the Contractor would be required to source from available resources Consultation with DWS regarding a water use application may thus not be relevant
35 Palaeontological and archaeological findings
Mr E Mmbadi 20170410 6 Please inform the Environment amp Heritage Section of the SBM on any Palaeontological and Archaeological findings for our records
This request has been included in the revised BAR (see Section F617) as well as the Construction EMP (see Section 3102(e))
4 COMMENTS FROM CAPENATURE 41 Status of
vegetation types Alana Duffell-Canham
20170410 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road 1 The proposed eastern access road passes through an area
These comments regarding the status of the vegetation types on the project site have been noted On the basis of the botanical assessment undertaken as part of the Basic Assessment process the condition of the Saldahna Limestone
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
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5
NO ISSUE NAME DATE COMMENT RESPONSE covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet [been] listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6 000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
Strandveld vegetation located on the limestone ridge has indeed been described as of high botanical sensitivity in the draft BAR As to the status of the vegetation please take cognisance of DEAampDPrsquos position that only the formal classification of vegetation in terms of NEMBA is considered applicable in relation to the NEMA EIA Regulations This was in response to our indication in the draft BAR that Saldahna Flats Strandveld which is classified ldquoVulnerablerdquo should be considered ldquoEndangeredrdquo on the basis of a 2014 CapeNature status report Please refer to Comment and Response 21 above We thus have to assume that DEAampDP would consider the formal classification of Saldahna Limestone Strandveld as ldquoLeast Threatenedrdquo in terms of NEMBA as applicable
42 Critical Biodiversity Areas
Alana Duffell-Canham
20170410 2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent land cover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truth where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data
A mentioned in Response 31 above the draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest WCBSP which became available in April 2017 has been taken into consideration in the revised BAR Our observation regarding the mapping of the CBAs is that this covers a large area on the specific property and extends notably further northwards than the intact vegetation on the limestone ridge According to the ground-truthing of the botanical
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
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8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
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SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
SITE NOTICE PHOTOGRAPHS
Site notice placed at the eastern end of the proposed new eastern access road along the road reserve boundary of Minor Road 7645 (Port Road)
Site notice placed at the southern end of the proposed new north-south road western end of the proposed new eastern access road at the eastern entrance to the Saldanha Bay Industrial Development Zone
NOTICE OF PUBLIC PARTICIPATION PROCESS
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Notice is hereby given of a public participation process in terms of the National Environmental Management Act (No 107 of 1998) (NEMA) and Environmental Impact Assessment (EIA) Regulations 2014
Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) Environmental Assessment Practitioner SLR Consulting (South Africa) (Pty) Ltd (SLR)
Project description The SBIDZ-LC is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) namely bull A new eastern access road and new intersection on Minor Road 7645 (Port Road) to
provide access to the SBIDZ area north of Main Road 559 (Camp Road) as well as to a proposed new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
Application for Environmental Authorisation (EA) to undertake the following activities The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
SLR Consulting Contact Details Unit 39 Roeland Square 30 Drury Lane CAPE TOWN 8001 Tel (021) 461 1118 Fax (021) 461 1120 E-mail edevilliersslrconsultingcom Website wwwslrconsultingcomza Date of advertisement 9 March 2017
SMEC03ARStakeholder docsAdvert_Notice Advert ndash new access roads (March 2017)
22 Weslander GEKLASSIFISEERD CLASSIFIEDS 9 Maart 2017
DIRECTORATE ENGINEERING amp PLANNING SERVICES
DIRECTORATE FINANCE
DEPARTMENT SOLID WASTE
DEPARTMENT SUPPLY CHAIN MANAGEMENT
DEPARTMENT REVENUE
Superintendent Solid Waste Management Landfills
Senior Bid Administrator
Meter Reader
Applicants must be in possession of a National Diploma in Civil Engineering with Solid WasteManagement 4 as an additional subject bull 2 yearsrsquo relevant experience within Civil Engineering of which 1year should be on a supervisory level bull Computer Literacy bull Code B driverrsquos License bull Good communicationskills in two of the three official languages of the Western Cape
Duties will entail Perform administrative functions bull Communicate information to community memberswith regards to landfill sites and transfer stations bull Manage landfill sites and transfer stations bull Monitor toxicwaste as per the relevant regulations bull Manage the staff discipline and safety within the section bull Collectionof borehole water samples twice a year bull Follow-up on reported incidents bull Manage assets (equipment andmachinery) within the section bull Tender and contract administration
Applicants must be in possession of a Grade 12 bull 4 yearsrsquo relevant Supply Chain Managementexperience bull Computer literacy bull Code B driverrsquos license will serve as a recommendation bull Goodcommunication skills in two of the three official languages of the Western Cape
Duties will entail Administer Bid specifications process bull Administer the opening and registration oftenders bull Ensure that contracts do not lapse in terms of the validity period bull Administer the performance ofvendorsbidders above R200 000 bull Provide Human Resource support bull Report any irregularities to theSupply Chain Manager bull Internal and external communication
Salary Scale T11 (R220 16214 ndash R285 76824 p a)Enquiries Ms H Meeding Tel (022) 701 6916
Applicants must be in possession of a Grade 12 bull Code B driverrsquos license bull Good numerical skillsbull Physically fit and healthy bull Good communication skills in two of the three official languages of the WesternCape
Duties will entail The accurate reading and recording of meter readings to ensure that readings are beingprocessed and that all customers are charged with correct amounts bull Noting and reporting of complaints onfaulty water and electricity meters bull Update of route cards to ensure that new developments and areas arerecorded on the financial- and meter reading system
Salary scale T6 (R108 07992 ndash R140 29232 pa)Enquiries Mr H Smith Tel (022) 701 7011
Closing Date 23 March 2017 at 1200
NOTES TO APPLICANT
bull Thank you for your interest in seeking employment with usbull All applications should be accompanied by a completed application form (obtainable from our
Human Resource office or website wwwsbmgovza) clearly reflecting the name of the positionapplying for a comprehensive CV a certified copy of your ID driverrsquos license and educationalqualifications
bull No original documents attached to the application will be safe keptreturnedbull Applications without afore - mentioned will not be consideredbull Applications should be forwarded to Human Resource Services Private Bag X12 Vredenburg
7380 or via email to munsbmgovzabull ApplicationsSupporting documents larger that 2MB sent via email are not accommodatedbull For the implementation of the Employment Act candidates are encouraged to indicate their race
gender and disabilitybull No late applications will be consideredbull Further communication will be limited to shortlisted candidates If you have not received a
response within 3 (three) months of the closing date please consider your applicationunsuccessful
bull All appointments are subject to a medical assessment criminal record and reference checks fromprevious and current employer(s)
bull The Council beholds the right to make an appointment
Serve Grow and SucceedTogether
Saldanha Bay Municipality is a high profile municipality that takes care of its people to deliver thehighest quality of service to its residents and visitors We are also committed to the goals of ourEmployment Equity Plan If you are competent and committed and would like to work in aprofessional environment you are welcome to apply for the following positions on our staffestablishment
T (022) 701 7000 F (022) 715 1518 munsbmgovza wwwsbmgovzabull bull bull
00000000-DW090317
NOTICE OF PUBLIC PARTICIPATION PROCESS
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THESALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SMEC03AR 022017 DEAampDP REF NO 16331F417301117
Notice is hereby given of a public participation process in terms of the National Environmental ManagementAct (No 107 of 1998) (NEMA) and Environmental ImpactAssessment (EIA) Regulations 2014
Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC)EnvironmentalAssessment Practitioner SLR Consulting (SouthAfrica) (Pty) Ltd (SLR)
Project description The SBIDZ-LC is proposing to develop two new access roads to the Saldanha BayIndustrial Development Zone (SBIDZ) namelybull Anew eastern access road and new intersection on Minor Road 7645 (Port Road) to provide access to
the SBIDZ area north of Main Road 559 (Camp Road) as well as to a proposed new Afrisam cementplant and
bull Anew north-south access road along the SBIDZ eastern boundary to provide an alternative access tothe Duferco steel processing plant
Application for EnvironmentalAuthorisation (EA) to undertake the following activitiesThe proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in termsof NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (ListingNotice 3)Activities 12 and 18ABasicAssessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor yourorganisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on theBasic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-daycomment period from 10 March to 10 April 2017 (including an additional day to cover the intervening publicholiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Anycomment should be submitted by no later than 10April 2017
SLR Consulting Contact DetailsUnit 39 Roeland Square 30 Drury LaneCAPE TOWN 8001Tel (021) 461 1118 Fax (021) 461 1120E-mail edevilliersslrconsultingcomWebsite wwwslrconsultingcomza Date of advertisement 9 March 2017
0000000-DW090317
Serve Grow and SucceedTogether
ApplicantAansoeker amp OwnerEienaar CK RUMBOLL amp PARTNERS
TEL 022-4871661 ndash Zanellerumbollcoza
Reference numberVerwysingsnommer NR 12319
Property DescriptionEiendomsbeskrywing FARMPLAAS DE KLIP NR 12319
Physical AddressFisiese adres VREDENBURG
Notice is hereby given in terms of Sections 45 amp 46 of the
Saldanha Bay Municipal Land Use Planning By-law that
Saldanha Bay Municipality is considering the following
i) a Consent Use (special usage) in terms Section 15(2)(o) in
order to establish 4 additional residential units on Portion
19 of the Farm De Klip No 123
Details are available for scrutiny at the Municipal Managerrsquos
office during weekdays between 0830 and 1630 contact
the Town Planning Department at 17 Main Street
Vredenburg Any written comments may be addressed to
the Municipal Manager at Private Bag x 12 17 Main Street
Vredenburg doreendunnsbmgovza on or before 10
April 2017 quoting your name address or contact details
interest in the application and reasons for comments
Telephonic enquiries can be made to Bradley Rubidge at 022
- 701 7080 The Municipality may refuse to accept comment
received after the closing date Any person who cannot
write will be assisted by a Municipal official by transcribing
their comments Commentsobjections will be forwarded to
the applicant for hisher response
N1817 (09-03-2017)
K e n n i s w o r d h i e r m e e g e g e e i n g e v o l g e
Artikels 45 amp 46 van die Saldanhabaai Munisipale
Grondgebruikbeplanningsverordening dat Saldanhabaai
M u n i s i p a l i t e i t d i e v o l g e n d e o o r w e e g
i) lsquon Vergunningsgebruik (spesiale gebruik) in terme Artikel
15(2)(a) ten einde 4 addisionele residensieumlle eenhede op
Gedeelte 19 van die Plaas De Klip Nr 123 te
akkommodeer
Nadere besonderhede lecirc ter insae by die Munisipale
Bestuurder se kantoor gedurende weeksdae tussen 0830
and 1630 kontak die Departement Stadsbeplanning by
Hoofstraat 17 Vredenburg Enige skriftelike kommentaar
kan gerig word aan die Munisipale Bestuurder Privaatsak x
12 Hoofstraat 17 Vredenburg doreendunnsbmgovza
op of voor 10 April 2017 met vermelding van u naam adres
of kontakbesonderhede belangstelling in die aansoek en
redes vir kommentaar Telefoniese navrae kan gerig word
aan Bradley Rubidge by 022 - 701 7080 Die Munisipaliteit
mag weier om kommentaar te aanvaar wat na die
sluitingsdatum ontvang word Enige persoon wat nie kan
skryf sal bygestaan word deur n munisipale amptenaar vir
transkribering van hul kommentaar Besware sal aan die
applicant gestuur word vir syhaar repliek
K1817 (09-03-2017)
T (022) 701 7000 F (022) 715 1518 munsbmgovza wwwsbmgovzabull bull bull
0000000-DW090317
Madeleyn Ingelyf prokureurs vanVredenburg benodig die dienste van n
litigasie invorderings tikster
Die geskikte kandidaat moetrekenaarvaardig en tweetalig wees en
sal toepaslike ondervinding n sterkaanbeveling wees
Stuur asseblief u CV per e pos aanniekiemadeleyncoza
of lewer per hand af aanMadeleyn Ingelyf
Hoofstraat 6 Vredenburg
LITIGASIE
TIKSTER
000000-DW090317
BESTUURDER VIR
HOSPITALITEITSBEDRYF
Vorige ondervinding n vereisteGoeie menseverhoudings
Uitstekende kommunikasie vermoeumlnsMoet onder druk kan werk asook lang ure
Verkieslik manlik
Kontak 073 070 8414
Sluitingsdatum 16 Maart 2017
000000-DW090317
BRAAIKUIKEN
PLAASBESTUURDER(WORCESTER AREA)
bull Algemene bestuur van braaikuiken plaasbull Beheer en kontrole oor personeelbull Opdragte van bestuur aan personeel oordra en
toesien dat werk effektief uitgevoer wordbull Betroubaar eerlik en hardwerkendbull Moet onder druk kan funksioneerbull Moet bereid wees om oortyd en naweke te werkbull Bestuurderslisensie n vereistebull Geen ondervinding nodig
Gratis behuising op plaas ingesluitSluitingsdatum 20 Maart 2017
E-pos soverbycompnetcozaof faks na 086 4306 721
Indien geen reaksie teen 25 Maart 2017
was u aansoek onsuksesvol
0000000-DW090317
TIPPLER 3 PROJECT
All Local Building Contractors areencouraged to register their
companies on the Group Five Thulanda JV Vendor databaseThe database will be used to
Registration places your company in a better position tobe considered for various sub-contracts that need to beawarded for the Tippler 3 and other Group Five Thulanda Projects in the region
To register on our Supplier Development (SD)Database all local companies are required to completea Vendors Take on Form and to submit the dulycompleted form together with necessary documentrequirements to our SD Officer Nosi Hlulelo byemailing her at nosihlulelothulandacoza
MAKING A DIFFERENCE
000000-DW090317
APPENDIX F3
PROOF OF BAR NOTIFICATION
From Mandy KulaTo Mandy KulaBcc brianwichtcoza yolandaswartmwebcoza adminbluebaylodgecoza admin3bluebaylodgecoza aduffell-canhamcapenaturecoza
Subject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENT
Date 09 March 2017 012626 PMAttachments Exec Summary - Basic Assessment Report (9Mar17)pdf
Let ndash BAR Notification (9Mar17)pdfimage4981fbPNG
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposedproject for a 30-day review and comment period from 10 March to 10 April 2017 (including one additional day to coverthe intervening public holiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
SLR Consulting (South Africa) (Pty) Ltd Page iv
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
Proposed north-south access road
Proposed eastern access road
Trunk Road 85
Main Road 559 Minor Road 7645
Saldanha Bay Industrial Development Zone
Duferco
Future Afrisam cement plant
Proposed north-south access road
Proposed eastern access road
From Ena de VilliersTo Ena de VilliersBcc gerritsmithsbmgovza malcolmwatterswesterncapegovza corvdwelsenburgcom aduffell-canhamcapenaturecoza
melaneseschipperswesterncapegovzaSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
REMINDER OF CLOSURE OF BAR COMMENT PERIODDate 04 April 2017 110142 AMAttachments image6c48afPNG
Dear SirsMadams We would like to take this opportunity to remind you of the closure of the comment period for the above-mentioned projecton 10 April 2017 Kindly submit your comments to Mandy Kula (mkulaslrconsultingcom) or myself at the contact particularsbelow You are welcome to contact us regarding any enquiries Thanks and best regardsEna
Ena de VilliersEnvironmental ConsultantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
APPENDIX F4
DRAFT BAR COMMENTS AND RESPONSES REPORT
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
1
DRAFT BASIC ASSESSMENT REPORT (BAR)
COMMENTS AND RESPONSES REPORT
Written submissions were received from the following commenting authorities and other Interested and Affected Parties (IampAPs) during the BAR comment period
SUBMITTED BY METHOD AND DATE Authorities 1 West Coast District Municipality ndash Ms Doretha Kotze Email - 29 March 2017
2 Department of Environmental Affairs and Development Planning ndash Ms M Schippers Fax - 07 April 2017
3 Saldanha Bay Municipality ndash Mr E Mmbadi Email - 10 April 2017
4 CapeNature ndash Ms Alana Duffell-Canham Email - 11 April 2017
Other IampAPs 1 Phillips Group ndash Mr Jan Phillips Email - 10 March 2017
Copies of the written comments are attached as Attachment A to this report arranged according to the order indicated in the table above The comments received are presented in Table 1 below and have been categorised as follows A Authority comments and issues 1 Comments received from West Coast District Municipality
11 Implications of Draft EMF for Saldanha region 12 Servitudes on the property
2 Comments received from Department of Environmental Affairs and Development Planning 21 Applicable listed Activities 22 Originally signed and dated declarations 23 Proof of Public Participation
3 Comments received from Saldanha Bay Municipality 31 Critical Biodiversity Areas 32 Cumulative impact of construction on ambient air quality 33 Road maintenance after completion 34 Water use during construction phase 35 Palaeontological and archaeological findings
4 Comments received from CapeNature 41 Status of vegetation types 42 Critical Biodiversity Areas 43 Implications for proposed eastern access route alignment 44 Proposed north-south access road 45 Rights reserved
B Other IampAP comments and issues 1 Comments received from Phillips Group
11 Effect of proposed project on traffic flow and businesses in the area 2 Comments received from Afrisam
21 Late submission of comments 22 South-north access road currently under construction 23 Zoning of Farm 1139 24 Suggestions for amending proposed mitigation measures 25 Details regarding activity information
No importance should be given to the order in which the categories are presented
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
2
Table 1 Summary table of comments received on the draft BAR with responses from SLR and the project technical team as appropriate
NO ISSUE NAME DATE COMMENT RESPONSE
A AUTHORITY COMMENTS AND ISSUES
1 COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY 11 Implications of
Draft EMF for Saldanha region
Doretha Kotze 20170329 1 Your letter dated 9 March 2017 and the information contained in the Draft BAR for the proposal refer
2 The Environmental Management Framework (EMF) for the Saldanha region is currently being revisited as part of the drafting of the Greater Saldanha Regional Spatial Implementation Framework by the Western Cape Provincial Department of Environmental Affairs and Development Planning It is recommended that this proposal be aligned with the outcomes of the different studies being undertaken as part of the finalisation of the EMF since Farm 1139 is situated in an area that has been identified as a Conflict Area in terms of the Urban Conservation Zone and Industrial Development Zone For more information of the EMF process kindly contact Ryan Nel at GIBB Consulting (rnelgibbcoza or Tel 011 519 4600)
We have taken the Draft EMF into consideration in the revised BAR (refer to Section D2(c)) However the document has not yet been formally adopted Thus the implied action by the Saldanha Municipality namely to resolve the conflict in the process of updating their Spatial Development Framework has not yet been undertaken Thus the formal land use status of the property remains intended for industrial development
12 Servitudes on the property
Doretha Kotze 20170329 3 Several servitudes had been registered over Farm 1139 over the years accommodating power lines water pipelines and rights of way Two bulk water pipelines of the West Coast District Municipality traversing the property in the northwest will be crossed by the proposed new access roads Care should be taken during the construction phase to prevent negative impacts on these pipelines
The project design engineers are aware of the existence of servitudes As necessary application would be made for wayleaves from the district and local municipalities if any works occur near water or other bulk services infrastructure
2 COMMENTS FROM DEPARTMENT OF ENVIRONMENTAL AFFAIRS AND DEVELOPMENT PLANNING 21 Applicable listed
activities M Schippers 20170407 The draft BAR dated March 2017 and received by this Department
on 09 March 2017 refer 1 Applicable listed activities 11 It is noted that Activity 12 of GN No R985 is being applied for 12 Please note that the abovementioned activity is not applicable
to the proposed development since the vegetation occurring on the proposed site has not been classified as a critically endangered or endangered ecosystem in terms of the National Environmental Management Biodiversity Act of 2004 (ldquoNEMBArdquo) List of Threatened Ecosystems in Need of Protection December 2011)
13 This activity must be excluded from the application
We have noted the comments in Item 1 and have amended the revised BAR accordingly ndash see Sections A1(c) and B5(c) and (d)
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
3
NO ISSUE NAME DATE COMMENT RESPONSE 22 Originally signed
and dated declarations
M Schippers 07 April17 2 The duly dated and originally signed declarations as completed by the applicant the Environmental Assessment Practitioner and the specialists who compiled the specialist reports as part of the Environmental Impact Assessment Process must be included in the BAR to be submitted to the competent authority
The originally signed declarations will be included in the final BAR which will be submitted to your Department after the conclusion of the revised BAR comment period
23 Proof of public participation
M Schippers 07 April17 3 Proof of Public Participation 31 Proof of the public participation conducted must be included in
the BAR to be submitted to the competent authority please note that the proof must include inter alia the following
311 A copy of the newspaper advertisement (ldquonewspaper clippingrdquo) that was placed indicating the name of the newspaper and date of publication
312 Photographs showing the notice displayed on site and a copy of the text displayed on the notice and
313 With regards to the written notices provided please note the following
bull If registered mail was sent a list of the registered mail sent as obtained from the post office must be provided
bull If regular mail was sent a list of the mail sent as obtained from the post office must be provided
bull If a facsimile was sent a copy of the facsimile report must be provided
bull If an electronic mail was sent a copy of the electronic mail sent and delivery reports must be provided and
bull If a ldquomail droprdquo was done a signed register of ldquomail dropsrdquo must be provided
Proof of public participation has been included in the revised BAR as follows bull Newspaper advertisement ndash Appendix F2 bull Site notice ndash Appendix F2 and bull Written notifications ndash Appendix F3 Please note that as e-mail addresses were available for all IampAPs registered on the database the formal notification letter was sent by means of electronic mail However delivery reports were not requested as this requirement is not stated in the relevant legislation nor in any guideline document on public participation of which we are aware Thus we have included a copy of the e-mail notification sent as adequate proof of distribution Hard copies of letters were delivered to representatives of commenting authorities proof of which is also included in Appendix F3
3 COMMENTS FROM SALDANHA BAY MUNICIPALITY 31 Critical
Biodiversity Areas
Mr E Mmbadi 20170410 1 Basic Assessment Report for the Proposed New Access Roads to the Saldanha Bay Industrial Development Zone dated 07 March 2017 refers
2 Even though the site is located outside the Critical Biodiversity Area it may function as a ldquostepping stonerdquo corridor that allows for animal and plant movement across the landscape Development within such sites should consider ecological connectivity of the landscape and care should be taken not to disrupt this connectivity especially for a site surrounded by Critical Biodiversity Areas
The draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest Western Cape Biodiversity Spatial Plan became available in April 2017 and was taken into consideration in the revised BAR which will be made available for a further review and comment period
32 Cumulative Mr E Mmbadi 20170410 3 The report should highlight the potential cumulative impacts of These comments have been noted As the
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
4
NO ISSUE NAME DATE COMMENT RESPONSE impact of construction on ambient air quality
several construction activities on ambient air quality Viewing the impacts of access roads construction in isolation may only reveal limited potential impacts on the ambient air quality The report should also look at the possible release of iron ore dust trapped on vegetation into the atmosphere
construction phase of the proposed project has not yet been scheduled it cannot be assumed that it will occur while other road construction projects in the area are in progress Reference to the implications of the possible release of iron ore dust trapped on vegetation for dust generation and control during the construction phase has been incorporated into the revised BAR (see Sections F2(b) and F615) and the Construction EMP (see Section 312(b))
33 Road maintenance after completion
Mr E Mmbadi 20170410 4 In most cases after the construction work is completed the roads are handed over to local authority to maintain and service If it is envisaged to hand over the proposed access roads to Saldanha Bay Municipality (ldquoSBMrdquo) the report should acknowledge such intention Also ensure that all the requirements from SBM with regard to roads are met Please contact Manager Roads amp Stormwater (jeremyjarvissbmgovza 022 701 7049) in this regard
The design engineers have engaged with SBM regarding the future management of the roads as is indicated by the following statement in the BAR ldquoSaldanha Bay Municipality has requested that the road reserve should be registered as a separate erf which would be a portion of this propertyrdquo (see Section A2)
34 Water use during construction phase
Mr E Mmbadi 20170410 5 SBM commenced with the implementation of level 3 water restriction Please advise if there is confirmation from the municipality with regard to the supply of water to the proposed development SBM discourages the use of potable water as a dust suppression measure or for any construction purpose please indicate the developmentrsquos potential water source The use of treated effluent from the waste water treatment works could be an option Please contact Manager of Bulk Water and Sanitation (gavinwilliamasbmgovza 022 701 7047) in this regard Also consult with the Department of Water and Sanitation with regard to the water use application process
These comments regarding water conservation have been noted and relevant measures to prevent the use of potable water for dust suppression have been included in the revised BAR (see Sections F2(b) F3 and E615 of the revised BAR and Section 312(a) of the Construction EMP) Please note that the road development would only require a limited supply of water during the construction phase which the Contractor would be required to source from available resources Consultation with DWS regarding a water use application may thus not be relevant
35 Palaeontological and archaeological findings
Mr E Mmbadi 20170410 6 Please inform the Environment amp Heritage Section of the SBM on any Palaeontological and Archaeological findings for our records
This request has been included in the revised BAR (see Section F617) as well as the Construction EMP (see Section 3102(e))
4 COMMENTS FROM CAPENATURE 41 Status of
vegetation types Alana Duffell-Canham
20170410 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road 1 The proposed eastern access road passes through an area
These comments regarding the status of the vegetation types on the project site have been noted On the basis of the botanical assessment undertaken as part of the Basic Assessment process the condition of the Saldahna Limestone
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
5
NO ISSUE NAME DATE COMMENT RESPONSE covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet [been] listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6 000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
Strandveld vegetation located on the limestone ridge has indeed been described as of high botanical sensitivity in the draft BAR As to the status of the vegetation please take cognisance of DEAampDPrsquos position that only the formal classification of vegetation in terms of NEMBA is considered applicable in relation to the NEMA EIA Regulations This was in response to our indication in the draft BAR that Saldahna Flats Strandveld which is classified ldquoVulnerablerdquo should be considered ldquoEndangeredrdquo on the basis of a 2014 CapeNature status report Please refer to Comment and Response 21 above We thus have to assume that DEAampDP would consider the formal classification of Saldahna Limestone Strandveld as ldquoLeast Threatenedrdquo in terms of NEMBA as applicable
42 Critical Biodiversity Areas
Alana Duffell-Canham
20170410 2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent land cover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truth where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data
A mentioned in Response 31 above the draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest WCBSP which became available in April 2017 has been taken into consideration in the revised BAR Our observation regarding the mapping of the CBAs is that this covers a large area on the specific property and extends notably further northwards than the intact vegetation on the limestone ridge According to the ground-truthing of the botanical
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
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SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
NOTICE OF PUBLIC PARTICIPATION PROCESS
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Notice is hereby given of a public participation process in terms of the National Environmental Management Act (No 107 of 1998) (NEMA) and Environmental Impact Assessment (EIA) Regulations 2014
Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) Environmental Assessment Practitioner SLR Consulting (South Africa) (Pty) Ltd (SLR)
Project description The SBIDZ-LC is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) namely bull A new eastern access road and new intersection on Minor Road 7645 (Port Road) to
provide access to the SBIDZ area north of Main Road 559 (Camp Road) as well as to a proposed new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
Application for Environmental Authorisation (EA) to undertake the following activities The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
SLR Consulting Contact Details Unit 39 Roeland Square 30 Drury Lane CAPE TOWN 8001 Tel (021) 461 1118 Fax (021) 461 1120 E-mail edevilliersslrconsultingcom Website wwwslrconsultingcomza Date of advertisement 9 March 2017
SMEC03ARStakeholder docsAdvert_Notice Advert ndash new access roads (March 2017)
22 Weslander GEKLASSIFISEERD CLASSIFIEDS 9 Maart 2017
DIRECTORATE ENGINEERING amp PLANNING SERVICES
DIRECTORATE FINANCE
DEPARTMENT SOLID WASTE
DEPARTMENT SUPPLY CHAIN MANAGEMENT
DEPARTMENT REVENUE
Superintendent Solid Waste Management Landfills
Senior Bid Administrator
Meter Reader
Applicants must be in possession of a National Diploma in Civil Engineering with Solid WasteManagement 4 as an additional subject bull 2 yearsrsquo relevant experience within Civil Engineering of which 1year should be on a supervisory level bull Computer Literacy bull Code B driverrsquos License bull Good communicationskills in two of the three official languages of the Western Cape
Duties will entail Perform administrative functions bull Communicate information to community memberswith regards to landfill sites and transfer stations bull Manage landfill sites and transfer stations bull Monitor toxicwaste as per the relevant regulations bull Manage the staff discipline and safety within the section bull Collectionof borehole water samples twice a year bull Follow-up on reported incidents bull Manage assets (equipment andmachinery) within the section bull Tender and contract administration
Applicants must be in possession of a Grade 12 bull 4 yearsrsquo relevant Supply Chain Managementexperience bull Computer literacy bull Code B driverrsquos license will serve as a recommendation bull Goodcommunication skills in two of the three official languages of the Western Cape
Duties will entail Administer Bid specifications process bull Administer the opening and registration oftenders bull Ensure that contracts do not lapse in terms of the validity period bull Administer the performance ofvendorsbidders above R200 000 bull Provide Human Resource support bull Report any irregularities to theSupply Chain Manager bull Internal and external communication
Salary Scale T11 (R220 16214 ndash R285 76824 p a)Enquiries Ms H Meeding Tel (022) 701 6916
Applicants must be in possession of a Grade 12 bull Code B driverrsquos license bull Good numerical skillsbull Physically fit and healthy bull Good communication skills in two of the three official languages of the WesternCape
Duties will entail The accurate reading and recording of meter readings to ensure that readings are beingprocessed and that all customers are charged with correct amounts bull Noting and reporting of complaints onfaulty water and electricity meters bull Update of route cards to ensure that new developments and areas arerecorded on the financial- and meter reading system
Salary scale T6 (R108 07992 ndash R140 29232 pa)Enquiries Mr H Smith Tel (022) 701 7011
Closing Date 23 March 2017 at 1200
NOTES TO APPLICANT
bull Thank you for your interest in seeking employment with usbull All applications should be accompanied by a completed application form (obtainable from our
Human Resource office or website wwwsbmgovza) clearly reflecting the name of the positionapplying for a comprehensive CV a certified copy of your ID driverrsquos license and educationalqualifications
bull No original documents attached to the application will be safe keptreturnedbull Applications without afore - mentioned will not be consideredbull Applications should be forwarded to Human Resource Services Private Bag X12 Vredenburg
7380 or via email to munsbmgovzabull ApplicationsSupporting documents larger that 2MB sent via email are not accommodatedbull For the implementation of the Employment Act candidates are encouraged to indicate their race
gender and disabilitybull No late applications will be consideredbull Further communication will be limited to shortlisted candidates If you have not received a
response within 3 (three) months of the closing date please consider your applicationunsuccessful
bull All appointments are subject to a medical assessment criminal record and reference checks fromprevious and current employer(s)
bull The Council beholds the right to make an appointment
Serve Grow and SucceedTogether
Saldanha Bay Municipality is a high profile municipality that takes care of its people to deliver thehighest quality of service to its residents and visitors We are also committed to the goals of ourEmployment Equity Plan If you are competent and committed and would like to work in aprofessional environment you are welcome to apply for the following positions on our staffestablishment
T (022) 701 7000 F (022) 715 1518 munsbmgovza wwwsbmgovzabull bull bull
00000000-DW090317
NOTICE OF PUBLIC PARTICIPATION PROCESS
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THESALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SMEC03AR 022017 DEAampDP REF NO 16331F417301117
Notice is hereby given of a public participation process in terms of the National Environmental ManagementAct (No 107 of 1998) (NEMA) and Environmental ImpactAssessment (EIA) Regulations 2014
Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC)EnvironmentalAssessment Practitioner SLR Consulting (SouthAfrica) (Pty) Ltd (SLR)
Project description The SBIDZ-LC is proposing to develop two new access roads to the Saldanha BayIndustrial Development Zone (SBIDZ) namelybull Anew eastern access road and new intersection on Minor Road 7645 (Port Road) to provide access to
the SBIDZ area north of Main Road 559 (Camp Road) as well as to a proposed new Afrisam cementplant and
bull Anew north-south access road along the SBIDZ eastern boundary to provide an alternative access tothe Duferco steel processing plant
Application for EnvironmentalAuthorisation (EA) to undertake the following activitiesThe proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in termsof NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (ListingNotice 3)Activities 12 and 18ABasicAssessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor yourorganisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on theBasic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-daycomment period from 10 March to 10 April 2017 (including an additional day to cover the intervening publicholiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Anycomment should be submitted by no later than 10April 2017
SLR Consulting Contact DetailsUnit 39 Roeland Square 30 Drury LaneCAPE TOWN 8001Tel (021) 461 1118 Fax (021) 461 1120E-mail edevilliersslrconsultingcomWebsite wwwslrconsultingcomza Date of advertisement 9 March 2017
0000000-DW090317
Serve Grow and SucceedTogether
ApplicantAansoeker amp OwnerEienaar CK RUMBOLL amp PARTNERS
TEL 022-4871661 ndash Zanellerumbollcoza
Reference numberVerwysingsnommer NR 12319
Property DescriptionEiendomsbeskrywing FARMPLAAS DE KLIP NR 12319
Physical AddressFisiese adres VREDENBURG
Notice is hereby given in terms of Sections 45 amp 46 of the
Saldanha Bay Municipal Land Use Planning By-law that
Saldanha Bay Municipality is considering the following
i) a Consent Use (special usage) in terms Section 15(2)(o) in
order to establish 4 additional residential units on Portion
19 of the Farm De Klip No 123
Details are available for scrutiny at the Municipal Managerrsquos
office during weekdays between 0830 and 1630 contact
the Town Planning Department at 17 Main Street
Vredenburg Any written comments may be addressed to
the Municipal Manager at Private Bag x 12 17 Main Street
Vredenburg doreendunnsbmgovza on or before 10
April 2017 quoting your name address or contact details
interest in the application and reasons for comments
Telephonic enquiries can be made to Bradley Rubidge at 022
- 701 7080 The Municipality may refuse to accept comment
received after the closing date Any person who cannot
write will be assisted by a Municipal official by transcribing
their comments Commentsobjections will be forwarded to
the applicant for hisher response
N1817 (09-03-2017)
K e n n i s w o r d h i e r m e e g e g e e i n g e v o l g e
Artikels 45 amp 46 van die Saldanhabaai Munisipale
Grondgebruikbeplanningsverordening dat Saldanhabaai
M u n i s i p a l i t e i t d i e v o l g e n d e o o r w e e g
i) lsquon Vergunningsgebruik (spesiale gebruik) in terme Artikel
15(2)(a) ten einde 4 addisionele residensieumlle eenhede op
Gedeelte 19 van die Plaas De Klip Nr 123 te
akkommodeer
Nadere besonderhede lecirc ter insae by die Munisipale
Bestuurder se kantoor gedurende weeksdae tussen 0830
and 1630 kontak die Departement Stadsbeplanning by
Hoofstraat 17 Vredenburg Enige skriftelike kommentaar
kan gerig word aan die Munisipale Bestuurder Privaatsak x
12 Hoofstraat 17 Vredenburg doreendunnsbmgovza
op of voor 10 April 2017 met vermelding van u naam adres
of kontakbesonderhede belangstelling in die aansoek en
redes vir kommentaar Telefoniese navrae kan gerig word
aan Bradley Rubidge by 022 - 701 7080 Die Munisipaliteit
mag weier om kommentaar te aanvaar wat na die
sluitingsdatum ontvang word Enige persoon wat nie kan
skryf sal bygestaan word deur n munisipale amptenaar vir
transkribering van hul kommentaar Besware sal aan die
applicant gestuur word vir syhaar repliek
K1817 (09-03-2017)
T (022) 701 7000 F (022) 715 1518 munsbmgovza wwwsbmgovzabull bull bull
0000000-DW090317
Madeleyn Ingelyf prokureurs vanVredenburg benodig die dienste van n
litigasie invorderings tikster
Die geskikte kandidaat moetrekenaarvaardig en tweetalig wees en
sal toepaslike ondervinding n sterkaanbeveling wees
Stuur asseblief u CV per e pos aanniekiemadeleyncoza
of lewer per hand af aanMadeleyn Ingelyf
Hoofstraat 6 Vredenburg
LITIGASIE
TIKSTER
000000-DW090317
BESTUURDER VIR
HOSPITALITEITSBEDRYF
Vorige ondervinding n vereisteGoeie menseverhoudings
Uitstekende kommunikasie vermoeumlnsMoet onder druk kan werk asook lang ure
Verkieslik manlik
Kontak 073 070 8414
Sluitingsdatum 16 Maart 2017
000000-DW090317
BRAAIKUIKEN
PLAASBESTUURDER(WORCESTER AREA)
bull Algemene bestuur van braaikuiken plaasbull Beheer en kontrole oor personeelbull Opdragte van bestuur aan personeel oordra en
toesien dat werk effektief uitgevoer wordbull Betroubaar eerlik en hardwerkendbull Moet onder druk kan funksioneerbull Moet bereid wees om oortyd en naweke te werkbull Bestuurderslisensie n vereistebull Geen ondervinding nodig
Gratis behuising op plaas ingesluitSluitingsdatum 20 Maart 2017
E-pos soverbycompnetcozaof faks na 086 4306 721
Indien geen reaksie teen 25 Maart 2017
was u aansoek onsuksesvol
0000000-DW090317
TIPPLER 3 PROJECT
All Local Building Contractors areencouraged to register their
companies on the Group Five Thulanda JV Vendor databaseThe database will be used to
Registration places your company in a better position tobe considered for various sub-contracts that need to beawarded for the Tippler 3 and other Group Five Thulanda Projects in the region
To register on our Supplier Development (SD)Database all local companies are required to completea Vendors Take on Form and to submit the dulycompleted form together with necessary documentrequirements to our SD Officer Nosi Hlulelo byemailing her at nosihlulelothulandacoza
MAKING A DIFFERENCE
000000-DW090317
APPENDIX F3
PROOF OF BAR NOTIFICATION
From Mandy KulaTo Mandy KulaBcc brianwichtcoza yolandaswartmwebcoza adminbluebaylodgecoza admin3bluebaylodgecoza aduffell-canhamcapenaturecoza
Subject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENT
Date 09 March 2017 012626 PMAttachments Exec Summary - Basic Assessment Report (9Mar17)pdf
Let ndash BAR Notification (9Mar17)pdfimage4981fbPNG
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposedproject for a 30-day review and comment period from 10 March to 10 April 2017 (including one additional day to coverthe intervening public holiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
SLR Consulting (South Africa) (Pty) Ltd Page iv
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
Proposed north-south access road
Proposed eastern access road
Trunk Road 85
Main Road 559 Minor Road 7645
Saldanha Bay Industrial Development Zone
Duferco
Future Afrisam cement plant
Proposed north-south access road
Proposed eastern access road
From Ena de VilliersTo Ena de VilliersBcc gerritsmithsbmgovza malcolmwatterswesterncapegovza corvdwelsenburgcom aduffell-canhamcapenaturecoza
melaneseschipperswesterncapegovzaSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
REMINDER OF CLOSURE OF BAR COMMENT PERIODDate 04 April 2017 110142 AMAttachments image6c48afPNG
Dear SirsMadams We would like to take this opportunity to remind you of the closure of the comment period for the above-mentioned projecton 10 April 2017 Kindly submit your comments to Mandy Kula (mkulaslrconsultingcom) or myself at the contact particularsbelow You are welcome to contact us regarding any enquiries Thanks and best regardsEna
Ena de VilliersEnvironmental ConsultantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
APPENDIX F4
DRAFT BAR COMMENTS AND RESPONSES REPORT
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
1
DRAFT BASIC ASSESSMENT REPORT (BAR)
COMMENTS AND RESPONSES REPORT
Written submissions were received from the following commenting authorities and other Interested and Affected Parties (IampAPs) during the BAR comment period
SUBMITTED BY METHOD AND DATE Authorities 1 West Coast District Municipality ndash Ms Doretha Kotze Email - 29 March 2017
2 Department of Environmental Affairs and Development Planning ndash Ms M Schippers Fax - 07 April 2017
3 Saldanha Bay Municipality ndash Mr E Mmbadi Email - 10 April 2017
4 CapeNature ndash Ms Alana Duffell-Canham Email - 11 April 2017
Other IampAPs 1 Phillips Group ndash Mr Jan Phillips Email - 10 March 2017
Copies of the written comments are attached as Attachment A to this report arranged according to the order indicated in the table above The comments received are presented in Table 1 below and have been categorised as follows A Authority comments and issues 1 Comments received from West Coast District Municipality
11 Implications of Draft EMF for Saldanha region 12 Servitudes on the property
2 Comments received from Department of Environmental Affairs and Development Planning 21 Applicable listed Activities 22 Originally signed and dated declarations 23 Proof of Public Participation
3 Comments received from Saldanha Bay Municipality 31 Critical Biodiversity Areas 32 Cumulative impact of construction on ambient air quality 33 Road maintenance after completion 34 Water use during construction phase 35 Palaeontological and archaeological findings
4 Comments received from CapeNature 41 Status of vegetation types 42 Critical Biodiversity Areas 43 Implications for proposed eastern access route alignment 44 Proposed north-south access road 45 Rights reserved
B Other IampAP comments and issues 1 Comments received from Phillips Group
11 Effect of proposed project on traffic flow and businesses in the area 2 Comments received from Afrisam
21 Late submission of comments 22 South-north access road currently under construction 23 Zoning of Farm 1139 24 Suggestions for amending proposed mitigation measures 25 Details regarding activity information
No importance should be given to the order in which the categories are presented
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
2
Table 1 Summary table of comments received on the draft BAR with responses from SLR and the project technical team as appropriate
NO ISSUE NAME DATE COMMENT RESPONSE
A AUTHORITY COMMENTS AND ISSUES
1 COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY 11 Implications of
Draft EMF for Saldanha region
Doretha Kotze 20170329 1 Your letter dated 9 March 2017 and the information contained in the Draft BAR for the proposal refer
2 The Environmental Management Framework (EMF) for the Saldanha region is currently being revisited as part of the drafting of the Greater Saldanha Regional Spatial Implementation Framework by the Western Cape Provincial Department of Environmental Affairs and Development Planning It is recommended that this proposal be aligned with the outcomes of the different studies being undertaken as part of the finalisation of the EMF since Farm 1139 is situated in an area that has been identified as a Conflict Area in terms of the Urban Conservation Zone and Industrial Development Zone For more information of the EMF process kindly contact Ryan Nel at GIBB Consulting (rnelgibbcoza or Tel 011 519 4600)
We have taken the Draft EMF into consideration in the revised BAR (refer to Section D2(c)) However the document has not yet been formally adopted Thus the implied action by the Saldanha Municipality namely to resolve the conflict in the process of updating their Spatial Development Framework has not yet been undertaken Thus the formal land use status of the property remains intended for industrial development
12 Servitudes on the property
Doretha Kotze 20170329 3 Several servitudes had been registered over Farm 1139 over the years accommodating power lines water pipelines and rights of way Two bulk water pipelines of the West Coast District Municipality traversing the property in the northwest will be crossed by the proposed new access roads Care should be taken during the construction phase to prevent negative impacts on these pipelines
The project design engineers are aware of the existence of servitudes As necessary application would be made for wayleaves from the district and local municipalities if any works occur near water or other bulk services infrastructure
2 COMMENTS FROM DEPARTMENT OF ENVIRONMENTAL AFFAIRS AND DEVELOPMENT PLANNING 21 Applicable listed
activities M Schippers 20170407 The draft BAR dated March 2017 and received by this Department
on 09 March 2017 refer 1 Applicable listed activities 11 It is noted that Activity 12 of GN No R985 is being applied for 12 Please note that the abovementioned activity is not applicable
to the proposed development since the vegetation occurring on the proposed site has not been classified as a critically endangered or endangered ecosystem in terms of the National Environmental Management Biodiversity Act of 2004 (ldquoNEMBArdquo) List of Threatened Ecosystems in Need of Protection December 2011)
13 This activity must be excluded from the application
We have noted the comments in Item 1 and have amended the revised BAR accordingly ndash see Sections A1(c) and B5(c) and (d)
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
3
NO ISSUE NAME DATE COMMENT RESPONSE 22 Originally signed
and dated declarations
M Schippers 07 April17 2 The duly dated and originally signed declarations as completed by the applicant the Environmental Assessment Practitioner and the specialists who compiled the specialist reports as part of the Environmental Impact Assessment Process must be included in the BAR to be submitted to the competent authority
The originally signed declarations will be included in the final BAR which will be submitted to your Department after the conclusion of the revised BAR comment period
23 Proof of public participation
M Schippers 07 April17 3 Proof of Public Participation 31 Proof of the public participation conducted must be included in
the BAR to be submitted to the competent authority please note that the proof must include inter alia the following
311 A copy of the newspaper advertisement (ldquonewspaper clippingrdquo) that was placed indicating the name of the newspaper and date of publication
312 Photographs showing the notice displayed on site and a copy of the text displayed on the notice and
313 With regards to the written notices provided please note the following
bull If registered mail was sent a list of the registered mail sent as obtained from the post office must be provided
bull If regular mail was sent a list of the mail sent as obtained from the post office must be provided
bull If a facsimile was sent a copy of the facsimile report must be provided
bull If an electronic mail was sent a copy of the electronic mail sent and delivery reports must be provided and
bull If a ldquomail droprdquo was done a signed register of ldquomail dropsrdquo must be provided
Proof of public participation has been included in the revised BAR as follows bull Newspaper advertisement ndash Appendix F2 bull Site notice ndash Appendix F2 and bull Written notifications ndash Appendix F3 Please note that as e-mail addresses were available for all IampAPs registered on the database the formal notification letter was sent by means of electronic mail However delivery reports were not requested as this requirement is not stated in the relevant legislation nor in any guideline document on public participation of which we are aware Thus we have included a copy of the e-mail notification sent as adequate proof of distribution Hard copies of letters were delivered to representatives of commenting authorities proof of which is also included in Appendix F3
3 COMMENTS FROM SALDANHA BAY MUNICIPALITY 31 Critical
Biodiversity Areas
Mr E Mmbadi 20170410 1 Basic Assessment Report for the Proposed New Access Roads to the Saldanha Bay Industrial Development Zone dated 07 March 2017 refers
2 Even though the site is located outside the Critical Biodiversity Area it may function as a ldquostepping stonerdquo corridor that allows for animal and plant movement across the landscape Development within such sites should consider ecological connectivity of the landscape and care should be taken not to disrupt this connectivity especially for a site surrounded by Critical Biodiversity Areas
The draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest Western Cape Biodiversity Spatial Plan became available in April 2017 and was taken into consideration in the revised BAR which will be made available for a further review and comment period
32 Cumulative Mr E Mmbadi 20170410 3 The report should highlight the potential cumulative impacts of These comments have been noted As the
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
4
NO ISSUE NAME DATE COMMENT RESPONSE impact of construction on ambient air quality
several construction activities on ambient air quality Viewing the impacts of access roads construction in isolation may only reveal limited potential impacts on the ambient air quality The report should also look at the possible release of iron ore dust trapped on vegetation into the atmosphere
construction phase of the proposed project has not yet been scheduled it cannot be assumed that it will occur while other road construction projects in the area are in progress Reference to the implications of the possible release of iron ore dust trapped on vegetation for dust generation and control during the construction phase has been incorporated into the revised BAR (see Sections F2(b) and F615) and the Construction EMP (see Section 312(b))
33 Road maintenance after completion
Mr E Mmbadi 20170410 4 In most cases after the construction work is completed the roads are handed over to local authority to maintain and service If it is envisaged to hand over the proposed access roads to Saldanha Bay Municipality (ldquoSBMrdquo) the report should acknowledge such intention Also ensure that all the requirements from SBM with regard to roads are met Please contact Manager Roads amp Stormwater (jeremyjarvissbmgovza 022 701 7049) in this regard
The design engineers have engaged with SBM regarding the future management of the roads as is indicated by the following statement in the BAR ldquoSaldanha Bay Municipality has requested that the road reserve should be registered as a separate erf which would be a portion of this propertyrdquo (see Section A2)
34 Water use during construction phase
Mr E Mmbadi 20170410 5 SBM commenced with the implementation of level 3 water restriction Please advise if there is confirmation from the municipality with regard to the supply of water to the proposed development SBM discourages the use of potable water as a dust suppression measure or for any construction purpose please indicate the developmentrsquos potential water source The use of treated effluent from the waste water treatment works could be an option Please contact Manager of Bulk Water and Sanitation (gavinwilliamasbmgovza 022 701 7047) in this regard Also consult with the Department of Water and Sanitation with regard to the water use application process
These comments regarding water conservation have been noted and relevant measures to prevent the use of potable water for dust suppression have been included in the revised BAR (see Sections F2(b) F3 and E615 of the revised BAR and Section 312(a) of the Construction EMP) Please note that the road development would only require a limited supply of water during the construction phase which the Contractor would be required to source from available resources Consultation with DWS regarding a water use application may thus not be relevant
35 Palaeontological and archaeological findings
Mr E Mmbadi 20170410 6 Please inform the Environment amp Heritage Section of the SBM on any Palaeontological and Archaeological findings for our records
This request has been included in the revised BAR (see Section F617) as well as the Construction EMP (see Section 3102(e))
4 COMMENTS FROM CAPENATURE 41 Status of
vegetation types Alana Duffell-Canham
20170410 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road 1 The proposed eastern access road passes through an area
These comments regarding the status of the vegetation types on the project site have been noted On the basis of the botanical assessment undertaken as part of the Basic Assessment process the condition of the Saldahna Limestone
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
5
NO ISSUE NAME DATE COMMENT RESPONSE covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet [been] listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6 000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
Strandveld vegetation located on the limestone ridge has indeed been described as of high botanical sensitivity in the draft BAR As to the status of the vegetation please take cognisance of DEAampDPrsquos position that only the formal classification of vegetation in terms of NEMBA is considered applicable in relation to the NEMA EIA Regulations This was in response to our indication in the draft BAR that Saldahna Flats Strandveld which is classified ldquoVulnerablerdquo should be considered ldquoEndangeredrdquo on the basis of a 2014 CapeNature status report Please refer to Comment and Response 21 above We thus have to assume that DEAampDP would consider the formal classification of Saldahna Limestone Strandveld as ldquoLeast Threatenedrdquo in terms of NEMBA as applicable
42 Critical Biodiversity Areas
Alana Duffell-Canham
20170410 2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent land cover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truth where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data
A mentioned in Response 31 above the draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest WCBSP which became available in April 2017 has been taken into consideration in the revised BAR Our observation regarding the mapping of the CBAs is that this covers a large area on the specific property and extends notably further northwards than the intact vegetation on the limestone ridge According to the ground-truthing of the botanical
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
22 Weslander GEKLASSIFISEERD CLASSIFIEDS 9 Maart 2017
DIRECTORATE ENGINEERING amp PLANNING SERVICES
DIRECTORATE FINANCE
DEPARTMENT SOLID WASTE
DEPARTMENT SUPPLY CHAIN MANAGEMENT
DEPARTMENT REVENUE
Superintendent Solid Waste Management Landfills
Senior Bid Administrator
Meter Reader
Applicants must be in possession of a National Diploma in Civil Engineering with Solid WasteManagement 4 as an additional subject bull 2 yearsrsquo relevant experience within Civil Engineering of which 1year should be on a supervisory level bull Computer Literacy bull Code B driverrsquos License bull Good communicationskills in two of the three official languages of the Western Cape
Duties will entail Perform administrative functions bull Communicate information to community memberswith regards to landfill sites and transfer stations bull Manage landfill sites and transfer stations bull Monitor toxicwaste as per the relevant regulations bull Manage the staff discipline and safety within the section bull Collectionof borehole water samples twice a year bull Follow-up on reported incidents bull Manage assets (equipment andmachinery) within the section bull Tender and contract administration
Applicants must be in possession of a Grade 12 bull 4 yearsrsquo relevant Supply Chain Managementexperience bull Computer literacy bull Code B driverrsquos license will serve as a recommendation bull Goodcommunication skills in two of the three official languages of the Western Cape
Duties will entail Administer Bid specifications process bull Administer the opening and registration oftenders bull Ensure that contracts do not lapse in terms of the validity period bull Administer the performance ofvendorsbidders above R200 000 bull Provide Human Resource support bull Report any irregularities to theSupply Chain Manager bull Internal and external communication
Salary Scale T11 (R220 16214 ndash R285 76824 p a)Enquiries Ms H Meeding Tel (022) 701 6916
Applicants must be in possession of a Grade 12 bull Code B driverrsquos license bull Good numerical skillsbull Physically fit and healthy bull Good communication skills in two of the three official languages of the WesternCape
Duties will entail The accurate reading and recording of meter readings to ensure that readings are beingprocessed and that all customers are charged with correct amounts bull Noting and reporting of complaints onfaulty water and electricity meters bull Update of route cards to ensure that new developments and areas arerecorded on the financial- and meter reading system
Salary scale T6 (R108 07992 ndash R140 29232 pa)Enquiries Mr H Smith Tel (022) 701 7011
Closing Date 23 March 2017 at 1200
NOTES TO APPLICANT
bull Thank you for your interest in seeking employment with usbull All applications should be accompanied by a completed application form (obtainable from our
Human Resource office or website wwwsbmgovza) clearly reflecting the name of the positionapplying for a comprehensive CV a certified copy of your ID driverrsquos license and educationalqualifications
bull No original documents attached to the application will be safe keptreturnedbull Applications without afore - mentioned will not be consideredbull Applications should be forwarded to Human Resource Services Private Bag X12 Vredenburg
7380 or via email to munsbmgovzabull ApplicationsSupporting documents larger that 2MB sent via email are not accommodatedbull For the implementation of the Employment Act candidates are encouraged to indicate their race
gender and disabilitybull No late applications will be consideredbull Further communication will be limited to shortlisted candidates If you have not received a
response within 3 (three) months of the closing date please consider your applicationunsuccessful
bull All appointments are subject to a medical assessment criminal record and reference checks fromprevious and current employer(s)
bull The Council beholds the right to make an appointment
Serve Grow and SucceedTogether
Saldanha Bay Municipality is a high profile municipality that takes care of its people to deliver thehighest quality of service to its residents and visitors We are also committed to the goals of ourEmployment Equity Plan If you are competent and committed and would like to work in aprofessional environment you are welcome to apply for the following positions on our staffestablishment
T (022) 701 7000 F (022) 715 1518 munsbmgovza wwwsbmgovzabull bull bull
00000000-DW090317
NOTICE OF PUBLIC PARTICIPATION PROCESS
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THESALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SMEC03AR 022017 DEAampDP REF NO 16331F417301117
Notice is hereby given of a public participation process in terms of the National Environmental ManagementAct (No 107 of 1998) (NEMA) and Environmental ImpactAssessment (EIA) Regulations 2014
Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC)EnvironmentalAssessment Practitioner SLR Consulting (SouthAfrica) (Pty) Ltd (SLR)
Project description The SBIDZ-LC is proposing to develop two new access roads to the Saldanha BayIndustrial Development Zone (SBIDZ) namelybull Anew eastern access road and new intersection on Minor Road 7645 (Port Road) to provide access to
the SBIDZ area north of Main Road 559 (Camp Road) as well as to a proposed new Afrisam cementplant and
bull Anew north-south access road along the SBIDZ eastern boundary to provide an alternative access tothe Duferco steel processing plant
Application for EnvironmentalAuthorisation (EA) to undertake the following activitiesThe proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in termsof NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (ListingNotice 3)Activities 12 and 18ABasicAssessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor yourorganisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on theBasic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-daycomment period from 10 March to 10 April 2017 (including an additional day to cover the intervening publicholiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Anycomment should be submitted by no later than 10April 2017
SLR Consulting Contact DetailsUnit 39 Roeland Square 30 Drury LaneCAPE TOWN 8001Tel (021) 461 1118 Fax (021) 461 1120E-mail edevilliersslrconsultingcomWebsite wwwslrconsultingcomza Date of advertisement 9 March 2017
0000000-DW090317
Serve Grow and SucceedTogether
ApplicantAansoeker amp OwnerEienaar CK RUMBOLL amp PARTNERS
TEL 022-4871661 ndash Zanellerumbollcoza
Reference numberVerwysingsnommer NR 12319
Property DescriptionEiendomsbeskrywing FARMPLAAS DE KLIP NR 12319
Physical AddressFisiese adres VREDENBURG
Notice is hereby given in terms of Sections 45 amp 46 of the
Saldanha Bay Municipal Land Use Planning By-law that
Saldanha Bay Municipality is considering the following
i) a Consent Use (special usage) in terms Section 15(2)(o) in
order to establish 4 additional residential units on Portion
19 of the Farm De Klip No 123
Details are available for scrutiny at the Municipal Managerrsquos
office during weekdays between 0830 and 1630 contact
the Town Planning Department at 17 Main Street
Vredenburg Any written comments may be addressed to
the Municipal Manager at Private Bag x 12 17 Main Street
Vredenburg doreendunnsbmgovza on or before 10
April 2017 quoting your name address or contact details
interest in the application and reasons for comments
Telephonic enquiries can be made to Bradley Rubidge at 022
- 701 7080 The Municipality may refuse to accept comment
received after the closing date Any person who cannot
write will be assisted by a Municipal official by transcribing
their comments Commentsobjections will be forwarded to
the applicant for hisher response
N1817 (09-03-2017)
K e n n i s w o r d h i e r m e e g e g e e i n g e v o l g e
Artikels 45 amp 46 van die Saldanhabaai Munisipale
Grondgebruikbeplanningsverordening dat Saldanhabaai
M u n i s i p a l i t e i t d i e v o l g e n d e o o r w e e g
i) lsquon Vergunningsgebruik (spesiale gebruik) in terme Artikel
15(2)(a) ten einde 4 addisionele residensieumlle eenhede op
Gedeelte 19 van die Plaas De Klip Nr 123 te
akkommodeer
Nadere besonderhede lecirc ter insae by die Munisipale
Bestuurder se kantoor gedurende weeksdae tussen 0830
and 1630 kontak die Departement Stadsbeplanning by
Hoofstraat 17 Vredenburg Enige skriftelike kommentaar
kan gerig word aan die Munisipale Bestuurder Privaatsak x
12 Hoofstraat 17 Vredenburg doreendunnsbmgovza
op of voor 10 April 2017 met vermelding van u naam adres
of kontakbesonderhede belangstelling in die aansoek en
redes vir kommentaar Telefoniese navrae kan gerig word
aan Bradley Rubidge by 022 - 701 7080 Die Munisipaliteit
mag weier om kommentaar te aanvaar wat na die
sluitingsdatum ontvang word Enige persoon wat nie kan
skryf sal bygestaan word deur n munisipale amptenaar vir
transkribering van hul kommentaar Besware sal aan die
applicant gestuur word vir syhaar repliek
K1817 (09-03-2017)
T (022) 701 7000 F (022) 715 1518 munsbmgovza wwwsbmgovzabull bull bull
0000000-DW090317
Madeleyn Ingelyf prokureurs vanVredenburg benodig die dienste van n
litigasie invorderings tikster
Die geskikte kandidaat moetrekenaarvaardig en tweetalig wees en
sal toepaslike ondervinding n sterkaanbeveling wees
Stuur asseblief u CV per e pos aanniekiemadeleyncoza
of lewer per hand af aanMadeleyn Ingelyf
Hoofstraat 6 Vredenburg
LITIGASIE
TIKSTER
000000-DW090317
BESTUURDER VIR
HOSPITALITEITSBEDRYF
Vorige ondervinding n vereisteGoeie menseverhoudings
Uitstekende kommunikasie vermoeumlnsMoet onder druk kan werk asook lang ure
Verkieslik manlik
Kontak 073 070 8414
Sluitingsdatum 16 Maart 2017
000000-DW090317
BRAAIKUIKEN
PLAASBESTUURDER(WORCESTER AREA)
bull Algemene bestuur van braaikuiken plaasbull Beheer en kontrole oor personeelbull Opdragte van bestuur aan personeel oordra en
toesien dat werk effektief uitgevoer wordbull Betroubaar eerlik en hardwerkendbull Moet onder druk kan funksioneerbull Moet bereid wees om oortyd en naweke te werkbull Bestuurderslisensie n vereistebull Geen ondervinding nodig
Gratis behuising op plaas ingesluitSluitingsdatum 20 Maart 2017
E-pos soverbycompnetcozaof faks na 086 4306 721
Indien geen reaksie teen 25 Maart 2017
was u aansoek onsuksesvol
0000000-DW090317
TIPPLER 3 PROJECT
All Local Building Contractors areencouraged to register their
companies on the Group Five Thulanda JV Vendor databaseThe database will be used to
Registration places your company in a better position tobe considered for various sub-contracts that need to beawarded for the Tippler 3 and other Group Five Thulanda Projects in the region
To register on our Supplier Development (SD)Database all local companies are required to completea Vendors Take on Form and to submit the dulycompleted form together with necessary documentrequirements to our SD Officer Nosi Hlulelo byemailing her at nosihlulelothulandacoza
MAKING A DIFFERENCE
000000-DW090317
APPENDIX F3
PROOF OF BAR NOTIFICATION
From Mandy KulaTo Mandy KulaBcc brianwichtcoza yolandaswartmwebcoza adminbluebaylodgecoza admin3bluebaylodgecoza aduffell-canhamcapenaturecoza
Subject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENT
Date 09 March 2017 012626 PMAttachments Exec Summary - Basic Assessment Report (9Mar17)pdf
Let ndash BAR Notification (9Mar17)pdfimage4981fbPNG
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposedproject for a 30-day review and comment period from 10 March to 10 April 2017 (including one additional day to coverthe intervening public holiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
SLR Consulting (South Africa) (Pty) Ltd Page iv
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
Proposed north-south access road
Proposed eastern access road
Trunk Road 85
Main Road 559 Minor Road 7645
Saldanha Bay Industrial Development Zone
Duferco
Future Afrisam cement plant
Proposed north-south access road
Proposed eastern access road
From Ena de VilliersTo Ena de VilliersBcc gerritsmithsbmgovza malcolmwatterswesterncapegovza corvdwelsenburgcom aduffell-canhamcapenaturecoza
melaneseschipperswesterncapegovzaSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
REMINDER OF CLOSURE OF BAR COMMENT PERIODDate 04 April 2017 110142 AMAttachments image6c48afPNG
Dear SirsMadams We would like to take this opportunity to remind you of the closure of the comment period for the above-mentioned projecton 10 April 2017 Kindly submit your comments to Mandy Kula (mkulaslrconsultingcom) or myself at the contact particularsbelow You are welcome to contact us regarding any enquiries Thanks and best regardsEna
Ena de VilliersEnvironmental ConsultantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
APPENDIX F4
DRAFT BAR COMMENTS AND RESPONSES REPORT
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
1
DRAFT BASIC ASSESSMENT REPORT (BAR)
COMMENTS AND RESPONSES REPORT
Written submissions were received from the following commenting authorities and other Interested and Affected Parties (IampAPs) during the BAR comment period
SUBMITTED BY METHOD AND DATE Authorities 1 West Coast District Municipality ndash Ms Doretha Kotze Email - 29 March 2017
2 Department of Environmental Affairs and Development Planning ndash Ms M Schippers Fax - 07 April 2017
3 Saldanha Bay Municipality ndash Mr E Mmbadi Email - 10 April 2017
4 CapeNature ndash Ms Alana Duffell-Canham Email - 11 April 2017
Other IampAPs 1 Phillips Group ndash Mr Jan Phillips Email - 10 March 2017
Copies of the written comments are attached as Attachment A to this report arranged according to the order indicated in the table above The comments received are presented in Table 1 below and have been categorised as follows A Authority comments and issues 1 Comments received from West Coast District Municipality
11 Implications of Draft EMF for Saldanha region 12 Servitudes on the property
2 Comments received from Department of Environmental Affairs and Development Planning 21 Applicable listed Activities 22 Originally signed and dated declarations 23 Proof of Public Participation
3 Comments received from Saldanha Bay Municipality 31 Critical Biodiversity Areas 32 Cumulative impact of construction on ambient air quality 33 Road maintenance after completion 34 Water use during construction phase 35 Palaeontological and archaeological findings
4 Comments received from CapeNature 41 Status of vegetation types 42 Critical Biodiversity Areas 43 Implications for proposed eastern access route alignment 44 Proposed north-south access road 45 Rights reserved
B Other IampAP comments and issues 1 Comments received from Phillips Group
11 Effect of proposed project on traffic flow and businesses in the area 2 Comments received from Afrisam
21 Late submission of comments 22 South-north access road currently under construction 23 Zoning of Farm 1139 24 Suggestions for amending proposed mitigation measures 25 Details regarding activity information
No importance should be given to the order in which the categories are presented
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
2
Table 1 Summary table of comments received on the draft BAR with responses from SLR and the project technical team as appropriate
NO ISSUE NAME DATE COMMENT RESPONSE
A AUTHORITY COMMENTS AND ISSUES
1 COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY 11 Implications of
Draft EMF for Saldanha region
Doretha Kotze 20170329 1 Your letter dated 9 March 2017 and the information contained in the Draft BAR for the proposal refer
2 The Environmental Management Framework (EMF) for the Saldanha region is currently being revisited as part of the drafting of the Greater Saldanha Regional Spatial Implementation Framework by the Western Cape Provincial Department of Environmental Affairs and Development Planning It is recommended that this proposal be aligned with the outcomes of the different studies being undertaken as part of the finalisation of the EMF since Farm 1139 is situated in an area that has been identified as a Conflict Area in terms of the Urban Conservation Zone and Industrial Development Zone For more information of the EMF process kindly contact Ryan Nel at GIBB Consulting (rnelgibbcoza or Tel 011 519 4600)
We have taken the Draft EMF into consideration in the revised BAR (refer to Section D2(c)) However the document has not yet been formally adopted Thus the implied action by the Saldanha Municipality namely to resolve the conflict in the process of updating their Spatial Development Framework has not yet been undertaken Thus the formal land use status of the property remains intended for industrial development
12 Servitudes on the property
Doretha Kotze 20170329 3 Several servitudes had been registered over Farm 1139 over the years accommodating power lines water pipelines and rights of way Two bulk water pipelines of the West Coast District Municipality traversing the property in the northwest will be crossed by the proposed new access roads Care should be taken during the construction phase to prevent negative impacts on these pipelines
The project design engineers are aware of the existence of servitudes As necessary application would be made for wayleaves from the district and local municipalities if any works occur near water or other bulk services infrastructure
2 COMMENTS FROM DEPARTMENT OF ENVIRONMENTAL AFFAIRS AND DEVELOPMENT PLANNING 21 Applicable listed
activities M Schippers 20170407 The draft BAR dated March 2017 and received by this Department
on 09 March 2017 refer 1 Applicable listed activities 11 It is noted that Activity 12 of GN No R985 is being applied for 12 Please note that the abovementioned activity is not applicable
to the proposed development since the vegetation occurring on the proposed site has not been classified as a critically endangered or endangered ecosystem in terms of the National Environmental Management Biodiversity Act of 2004 (ldquoNEMBArdquo) List of Threatened Ecosystems in Need of Protection December 2011)
13 This activity must be excluded from the application
We have noted the comments in Item 1 and have amended the revised BAR accordingly ndash see Sections A1(c) and B5(c) and (d)
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
3
NO ISSUE NAME DATE COMMENT RESPONSE 22 Originally signed
and dated declarations
M Schippers 07 April17 2 The duly dated and originally signed declarations as completed by the applicant the Environmental Assessment Practitioner and the specialists who compiled the specialist reports as part of the Environmental Impact Assessment Process must be included in the BAR to be submitted to the competent authority
The originally signed declarations will be included in the final BAR which will be submitted to your Department after the conclusion of the revised BAR comment period
23 Proof of public participation
M Schippers 07 April17 3 Proof of Public Participation 31 Proof of the public participation conducted must be included in
the BAR to be submitted to the competent authority please note that the proof must include inter alia the following
311 A copy of the newspaper advertisement (ldquonewspaper clippingrdquo) that was placed indicating the name of the newspaper and date of publication
312 Photographs showing the notice displayed on site and a copy of the text displayed on the notice and
313 With regards to the written notices provided please note the following
bull If registered mail was sent a list of the registered mail sent as obtained from the post office must be provided
bull If regular mail was sent a list of the mail sent as obtained from the post office must be provided
bull If a facsimile was sent a copy of the facsimile report must be provided
bull If an electronic mail was sent a copy of the electronic mail sent and delivery reports must be provided and
bull If a ldquomail droprdquo was done a signed register of ldquomail dropsrdquo must be provided
Proof of public participation has been included in the revised BAR as follows bull Newspaper advertisement ndash Appendix F2 bull Site notice ndash Appendix F2 and bull Written notifications ndash Appendix F3 Please note that as e-mail addresses were available for all IampAPs registered on the database the formal notification letter was sent by means of electronic mail However delivery reports were not requested as this requirement is not stated in the relevant legislation nor in any guideline document on public participation of which we are aware Thus we have included a copy of the e-mail notification sent as adequate proof of distribution Hard copies of letters were delivered to representatives of commenting authorities proof of which is also included in Appendix F3
3 COMMENTS FROM SALDANHA BAY MUNICIPALITY 31 Critical
Biodiversity Areas
Mr E Mmbadi 20170410 1 Basic Assessment Report for the Proposed New Access Roads to the Saldanha Bay Industrial Development Zone dated 07 March 2017 refers
2 Even though the site is located outside the Critical Biodiversity Area it may function as a ldquostepping stonerdquo corridor that allows for animal and plant movement across the landscape Development within such sites should consider ecological connectivity of the landscape and care should be taken not to disrupt this connectivity especially for a site surrounded by Critical Biodiversity Areas
The draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest Western Cape Biodiversity Spatial Plan became available in April 2017 and was taken into consideration in the revised BAR which will be made available for a further review and comment period
32 Cumulative Mr E Mmbadi 20170410 3 The report should highlight the potential cumulative impacts of These comments have been noted As the
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
4
NO ISSUE NAME DATE COMMENT RESPONSE impact of construction on ambient air quality
several construction activities on ambient air quality Viewing the impacts of access roads construction in isolation may only reveal limited potential impacts on the ambient air quality The report should also look at the possible release of iron ore dust trapped on vegetation into the atmosphere
construction phase of the proposed project has not yet been scheduled it cannot be assumed that it will occur while other road construction projects in the area are in progress Reference to the implications of the possible release of iron ore dust trapped on vegetation for dust generation and control during the construction phase has been incorporated into the revised BAR (see Sections F2(b) and F615) and the Construction EMP (see Section 312(b))
33 Road maintenance after completion
Mr E Mmbadi 20170410 4 In most cases after the construction work is completed the roads are handed over to local authority to maintain and service If it is envisaged to hand over the proposed access roads to Saldanha Bay Municipality (ldquoSBMrdquo) the report should acknowledge such intention Also ensure that all the requirements from SBM with regard to roads are met Please contact Manager Roads amp Stormwater (jeremyjarvissbmgovza 022 701 7049) in this regard
The design engineers have engaged with SBM regarding the future management of the roads as is indicated by the following statement in the BAR ldquoSaldanha Bay Municipality has requested that the road reserve should be registered as a separate erf which would be a portion of this propertyrdquo (see Section A2)
34 Water use during construction phase
Mr E Mmbadi 20170410 5 SBM commenced with the implementation of level 3 water restriction Please advise if there is confirmation from the municipality with regard to the supply of water to the proposed development SBM discourages the use of potable water as a dust suppression measure or for any construction purpose please indicate the developmentrsquos potential water source The use of treated effluent from the waste water treatment works could be an option Please contact Manager of Bulk Water and Sanitation (gavinwilliamasbmgovza 022 701 7047) in this regard Also consult with the Department of Water and Sanitation with regard to the water use application process
These comments regarding water conservation have been noted and relevant measures to prevent the use of potable water for dust suppression have been included in the revised BAR (see Sections F2(b) F3 and E615 of the revised BAR and Section 312(a) of the Construction EMP) Please note that the road development would only require a limited supply of water during the construction phase which the Contractor would be required to source from available resources Consultation with DWS regarding a water use application may thus not be relevant
35 Palaeontological and archaeological findings
Mr E Mmbadi 20170410 6 Please inform the Environment amp Heritage Section of the SBM on any Palaeontological and Archaeological findings for our records
This request has been included in the revised BAR (see Section F617) as well as the Construction EMP (see Section 3102(e))
4 COMMENTS FROM CAPENATURE 41 Status of
vegetation types Alana Duffell-Canham
20170410 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road 1 The proposed eastern access road passes through an area
These comments regarding the status of the vegetation types on the project site have been noted On the basis of the botanical assessment undertaken as part of the Basic Assessment process the condition of the Saldahna Limestone
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
5
NO ISSUE NAME DATE COMMENT RESPONSE covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet [been] listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6 000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
Strandveld vegetation located on the limestone ridge has indeed been described as of high botanical sensitivity in the draft BAR As to the status of the vegetation please take cognisance of DEAampDPrsquos position that only the formal classification of vegetation in terms of NEMBA is considered applicable in relation to the NEMA EIA Regulations This was in response to our indication in the draft BAR that Saldahna Flats Strandveld which is classified ldquoVulnerablerdquo should be considered ldquoEndangeredrdquo on the basis of a 2014 CapeNature status report Please refer to Comment and Response 21 above We thus have to assume that DEAampDP would consider the formal classification of Saldahna Limestone Strandveld as ldquoLeast Threatenedrdquo in terms of NEMBA as applicable
42 Critical Biodiversity Areas
Alana Duffell-Canham
20170410 2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent land cover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truth where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data
A mentioned in Response 31 above the draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest WCBSP which became available in April 2017 has been taken into consideration in the revised BAR Our observation regarding the mapping of the CBAs is that this covers a large area on the specific property and extends notably further northwards than the intact vegetation on the limestone ridge According to the ground-truthing of the botanical
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
APPENDIX F3
PROOF OF BAR NOTIFICATION
From Mandy KulaTo Mandy KulaBcc brianwichtcoza yolandaswartmwebcoza adminbluebaylodgecoza admin3bluebaylodgecoza aduffell-canhamcapenaturecoza
Subject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENT
Date 09 March 2017 012626 PMAttachments Exec Summary - Basic Assessment Report (9Mar17)pdf
Let ndash BAR Notification (9Mar17)pdfimage4981fbPNG
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposedproject for a 30-day review and comment period from 10 March to 10 April 2017 (including one additional day to coverthe intervening public holiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
SLR Consulting (South Africa) (Pty) Ltd Page iv
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
Proposed north-south access road
Proposed eastern access road
Trunk Road 85
Main Road 559 Minor Road 7645
Saldanha Bay Industrial Development Zone
Duferco
Future Afrisam cement plant
Proposed north-south access road
Proposed eastern access road
From Ena de VilliersTo Ena de VilliersBcc gerritsmithsbmgovza malcolmwatterswesterncapegovza corvdwelsenburgcom aduffell-canhamcapenaturecoza
melaneseschipperswesterncapegovzaSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
REMINDER OF CLOSURE OF BAR COMMENT PERIODDate 04 April 2017 110142 AMAttachments image6c48afPNG
Dear SirsMadams We would like to take this opportunity to remind you of the closure of the comment period for the above-mentioned projecton 10 April 2017 Kindly submit your comments to Mandy Kula (mkulaslrconsultingcom) or myself at the contact particularsbelow You are welcome to contact us regarding any enquiries Thanks and best regardsEna
Ena de VilliersEnvironmental ConsultantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
APPENDIX F4
DRAFT BAR COMMENTS AND RESPONSES REPORT
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
1
DRAFT BASIC ASSESSMENT REPORT (BAR)
COMMENTS AND RESPONSES REPORT
Written submissions were received from the following commenting authorities and other Interested and Affected Parties (IampAPs) during the BAR comment period
SUBMITTED BY METHOD AND DATE Authorities 1 West Coast District Municipality ndash Ms Doretha Kotze Email - 29 March 2017
2 Department of Environmental Affairs and Development Planning ndash Ms M Schippers Fax - 07 April 2017
3 Saldanha Bay Municipality ndash Mr E Mmbadi Email - 10 April 2017
4 CapeNature ndash Ms Alana Duffell-Canham Email - 11 April 2017
Other IampAPs 1 Phillips Group ndash Mr Jan Phillips Email - 10 March 2017
Copies of the written comments are attached as Attachment A to this report arranged according to the order indicated in the table above The comments received are presented in Table 1 below and have been categorised as follows A Authority comments and issues 1 Comments received from West Coast District Municipality
11 Implications of Draft EMF for Saldanha region 12 Servitudes on the property
2 Comments received from Department of Environmental Affairs and Development Planning 21 Applicable listed Activities 22 Originally signed and dated declarations 23 Proof of Public Participation
3 Comments received from Saldanha Bay Municipality 31 Critical Biodiversity Areas 32 Cumulative impact of construction on ambient air quality 33 Road maintenance after completion 34 Water use during construction phase 35 Palaeontological and archaeological findings
4 Comments received from CapeNature 41 Status of vegetation types 42 Critical Biodiversity Areas 43 Implications for proposed eastern access route alignment 44 Proposed north-south access road 45 Rights reserved
B Other IampAP comments and issues 1 Comments received from Phillips Group
11 Effect of proposed project on traffic flow and businesses in the area 2 Comments received from Afrisam
21 Late submission of comments 22 South-north access road currently under construction 23 Zoning of Farm 1139 24 Suggestions for amending proposed mitigation measures 25 Details regarding activity information
No importance should be given to the order in which the categories are presented
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
2
Table 1 Summary table of comments received on the draft BAR with responses from SLR and the project technical team as appropriate
NO ISSUE NAME DATE COMMENT RESPONSE
A AUTHORITY COMMENTS AND ISSUES
1 COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY 11 Implications of
Draft EMF for Saldanha region
Doretha Kotze 20170329 1 Your letter dated 9 March 2017 and the information contained in the Draft BAR for the proposal refer
2 The Environmental Management Framework (EMF) for the Saldanha region is currently being revisited as part of the drafting of the Greater Saldanha Regional Spatial Implementation Framework by the Western Cape Provincial Department of Environmental Affairs and Development Planning It is recommended that this proposal be aligned with the outcomes of the different studies being undertaken as part of the finalisation of the EMF since Farm 1139 is situated in an area that has been identified as a Conflict Area in terms of the Urban Conservation Zone and Industrial Development Zone For more information of the EMF process kindly contact Ryan Nel at GIBB Consulting (rnelgibbcoza or Tel 011 519 4600)
We have taken the Draft EMF into consideration in the revised BAR (refer to Section D2(c)) However the document has not yet been formally adopted Thus the implied action by the Saldanha Municipality namely to resolve the conflict in the process of updating their Spatial Development Framework has not yet been undertaken Thus the formal land use status of the property remains intended for industrial development
12 Servitudes on the property
Doretha Kotze 20170329 3 Several servitudes had been registered over Farm 1139 over the years accommodating power lines water pipelines and rights of way Two bulk water pipelines of the West Coast District Municipality traversing the property in the northwest will be crossed by the proposed new access roads Care should be taken during the construction phase to prevent negative impacts on these pipelines
The project design engineers are aware of the existence of servitudes As necessary application would be made for wayleaves from the district and local municipalities if any works occur near water or other bulk services infrastructure
2 COMMENTS FROM DEPARTMENT OF ENVIRONMENTAL AFFAIRS AND DEVELOPMENT PLANNING 21 Applicable listed
activities M Schippers 20170407 The draft BAR dated March 2017 and received by this Department
on 09 March 2017 refer 1 Applicable listed activities 11 It is noted that Activity 12 of GN No R985 is being applied for 12 Please note that the abovementioned activity is not applicable
to the proposed development since the vegetation occurring on the proposed site has not been classified as a critically endangered or endangered ecosystem in terms of the National Environmental Management Biodiversity Act of 2004 (ldquoNEMBArdquo) List of Threatened Ecosystems in Need of Protection December 2011)
13 This activity must be excluded from the application
We have noted the comments in Item 1 and have amended the revised BAR accordingly ndash see Sections A1(c) and B5(c) and (d)
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
3
NO ISSUE NAME DATE COMMENT RESPONSE 22 Originally signed
and dated declarations
M Schippers 07 April17 2 The duly dated and originally signed declarations as completed by the applicant the Environmental Assessment Practitioner and the specialists who compiled the specialist reports as part of the Environmental Impact Assessment Process must be included in the BAR to be submitted to the competent authority
The originally signed declarations will be included in the final BAR which will be submitted to your Department after the conclusion of the revised BAR comment period
23 Proof of public participation
M Schippers 07 April17 3 Proof of Public Participation 31 Proof of the public participation conducted must be included in
the BAR to be submitted to the competent authority please note that the proof must include inter alia the following
311 A copy of the newspaper advertisement (ldquonewspaper clippingrdquo) that was placed indicating the name of the newspaper and date of publication
312 Photographs showing the notice displayed on site and a copy of the text displayed on the notice and
313 With regards to the written notices provided please note the following
bull If registered mail was sent a list of the registered mail sent as obtained from the post office must be provided
bull If regular mail was sent a list of the mail sent as obtained from the post office must be provided
bull If a facsimile was sent a copy of the facsimile report must be provided
bull If an electronic mail was sent a copy of the electronic mail sent and delivery reports must be provided and
bull If a ldquomail droprdquo was done a signed register of ldquomail dropsrdquo must be provided
Proof of public participation has been included in the revised BAR as follows bull Newspaper advertisement ndash Appendix F2 bull Site notice ndash Appendix F2 and bull Written notifications ndash Appendix F3 Please note that as e-mail addresses were available for all IampAPs registered on the database the formal notification letter was sent by means of electronic mail However delivery reports were not requested as this requirement is not stated in the relevant legislation nor in any guideline document on public participation of which we are aware Thus we have included a copy of the e-mail notification sent as adequate proof of distribution Hard copies of letters were delivered to representatives of commenting authorities proof of which is also included in Appendix F3
3 COMMENTS FROM SALDANHA BAY MUNICIPALITY 31 Critical
Biodiversity Areas
Mr E Mmbadi 20170410 1 Basic Assessment Report for the Proposed New Access Roads to the Saldanha Bay Industrial Development Zone dated 07 March 2017 refers
2 Even though the site is located outside the Critical Biodiversity Area it may function as a ldquostepping stonerdquo corridor that allows for animal and plant movement across the landscape Development within such sites should consider ecological connectivity of the landscape and care should be taken not to disrupt this connectivity especially for a site surrounded by Critical Biodiversity Areas
The draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest Western Cape Biodiversity Spatial Plan became available in April 2017 and was taken into consideration in the revised BAR which will be made available for a further review and comment period
32 Cumulative Mr E Mmbadi 20170410 3 The report should highlight the potential cumulative impacts of These comments have been noted As the
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
4
NO ISSUE NAME DATE COMMENT RESPONSE impact of construction on ambient air quality
several construction activities on ambient air quality Viewing the impacts of access roads construction in isolation may only reveal limited potential impacts on the ambient air quality The report should also look at the possible release of iron ore dust trapped on vegetation into the atmosphere
construction phase of the proposed project has not yet been scheduled it cannot be assumed that it will occur while other road construction projects in the area are in progress Reference to the implications of the possible release of iron ore dust trapped on vegetation for dust generation and control during the construction phase has been incorporated into the revised BAR (see Sections F2(b) and F615) and the Construction EMP (see Section 312(b))
33 Road maintenance after completion
Mr E Mmbadi 20170410 4 In most cases after the construction work is completed the roads are handed over to local authority to maintain and service If it is envisaged to hand over the proposed access roads to Saldanha Bay Municipality (ldquoSBMrdquo) the report should acknowledge such intention Also ensure that all the requirements from SBM with regard to roads are met Please contact Manager Roads amp Stormwater (jeremyjarvissbmgovza 022 701 7049) in this regard
The design engineers have engaged with SBM regarding the future management of the roads as is indicated by the following statement in the BAR ldquoSaldanha Bay Municipality has requested that the road reserve should be registered as a separate erf which would be a portion of this propertyrdquo (see Section A2)
34 Water use during construction phase
Mr E Mmbadi 20170410 5 SBM commenced with the implementation of level 3 water restriction Please advise if there is confirmation from the municipality with regard to the supply of water to the proposed development SBM discourages the use of potable water as a dust suppression measure or for any construction purpose please indicate the developmentrsquos potential water source The use of treated effluent from the waste water treatment works could be an option Please contact Manager of Bulk Water and Sanitation (gavinwilliamasbmgovza 022 701 7047) in this regard Also consult with the Department of Water and Sanitation with regard to the water use application process
These comments regarding water conservation have been noted and relevant measures to prevent the use of potable water for dust suppression have been included in the revised BAR (see Sections F2(b) F3 and E615 of the revised BAR and Section 312(a) of the Construction EMP) Please note that the road development would only require a limited supply of water during the construction phase which the Contractor would be required to source from available resources Consultation with DWS regarding a water use application may thus not be relevant
35 Palaeontological and archaeological findings
Mr E Mmbadi 20170410 6 Please inform the Environment amp Heritage Section of the SBM on any Palaeontological and Archaeological findings for our records
This request has been included in the revised BAR (see Section F617) as well as the Construction EMP (see Section 3102(e))
4 COMMENTS FROM CAPENATURE 41 Status of
vegetation types Alana Duffell-Canham
20170410 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road 1 The proposed eastern access road passes through an area
These comments regarding the status of the vegetation types on the project site have been noted On the basis of the botanical assessment undertaken as part of the Basic Assessment process the condition of the Saldahna Limestone
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
5
NO ISSUE NAME DATE COMMENT RESPONSE covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet [been] listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6 000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
Strandveld vegetation located on the limestone ridge has indeed been described as of high botanical sensitivity in the draft BAR As to the status of the vegetation please take cognisance of DEAampDPrsquos position that only the formal classification of vegetation in terms of NEMBA is considered applicable in relation to the NEMA EIA Regulations This was in response to our indication in the draft BAR that Saldahna Flats Strandveld which is classified ldquoVulnerablerdquo should be considered ldquoEndangeredrdquo on the basis of a 2014 CapeNature status report Please refer to Comment and Response 21 above We thus have to assume that DEAampDP would consider the formal classification of Saldahna Limestone Strandveld as ldquoLeast Threatenedrdquo in terms of NEMBA as applicable
42 Critical Biodiversity Areas
Alana Duffell-Canham
20170410 2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent land cover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truth where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data
A mentioned in Response 31 above the draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest WCBSP which became available in April 2017 has been taken into consideration in the revised BAR Our observation regarding the mapping of the CBAs is that this covers a large area on the specific property and extends notably further northwards than the intact vegetation on the limestone ridge According to the ground-truthing of the botanical
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
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SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
From Mandy KulaTo Mandy KulaBcc brianwichtcoza yolandaswartmwebcoza adminbluebaylodgecoza admin3bluebaylodgecoza aduffell-canhamcapenaturecoza
Subject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENT
Date 09 March 2017 012626 PMAttachments Exec Summary - Basic Assessment Report (9Mar17)pdf
Let ndash BAR Notification (9Mar17)pdfimage4981fbPNG
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposedproject for a 30-day review and comment period from 10 March to 10 April 2017 (including one additional day to coverthe intervening public holiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
SLR Consulting (South Africa) (Pty) Ltd Page iv
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
Proposed north-south access road
Proposed eastern access road
Trunk Road 85
Main Road 559 Minor Road 7645
Saldanha Bay Industrial Development Zone
Duferco
Future Afrisam cement plant
Proposed north-south access road
Proposed eastern access road
From Ena de VilliersTo Ena de VilliersBcc gerritsmithsbmgovza malcolmwatterswesterncapegovza corvdwelsenburgcom aduffell-canhamcapenaturecoza
melaneseschipperswesterncapegovzaSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
REMINDER OF CLOSURE OF BAR COMMENT PERIODDate 04 April 2017 110142 AMAttachments image6c48afPNG
Dear SirsMadams We would like to take this opportunity to remind you of the closure of the comment period for the above-mentioned projecton 10 April 2017 Kindly submit your comments to Mandy Kula (mkulaslrconsultingcom) or myself at the contact particularsbelow You are welcome to contact us regarding any enquiries Thanks and best regardsEna
Ena de VilliersEnvironmental ConsultantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
APPENDIX F4
DRAFT BAR COMMENTS AND RESPONSES REPORT
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
1
DRAFT BASIC ASSESSMENT REPORT (BAR)
COMMENTS AND RESPONSES REPORT
Written submissions were received from the following commenting authorities and other Interested and Affected Parties (IampAPs) during the BAR comment period
SUBMITTED BY METHOD AND DATE Authorities 1 West Coast District Municipality ndash Ms Doretha Kotze Email - 29 March 2017
2 Department of Environmental Affairs and Development Planning ndash Ms M Schippers Fax - 07 April 2017
3 Saldanha Bay Municipality ndash Mr E Mmbadi Email - 10 April 2017
4 CapeNature ndash Ms Alana Duffell-Canham Email - 11 April 2017
Other IampAPs 1 Phillips Group ndash Mr Jan Phillips Email - 10 March 2017
Copies of the written comments are attached as Attachment A to this report arranged according to the order indicated in the table above The comments received are presented in Table 1 below and have been categorised as follows A Authority comments and issues 1 Comments received from West Coast District Municipality
11 Implications of Draft EMF for Saldanha region 12 Servitudes on the property
2 Comments received from Department of Environmental Affairs and Development Planning 21 Applicable listed Activities 22 Originally signed and dated declarations 23 Proof of Public Participation
3 Comments received from Saldanha Bay Municipality 31 Critical Biodiversity Areas 32 Cumulative impact of construction on ambient air quality 33 Road maintenance after completion 34 Water use during construction phase 35 Palaeontological and archaeological findings
4 Comments received from CapeNature 41 Status of vegetation types 42 Critical Biodiversity Areas 43 Implications for proposed eastern access route alignment 44 Proposed north-south access road 45 Rights reserved
B Other IampAP comments and issues 1 Comments received from Phillips Group
11 Effect of proposed project on traffic flow and businesses in the area 2 Comments received from Afrisam
21 Late submission of comments 22 South-north access road currently under construction 23 Zoning of Farm 1139 24 Suggestions for amending proposed mitigation measures 25 Details regarding activity information
No importance should be given to the order in which the categories are presented
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
2
Table 1 Summary table of comments received on the draft BAR with responses from SLR and the project technical team as appropriate
NO ISSUE NAME DATE COMMENT RESPONSE
A AUTHORITY COMMENTS AND ISSUES
1 COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY 11 Implications of
Draft EMF for Saldanha region
Doretha Kotze 20170329 1 Your letter dated 9 March 2017 and the information contained in the Draft BAR for the proposal refer
2 The Environmental Management Framework (EMF) for the Saldanha region is currently being revisited as part of the drafting of the Greater Saldanha Regional Spatial Implementation Framework by the Western Cape Provincial Department of Environmental Affairs and Development Planning It is recommended that this proposal be aligned with the outcomes of the different studies being undertaken as part of the finalisation of the EMF since Farm 1139 is situated in an area that has been identified as a Conflict Area in terms of the Urban Conservation Zone and Industrial Development Zone For more information of the EMF process kindly contact Ryan Nel at GIBB Consulting (rnelgibbcoza or Tel 011 519 4600)
We have taken the Draft EMF into consideration in the revised BAR (refer to Section D2(c)) However the document has not yet been formally adopted Thus the implied action by the Saldanha Municipality namely to resolve the conflict in the process of updating their Spatial Development Framework has not yet been undertaken Thus the formal land use status of the property remains intended for industrial development
12 Servitudes on the property
Doretha Kotze 20170329 3 Several servitudes had been registered over Farm 1139 over the years accommodating power lines water pipelines and rights of way Two bulk water pipelines of the West Coast District Municipality traversing the property in the northwest will be crossed by the proposed new access roads Care should be taken during the construction phase to prevent negative impacts on these pipelines
The project design engineers are aware of the existence of servitudes As necessary application would be made for wayleaves from the district and local municipalities if any works occur near water or other bulk services infrastructure
2 COMMENTS FROM DEPARTMENT OF ENVIRONMENTAL AFFAIRS AND DEVELOPMENT PLANNING 21 Applicable listed
activities M Schippers 20170407 The draft BAR dated March 2017 and received by this Department
on 09 March 2017 refer 1 Applicable listed activities 11 It is noted that Activity 12 of GN No R985 is being applied for 12 Please note that the abovementioned activity is not applicable
to the proposed development since the vegetation occurring on the proposed site has not been classified as a critically endangered or endangered ecosystem in terms of the National Environmental Management Biodiversity Act of 2004 (ldquoNEMBArdquo) List of Threatened Ecosystems in Need of Protection December 2011)
13 This activity must be excluded from the application
We have noted the comments in Item 1 and have amended the revised BAR accordingly ndash see Sections A1(c) and B5(c) and (d)
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
3
NO ISSUE NAME DATE COMMENT RESPONSE 22 Originally signed
and dated declarations
M Schippers 07 April17 2 The duly dated and originally signed declarations as completed by the applicant the Environmental Assessment Practitioner and the specialists who compiled the specialist reports as part of the Environmental Impact Assessment Process must be included in the BAR to be submitted to the competent authority
The originally signed declarations will be included in the final BAR which will be submitted to your Department after the conclusion of the revised BAR comment period
23 Proof of public participation
M Schippers 07 April17 3 Proof of Public Participation 31 Proof of the public participation conducted must be included in
the BAR to be submitted to the competent authority please note that the proof must include inter alia the following
311 A copy of the newspaper advertisement (ldquonewspaper clippingrdquo) that was placed indicating the name of the newspaper and date of publication
312 Photographs showing the notice displayed on site and a copy of the text displayed on the notice and
313 With regards to the written notices provided please note the following
bull If registered mail was sent a list of the registered mail sent as obtained from the post office must be provided
bull If regular mail was sent a list of the mail sent as obtained from the post office must be provided
bull If a facsimile was sent a copy of the facsimile report must be provided
bull If an electronic mail was sent a copy of the electronic mail sent and delivery reports must be provided and
bull If a ldquomail droprdquo was done a signed register of ldquomail dropsrdquo must be provided
Proof of public participation has been included in the revised BAR as follows bull Newspaper advertisement ndash Appendix F2 bull Site notice ndash Appendix F2 and bull Written notifications ndash Appendix F3 Please note that as e-mail addresses were available for all IampAPs registered on the database the formal notification letter was sent by means of electronic mail However delivery reports were not requested as this requirement is not stated in the relevant legislation nor in any guideline document on public participation of which we are aware Thus we have included a copy of the e-mail notification sent as adequate proof of distribution Hard copies of letters were delivered to representatives of commenting authorities proof of which is also included in Appendix F3
3 COMMENTS FROM SALDANHA BAY MUNICIPALITY 31 Critical
Biodiversity Areas
Mr E Mmbadi 20170410 1 Basic Assessment Report for the Proposed New Access Roads to the Saldanha Bay Industrial Development Zone dated 07 March 2017 refers
2 Even though the site is located outside the Critical Biodiversity Area it may function as a ldquostepping stonerdquo corridor that allows for animal and plant movement across the landscape Development within such sites should consider ecological connectivity of the landscape and care should be taken not to disrupt this connectivity especially for a site surrounded by Critical Biodiversity Areas
The draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest Western Cape Biodiversity Spatial Plan became available in April 2017 and was taken into consideration in the revised BAR which will be made available for a further review and comment period
32 Cumulative Mr E Mmbadi 20170410 3 The report should highlight the potential cumulative impacts of These comments have been noted As the
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
4
NO ISSUE NAME DATE COMMENT RESPONSE impact of construction on ambient air quality
several construction activities on ambient air quality Viewing the impacts of access roads construction in isolation may only reveal limited potential impacts on the ambient air quality The report should also look at the possible release of iron ore dust trapped on vegetation into the atmosphere
construction phase of the proposed project has not yet been scheduled it cannot be assumed that it will occur while other road construction projects in the area are in progress Reference to the implications of the possible release of iron ore dust trapped on vegetation for dust generation and control during the construction phase has been incorporated into the revised BAR (see Sections F2(b) and F615) and the Construction EMP (see Section 312(b))
33 Road maintenance after completion
Mr E Mmbadi 20170410 4 In most cases after the construction work is completed the roads are handed over to local authority to maintain and service If it is envisaged to hand over the proposed access roads to Saldanha Bay Municipality (ldquoSBMrdquo) the report should acknowledge such intention Also ensure that all the requirements from SBM with regard to roads are met Please contact Manager Roads amp Stormwater (jeremyjarvissbmgovza 022 701 7049) in this regard
The design engineers have engaged with SBM regarding the future management of the roads as is indicated by the following statement in the BAR ldquoSaldanha Bay Municipality has requested that the road reserve should be registered as a separate erf which would be a portion of this propertyrdquo (see Section A2)
34 Water use during construction phase
Mr E Mmbadi 20170410 5 SBM commenced with the implementation of level 3 water restriction Please advise if there is confirmation from the municipality with regard to the supply of water to the proposed development SBM discourages the use of potable water as a dust suppression measure or for any construction purpose please indicate the developmentrsquos potential water source The use of treated effluent from the waste water treatment works could be an option Please contact Manager of Bulk Water and Sanitation (gavinwilliamasbmgovza 022 701 7047) in this regard Also consult with the Department of Water and Sanitation with regard to the water use application process
These comments regarding water conservation have been noted and relevant measures to prevent the use of potable water for dust suppression have been included in the revised BAR (see Sections F2(b) F3 and E615 of the revised BAR and Section 312(a) of the Construction EMP) Please note that the road development would only require a limited supply of water during the construction phase which the Contractor would be required to source from available resources Consultation with DWS regarding a water use application may thus not be relevant
35 Palaeontological and archaeological findings
Mr E Mmbadi 20170410 6 Please inform the Environment amp Heritage Section of the SBM on any Palaeontological and Archaeological findings for our records
This request has been included in the revised BAR (see Section F617) as well as the Construction EMP (see Section 3102(e))
4 COMMENTS FROM CAPENATURE 41 Status of
vegetation types Alana Duffell-Canham
20170410 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road 1 The proposed eastern access road passes through an area
These comments regarding the status of the vegetation types on the project site have been noted On the basis of the botanical assessment undertaken as part of the Basic Assessment process the condition of the Saldahna Limestone
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
5
NO ISSUE NAME DATE COMMENT RESPONSE covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet [been] listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6 000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
Strandveld vegetation located on the limestone ridge has indeed been described as of high botanical sensitivity in the draft BAR As to the status of the vegetation please take cognisance of DEAampDPrsquos position that only the formal classification of vegetation in terms of NEMBA is considered applicable in relation to the NEMA EIA Regulations This was in response to our indication in the draft BAR that Saldahna Flats Strandveld which is classified ldquoVulnerablerdquo should be considered ldquoEndangeredrdquo on the basis of a 2014 CapeNature status report Please refer to Comment and Response 21 above We thus have to assume that DEAampDP would consider the formal classification of Saldahna Limestone Strandveld as ldquoLeast Threatenedrdquo in terms of NEMBA as applicable
42 Critical Biodiversity Areas
Alana Duffell-Canham
20170410 2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent land cover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truth where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data
A mentioned in Response 31 above the draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest WCBSP which became available in April 2017 has been taken into consideration in the revised BAR Our observation regarding the mapping of the CBAs is that this covers a large area on the specific property and extends notably further northwards than the intact vegetation on the limestone ridge According to the ground-truthing of the botanical
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
SLR Consulting (South Africa) (Pty) Ltd Page iv
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
Proposed north-south access road
Proposed eastern access road
Trunk Road 85
Main Road 559 Minor Road 7645
Saldanha Bay Industrial Development Zone
Duferco
Future Afrisam cement plant
Proposed north-south access road
Proposed eastern access road
From Ena de VilliersTo Ena de VilliersBcc gerritsmithsbmgovza malcolmwatterswesterncapegovza corvdwelsenburgcom aduffell-canhamcapenaturecoza
melaneseschipperswesterncapegovzaSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
REMINDER OF CLOSURE OF BAR COMMENT PERIODDate 04 April 2017 110142 AMAttachments image6c48afPNG
Dear SirsMadams We would like to take this opportunity to remind you of the closure of the comment period for the above-mentioned projecton 10 April 2017 Kindly submit your comments to Mandy Kula (mkulaslrconsultingcom) or myself at the contact particularsbelow You are welcome to contact us regarding any enquiries Thanks and best regardsEna
Ena de VilliersEnvironmental ConsultantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
APPENDIX F4
DRAFT BAR COMMENTS AND RESPONSES REPORT
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
1
DRAFT BASIC ASSESSMENT REPORT (BAR)
COMMENTS AND RESPONSES REPORT
Written submissions were received from the following commenting authorities and other Interested and Affected Parties (IampAPs) during the BAR comment period
SUBMITTED BY METHOD AND DATE Authorities 1 West Coast District Municipality ndash Ms Doretha Kotze Email - 29 March 2017
2 Department of Environmental Affairs and Development Planning ndash Ms M Schippers Fax - 07 April 2017
3 Saldanha Bay Municipality ndash Mr E Mmbadi Email - 10 April 2017
4 CapeNature ndash Ms Alana Duffell-Canham Email - 11 April 2017
Other IampAPs 1 Phillips Group ndash Mr Jan Phillips Email - 10 March 2017
Copies of the written comments are attached as Attachment A to this report arranged according to the order indicated in the table above The comments received are presented in Table 1 below and have been categorised as follows A Authority comments and issues 1 Comments received from West Coast District Municipality
11 Implications of Draft EMF for Saldanha region 12 Servitudes on the property
2 Comments received from Department of Environmental Affairs and Development Planning 21 Applicable listed Activities 22 Originally signed and dated declarations 23 Proof of Public Participation
3 Comments received from Saldanha Bay Municipality 31 Critical Biodiversity Areas 32 Cumulative impact of construction on ambient air quality 33 Road maintenance after completion 34 Water use during construction phase 35 Palaeontological and archaeological findings
4 Comments received from CapeNature 41 Status of vegetation types 42 Critical Biodiversity Areas 43 Implications for proposed eastern access route alignment 44 Proposed north-south access road 45 Rights reserved
B Other IampAP comments and issues 1 Comments received from Phillips Group
11 Effect of proposed project on traffic flow and businesses in the area 2 Comments received from Afrisam
21 Late submission of comments 22 South-north access road currently under construction 23 Zoning of Farm 1139 24 Suggestions for amending proposed mitigation measures 25 Details regarding activity information
No importance should be given to the order in which the categories are presented
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
2
Table 1 Summary table of comments received on the draft BAR with responses from SLR and the project technical team as appropriate
NO ISSUE NAME DATE COMMENT RESPONSE
A AUTHORITY COMMENTS AND ISSUES
1 COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY 11 Implications of
Draft EMF for Saldanha region
Doretha Kotze 20170329 1 Your letter dated 9 March 2017 and the information contained in the Draft BAR for the proposal refer
2 The Environmental Management Framework (EMF) for the Saldanha region is currently being revisited as part of the drafting of the Greater Saldanha Regional Spatial Implementation Framework by the Western Cape Provincial Department of Environmental Affairs and Development Planning It is recommended that this proposal be aligned with the outcomes of the different studies being undertaken as part of the finalisation of the EMF since Farm 1139 is situated in an area that has been identified as a Conflict Area in terms of the Urban Conservation Zone and Industrial Development Zone For more information of the EMF process kindly contact Ryan Nel at GIBB Consulting (rnelgibbcoza or Tel 011 519 4600)
We have taken the Draft EMF into consideration in the revised BAR (refer to Section D2(c)) However the document has not yet been formally adopted Thus the implied action by the Saldanha Municipality namely to resolve the conflict in the process of updating their Spatial Development Framework has not yet been undertaken Thus the formal land use status of the property remains intended for industrial development
12 Servitudes on the property
Doretha Kotze 20170329 3 Several servitudes had been registered over Farm 1139 over the years accommodating power lines water pipelines and rights of way Two bulk water pipelines of the West Coast District Municipality traversing the property in the northwest will be crossed by the proposed new access roads Care should be taken during the construction phase to prevent negative impacts on these pipelines
The project design engineers are aware of the existence of servitudes As necessary application would be made for wayleaves from the district and local municipalities if any works occur near water or other bulk services infrastructure
2 COMMENTS FROM DEPARTMENT OF ENVIRONMENTAL AFFAIRS AND DEVELOPMENT PLANNING 21 Applicable listed
activities M Schippers 20170407 The draft BAR dated March 2017 and received by this Department
on 09 March 2017 refer 1 Applicable listed activities 11 It is noted that Activity 12 of GN No R985 is being applied for 12 Please note that the abovementioned activity is not applicable
to the proposed development since the vegetation occurring on the proposed site has not been classified as a critically endangered or endangered ecosystem in terms of the National Environmental Management Biodiversity Act of 2004 (ldquoNEMBArdquo) List of Threatened Ecosystems in Need of Protection December 2011)
13 This activity must be excluded from the application
We have noted the comments in Item 1 and have amended the revised BAR accordingly ndash see Sections A1(c) and B5(c) and (d)
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
3
NO ISSUE NAME DATE COMMENT RESPONSE 22 Originally signed
and dated declarations
M Schippers 07 April17 2 The duly dated and originally signed declarations as completed by the applicant the Environmental Assessment Practitioner and the specialists who compiled the specialist reports as part of the Environmental Impact Assessment Process must be included in the BAR to be submitted to the competent authority
The originally signed declarations will be included in the final BAR which will be submitted to your Department after the conclusion of the revised BAR comment period
23 Proof of public participation
M Schippers 07 April17 3 Proof of Public Participation 31 Proof of the public participation conducted must be included in
the BAR to be submitted to the competent authority please note that the proof must include inter alia the following
311 A copy of the newspaper advertisement (ldquonewspaper clippingrdquo) that was placed indicating the name of the newspaper and date of publication
312 Photographs showing the notice displayed on site and a copy of the text displayed on the notice and
313 With regards to the written notices provided please note the following
bull If registered mail was sent a list of the registered mail sent as obtained from the post office must be provided
bull If regular mail was sent a list of the mail sent as obtained from the post office must be provided
bull If a facsimile was sent a copy of the facsimile report must be provided
bull If an electronic mail was sent a copy of the electronic mail sent and delivery reports must be provided and
bull If a ldquomail droprdquo was done a signed register of ldquomail dropsrdquo must be provided
Proof of public participation has been included in the revised BAR as follows bull Newspaper advertisement ndash Appendix F2 bull Site notice ndash Appendix F2 and bull Written notifications ndash Appendix F3 Please note that as e-mail addresses were available for all IampAPs registered on the database the formal notification letter was sent by means of electronic mail However delivery reports were not requested as this requirement is not stated in the relevant legislation nor in any guideline document on public participation of which we are aware Thus we have included a copy of the e-mail notification sent as adequate proof of distribution Hard copies of letters were delivered to representatives of commenting authorities proof of which is also included in Appendix F3
3 COMMENTS FROM SALDANHA BAY MUNICIPALITY 31 Critical
Biodiversity Areas
Mr E Mmbadi 20170410 1 Basic Assessment Report for the Proposed New Access Roads to the Saldanha Bay Industrial Development Zone dated 07 March 2017 refers
2 Even though the site is located outside the Critical Biodiversity Area it may function as a ldquostepping stonerdquo corridor that allows for animal and plant movement across the landscape Development within such sites should consider ecological connectivity of the landscape and care should be taken not to disrupt this connectivity especially for a site surrounded by Critical Biodiversity Areas
The draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest Western Cape Biodiversity Spatial Plan became available in April 2017 and was taken into consideration in the revised BAR which will be made available for a further review and comment period
32 Cumulative Mr E Mmbadi 20170410 3 The report should highlight the potential cumulative impacts of These comments have been noted As the
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
4
NO ISSUE NAME DATE COMMENT RESPONSE impact of construction on ambient air quality
several construction activities on ambient air quality Viewing the impacts of access roads construction in isolation may only reveal limited potential impacts on the ambient air quality The report should also look at the possible release of iron ore dust trapped on vegetation into the atmosphere
construction phase of the proposed project has not yet been scheduled it cannot be assumed that it will occur while other road construction projects in the area are in progress Reference to the implications of the possible release of iron ore dust trapped on vegetation for dust generation and control during the construction phase has been incorporated into the revised BAR (see Sections F2(b) and F615) and the Construction EMP (see Section 312(b))
33 Road maintenance after completion
Mr E Mmbadi 20170410 4 In most cases after the construction work is completed the roads are handed over to local authority to maintain and service If it is envisaged to hand over the proposed access roads to Saldanha Bay Municipality (ldquoSBMrdquo) the report should acknowledge such intention Also ensure that all the requirements from SBM with regard to roads are met Please contact Manager Roads amp Stormwater (jeremyjarvissbmgovza 022 701 7049) in this regard
The design engineers have engaged with SBM regarding the future management of the roads as is indicated by the following statement in the BAR ldquoSaldanha Bay Municipality has requested that the road reserve should be registered as a separate erf which would be a portion of this propertyrdquo (see Section A2)
34 Water use during construction phase
Mr E Mmbadi 20170410 5 SBM commenced with the implementation of level 3 water restriction Please advise if there is confirmation from the municipality with regard to the supply of water to the proposed development SBM discourages the use of potable water as a dust suppression measure or for any construction purpose please indicate the developmentrsquos potential water source The use of treated effluent from the waste water treatment works could be an option Please contact Manager of Bulk Water and Sanitation (gavinwilliamasbmgovza 022 701 7047) in this regard Also consult with the Department of Water and Sanitation with regard to the water use application process
These comments regarding water conservation have been noted and relevant measures to prevent the use of potable water for dust suppression have been included in the revised BAR (see Sections F2(b) F3 and E615 of the revised BAR and Section 312(a) of the Construction EMP) Please note that the road development would only require a limited supply of water during the construction phase which the Contractor would be required to source from available resources Consultation with DWS regarding a water use application may thus not be relevant
35 Palaeontological and archaeological findings
Mr E Mmbadi 20170410 6 Please inform the Environment amp Heritage Section of the SBM on any Palaeontological and Archaeological findings for our records
This request has been included in the revised BAR (see Section F617) as well as the Construction EMP (see Section 3102(e))
4 COMMENTS FROM CAPENATURE 41 Status of
vegetation types Alana Duffell-Canham
20170410 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road 1 The proposed eastern access road passes through an area
These comments regarding the status of the vegetation types on the project site have been noted On the basis of the botanical assessment undertaken as part of the Basic Assessment process the condition of the Saldahna Limestone
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
5
NO ISSUE NAME DATE COMMENT RESPONSE covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet [been] listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6 000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
Strandveld vegetation located on the limestone ridge has indeed been described as of high botanical sensitivity in the draft BAR As to the status of the vegetation please take cognisance of DEAampDPrsquos position that only the formal classification of vegetation in terms of NEMBA is considered applicable in relation to the NEMA EIA Regulations This was in response to our indication in the draft BAR that Saldahna Flats Strandveld which is classified ldquoVulnerablerdquo should be considered ldquoEndangeredrdquo on the basis of a 2014 CapeNature status report Please refer to Comment and Response 21 above We thus have to assume that DEAampDP would consider the formal classification of Saldahna Limestone Strandveld as ldquoLeast Threatenedrdquo in terms of NEMBA as applicable
42 Critical Biodiversity Areas
Alana Duffell-Canham
20170410 2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent land cover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truth where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data
A mentioned in Response 31 above the draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest WCBSP which became available in April 2017 has been taken into consideration in the revised BAR Our observation regarding the mapping of the CBAs is that this covers a large area on the specific property and extends notably further northwards than the intact vegetation on the limestone ridge According to the ground-truthing of the botanical
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
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SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
Proposed north-south access road
Proposed eastern access road
Trunk Road 85
Main Road 559 Minor Road 7645
Saldanha Bay Industrial Development Zone
Duferco
Future Afrisam cement plant
Proposed north-south access road
Proposed eastern access road
From Ena de VilliersTo Ena de VilliersBcc gerritsmithsbmgovza malcolmwatterswesterncapegovza corvdwelsenburgcom aduffell-canhamcapenaturecoza
melaneseschipperswesterncapegovzaSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
REMINDER OF CLOSURE OF BAR COMMENT PERIODDate 04 April 2017 110142 AMAttachments image6c48afPNG
Dear SirsMadams We would like to take this opportunity to remind you of the closure of the comment period for the above-mentioned projecton 10 April 2017 Kindly submit your comments to Mandy Kula (mkulaslrconsultingcom) or myself at the contact particularsbelow You are welcome to contact us regarding any enquiries Thanks and best regardsEna
Ena de VilliersEnvironmental ConsultantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
APPENDIX F4
DRAFT BAR COMMENTS AND RESPONSES REPORT
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
1
DRAFT BASIC ASSESSMENT REPORT (BAR)
COMMENTS AND RESPONSES REPORT
Written submissions were received from the following commenting authorities and other Interested and Affected Parties (IampAPs) during the BAR comment period
SUBMITTED BY METHOD AND DATE Authorities 1 West Coast District Municipality ndash Ms Doretha Kotze Email - 29 March 2017
2 Department of Environmental Affairs and Development Planning ndash Ms M Schippers Fax - 07 April 2017
3 Saldanha Bay Municipality ndash Mr E Mmbadi Email - 10 April 2017
4 CapeNature ndash Ms Alana Duffell-Canham Email - 11 April 2017
Other IampAPs 1 Phillips Group ndash Mr Jan Phillips Email - 10 March 2017
Copies of the written comments are attached as Attachment A to this report arranged according to the order indicated in the table above The comments received are presented in Table 1 below and have been categorised as follows A Authority comments and issues 1 Comments received from West Coast District Municipality
11 Implications of Draft EMF for Saldanha region 12 Servitudes on the property
2 Comments received from Department of Environmental Affairs and Development Planning 21 Applicable listed Activities 22 Originally signed and dated declarations 23 Proof of Public Participation
3 Comments received from Saldanha Bay Municipality 31 Critical Biodiversity Areas 32 Cumulative impact of construction on ambient air quality 33 Road maintenance after completion 34 Water use during construction phase 35 Palaeontological and archaeological findings
4 Comments received from CapeNature 41 Status of vegetation types 42 Critical Biodiversity Areas 43 Implications for proposed eastern access route alignment 44 Proposed north-south access road 45 Rights reserved
B Other IampAP comments and issues 1 Comments received from Phillips Group
11 Effect of proposed project on traffic flow and businesses in the area 2 Comments received from Afrisam
21 Late submission of comments 22 South-north access road currently under construction 23 Zoning of Farm 1139 24 Suggestions for amending proposed mitigation measures 25 Details regarding activity information
No importance should be given to the order in which the categories are presented
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
2
Table 1 Summary table of comments received on the draft BAR with responses from SLR and the project technical team as appropriate
NO ISSUE NAME DATE COMMENT RESPONSE
A AUTHORITY COMMENTS AND ISSUES
1 COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY 11 Implications of
Draft EMF for Saldanha region
Doretha Kotze 20170329 1 Your letter dated 9 March 2017 and the information contained in the Draft BAR for the proposal refer
2 The Environmental Management Framework (EMF) for the Saldanha region is currently being revisited as part of the drafting of the Greater Saldanha Regional Spatial Implementation Framework by the Western Cape Provincial Department of Environmental Affairs and Development Planning It is recommended that this proposal be aligned with the outcomes of the different studies being undertaken as part of the finalisation of the EMF since Farm 1139 is situated in an area that has been identified as a Conflict Area in terms of the Urban Conservation Zone and Industrial Development Zone For more information of the EMF process kindly contact Ryan Nel at GIBB Consulting (rnelgibbcoza or Tel 011 519 4600)
We have taken the Draft EMF into consideration in the revised BAR (refer to Section D2(c)) However the document has not yet been formally adopted Thus the implied action by the Saldanha Municipality namely to resolve the conflict in the process of updating their Spatial Development Framework has not yet been undertaken Thus the formal land use status of the property remains intended for industrial development
12 Servitudes on the property
Doretha Kotze 20170329 3 Several servitudes had been registered over Farm 1139 over the years accommodating power lines water pipelines and rights of way Two bulk water pipelines of the West Coast District Municipality traversing the property in the northwest will be crossed by the proposed new access roads Care should be taken during the construction phase to prevent negative impacts on these pipelines
The project design engineers are aware of the existence of servitudes As necessary application would be made for wayleaves from the district and local municipalities if any works occur near water or other bulk services infrastructure
2 COMMENTS FROM DEPARTMENT OF ENVIRONMENTAL AFFAIRS AND DEVELOPMENT PLANNING 21 Applicable listed
activities M Schippers 20170407 The draft BAR dated March 2017 and received by this Department
on 09 March 2017 refer 1 Applicable listed activities 11 It is noted that Activity 12 of GN No R985 is being applied for 12 Please note that the abovementioned activity is not applicable
to the proposed development since the vegetation occurring on the proposed site has not been classified as a critically endangered or endangered ecosystem in terms of the National Environmental Management Biodiversity Act of 2004 (ldquoNEMBArdquo) List of Threatened Ecosystems in Need of Protection December 2011)
13 This activity must be excluded from the application
We have noted the comments in Item 1 and have amended the revised BAR accordingly ndash see Sections A1(c) and B5(c) and (d)
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3
NO ISSUE NAME DATE COMMENT RESPONSE 22 Originally signed
and dated declarations
M Schippers 07 April17 2 The duly dated and originally signed declarations as completed by the applicant the Environmental Assessment Practitioner and the specialists who compiled the specialist reports as part of the Environmental Impact Assessment Process must be included in the BAR to be submitted to the competent authority
The originally signed declarations will be included in the final BAR which will be submitted to your Department after the conclusion of the revised BAR comment period
23 Proof of public participation
M Schippers 07 April17 3 Proof of Public Participation 31 Proof of the public participation conducted must be included in
the BAR to be submitted to the competent authority please note that the proof must include inter alia the following
311 A copy of the newspaper advertisement (ldquonewspaper clippingrdquo) that was placed indicating the name of the newspaper and date of publication
312 Photographs showing the notice displayed on site and a copy of the text displayed on the notice and
313 With regards to the written notices provided please note the following
bull If registered mail was sent a list of the registered mail sent as obtained from the post office must be provided
bull If regular mail was sent a list of the mail sent as obtained from the post office must be provided
bull If a facsimile was sent a copy of the facsimile report must be provided
bull If an electronic mail was sent a copy of the electronic mail sent and delivery reports must be provided and
bull If a ldquomail droprdquo was done a signed register of ldquomail dropsrdquo must be provided
Proof of public participation has been included in the revised BAR as follows bull Newspaper advertisement ndash Appendix F2 bull Site notice ndash Appendix F2 and bull Written notifications ndash Appendix F3 Please note that as e-mail addresses were available for all IampAPs registered on the database the formal notification letter was sent by means of electronic mail However delivery reports were not requested as this requirement is not stated in the relevant legislation nor in any guideline document on public participation of which we are aware Thus we have included a copy of the e-mail notification sent as adequate proof of distribution Hard copies of letters were delivered to representatives of commenting authorities proof of which is also included in Appendix F3
3 COMMENTS FROM SALDANHA BAY MUNICIPALITY 31 Critical
Biodiversity Areas
Mr E Mmbadi 20170410 1 Basic Assessment Report for the Proposed New Access Roads to the Saldanha Bay Industrial Development Zone dated 07 March 2017 refers
2 Even though the site is located outside the Critical Biodiversity Area it may function as a ldquostepping stonerdquo corridor that allows for animal and plant movement across the landscape Development within such sites should consider ecological connectivity of the landscape and care should be taken not to disrupt this connectivity especially for a site surrounded by Critical Biodiversity Areas
The draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest Western Cape Biodiversity Spatial Plan became available in April 2017 and was taken into consideration in the revised BAR which will be made available for a further review and comment period
32 Cumulative Mr E Mmbadi 20170410 3 The report should highlight the potential cumulative impacts of These comments have been noted As the
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NO ISSUE NAME DATE COMMENT RESPONSE impact of construction on ambient air quality
several construction activities on ambient air quality Viewing the impacts of access roads construction in isolation may only reveal limited potential impacts on the ambient air quality The report should also look at the possible release of iron ore dust trapped on vegetation into the atmosphere
construction phase of the proposed project has not yet been scheduled it cannot be assumed that it will occur while other road construction projects in the area are in progress Reference to the implications of the possible release of iron ore dust trapped on vegetation for dust generation and control during the construction phase has been incorporated into the revised BAR (see Sections F2(b) and F615) and the Construction EMP (see Section 312(b))
33 Road maintenance after completion
Mr E Mmbadi 20170410 4 In most cases after the construction work is completed the roads are handed over to local authority to maintain and service If it is envisaged to hand over the proposed access roads to Saldanha Bay Municipality (ldquoSBMrdquo) the report should acknowledge such intention Also ensure that all the requirements from SBM with regard to roads are met Please contact Manager Roads amp Stormwater (jeremyjarvissbmgovza 022 701 7049) in this regard
The design engineers have engaged with SBM regarding the future management of the roads as is indicated by the following statement in the BAR ldquoSaldanha Bay Municipality has requested that the road reserve should be registered as a separate erf which would be a portion of this propertyrdquo (see Section A2)
34 Water use during construction phase
Mr E Mmbadi 20170410 5 SBM commenced with the implementation of level 3 water restriction Please advise if there is confirmation from the municipality with regard to the supply of water to the proposed development SBM discourages the use of potable water as a dust suppression measure or for any construction purpose please indicate the developmentrsquos potential water source The use of treated effluent from the waste water treatment works could be an option Please contact Manager of Bulk Water and Sanitation (gavinwilliamasbmgovza 022 701 7047) in this regard Also consult with the Department of Water and Sanitation with regard to the water use application process
These comments regarding water conservation have been noted and relevant measures to prevent the use of potable water for dust suppression have been included in the revised BAR (see Sections F2(b) F3 and E615 of the revised BAR and Section 312(a) of the Construction EMP) Please note that the road development would only require a limited supply of water during the construction phase which the Contractor would be required to source from available resources Consultation with DWS regarding a water use application may thus not be relevant
35 Palaeontological and archaeological findings
Mr E Mmbadi 20170410 6 Please inform the Environment amp Heritage Section of the SBM on any Palaeontological and Archaeological findings for our records
This request has been included in the revised BAR (see Section F617) as well as the Construction EMP (see Section 3102(e))
4 COMMENTS FROM CAPENATURE 41 Status of
vegetation types Alana Duffell-Canham
20170410 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road 1 The proposed eastern access road passes through an area
These comments regarding the status of the vegetation types on the project site have been noted On the basis of the botanical assessment undertaken as part of the Basic Assessment process the condition of the Saldahna Limestone
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
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5
NO ISSUE NAME DATE COMMENT RESPONSE covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet [been] listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6 000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
Strandveld vegetation located on the limestone ridge has indeed been described as of high botanical sensitivity in the draft BAR As to the status of the vegetation please take cognisance of DEAampDPrsquos position that only the formal classification of vegetation in terms of NEMBA is considered applicable in relation to the NEMA EIA Regulations This was in response to our indication in the draft BAR that Saldahna Flats Strandveld which is classified ldquoVulnerablerdquo should be considered ldquoEndangeredrdquo on the basis of a 2014 CapeNature status report Please refer to Comment and Response 21 above We thus have to assume that DEAampDP would consider the formal classification of Saldahna Limestone Strandveld as ldquoLeast Threatenedrdquo in terms of NEMBA as applicable
42 Critical Biodiversity Areas
Alana Duffell-Canham
20170410 2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent land cover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truth where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data
A mentioned in Response 31 above the draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest WCBSP which became available in April 2017 has been taken into consideration in the revised BAR Our observation regarding the mapping of the CBAs is that this covers a large area on the specific property and extends notably further northwards than the intact vegetation on the limestone ridge According to the ground-truthing of the botanical
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
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8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
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SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
Proposed north-south access road
Proposed eastern access road
Trunk Road 85
Main Road 559 Minor Road 7645
Saldanha Bay Industrial Development Zone
Duferco
Future Afrisam cement plant
Proposed north-south access road
Proposed eastern access road
From Ena de VilliersTo Ena de VilliersBcc gerritsmithsbmgovza malcolmwatterswesterncapegovza corvdwelsenburgcom aduffell-canhamcapenaturecoza
melaneseschipperswesterncapegovzaSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
REMINDER OF CLOSURE OF BAR COMMENT PERIODDate 04 April 2017 110142 AMAttachments image6c48afPNG
Dear SirsMadams We would like to take this opportunity to remind you of the closure of the comment period for the above-mentioned projecton 10 April 2017 Kindly submit your comments to Mandy Kula (mkulaslrconsultingcom) or myself at the contact particularsbelow You are welcome to contact us regarding any enquiries Thanks and best regardsEna
Ena de VilliersEnvironmental ConsultantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
APPENDIX F4
DRAFT BAR COMMENTS AND RESPONSES REPORT
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
1
DRAFT BASIC ASSESSMENT REPORT (BAR)
COMMENTS AND RESPONSES REPORT
Written submissions were received from the following commenting authorities and other Interested and Affected Parties (IampAPs) during the BAR comment period
SUBMITTED BY METHOD AND DATE Authorities 1 West Coast District Municipality ndash Ms Doretha Kotze Email - 29 March 2017
2 Department of Environmental Affairs and Development Planning ndash Ms M Schippers Fax - 07 April 2017
3 Saldanha Bay Municipality ndash Mr E Mmbadi Email - 10 April 2017
4 CapeNature ndash Ms Alana Duffell-Canham Email - 11 April 2017
Other IampAPs 1 Phillips Group ndash Mr Jan Phillips Email - 10 March 2017
Copies of the written comments are attached as Attachment A to this report arranged according to the order indicated in the table above The comments received are presented in Table 1 below and have been categorised as follows A Authority comments and issues 1 Comments received from West Coast District Municipality
11 Implications of Draft EMF for Saldanha region 12 Servitudes on the property
2 Comments received from Department of Environmental Affairs and Development Planning 21 Applicable listed Activities 22 Originally signed and dated declarations 23 Proof of Public Participation
3 Comments received from Saldanha Bay Municipality 31 Critical Biodiversity Areas 32 Cumulative impact of construction on ambient air quality 33 Road maintenance after completion 34 Water use during construction phase 35 Palaeontological and archaeological findings
4 Comments received from CapeNature 41 Status of vegetation types 42 Critical Biodiversity Areas 43 Implications for proposed eastern access route alignment 44 Proposed north-south access road 45 Rights reserved
B Other IampAP comments and issues 1 Comments received from Phillips Group
11 Effect of proposed project on traffic flow and businesses in the area 2 Comments received from Afrisam
21 Late submission of comments 22 South-north access road currently under construction 23 Zoning of Farm 1139 24 Suggestions for amending proposed mitigation measures 25 Details regarding activity information
No importance should be given to the order in which the categories are presented
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
2
Table 1 Summary table of comments received on the draft BAR with responses from SLR and the project technical team as appropriate
NO ISSUE NAME DATE COMMENT RESPONSE
A AUTHORITY COMMENTS AND ISSUES
1 COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY 11 Implications of
Draft EMF for Saldanha region
Doretha Kotze 20170329 1 Your letter dated 9 March 2017 and the information contained in the Draft BAR for the proposal refer
2 The Environmental Management Framework (EMF) for the Saldanha region is currently being revisited as part of the drafting of the Greater Saldanha Regional Spatial Implementation Framework by the Western Cape Provincial Department of Environmental Affairs and Development Planning It is recommended that this proposal be aligned with the outcomes of the different studies being undertaken as part of the finalisation of the EMF since Farm 1139 is situated in an area that has been identified as a Conflict Area in terms of the Urban Conservation Zone and Industrial Development Zone For more information of the EMF process kindly contact Ryan Nel at GIBB Consulting (rnelgibbcoza or Tel 011 519 4600)
We have taken the Draft EMF into consideration in the revised BAR (refer to Section D2(c)) However the document has not yet been formally adopted Thus the implied action by the Saldanha Municipality namely to resolve the conflict in the process of updating their Spatial Development Framework has not yet been undertaken Thus the formal land use status of the property remains intended for industrial development
12 Servitudes on the property
Doretha Kotze 20170329 3 Several servitudes had been registered over Farm 1139 over the years accommodating power lines water pipelines and rights of way Two bulk water pipelines of the West Coast District Municipality traversing the property in the northwest will be crossed by the proposed new access roads Care should be taken during the construction phase to prevent negative impacts on these pipelines
The project design engineers are aware of the existence of servitudes As necessary application would be made for wayleaves from the district and local municipalities if any works occur near water or other bulk services infrastructure
2 COMMENTS FROM DEPARTMENT OF ENVIRONMENTAL AFFAIRS AND DEVELOPMENT PLANNING 21 Applicable listed
activities M Schippers 20170407 The draft BAR dated March 2017 and received by this Department
on 09 March 2017 refer 1 Applicable listed activities 11 It is noted that Activity 12 of GN No R985 is being applied for 12 Please note that the abovementioned activity is not applicable
to the proposed development since the vegetation occurring on the proposed site has not been classified as a critically endangered or endangered ecosystem in terms of the National Environmental Management Biodiversity Act of 2004 (ldquoNEMBArdquo) List of Threatened Ecosystems in Need of Protection December 2011)
13 This activity must be excluded from the application
We have noted the comments in Item 1 and have amended the revised BAR accordingly ndash see Sections A1(c) and B5(c) and (d)
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
3
NO ISSUE NAME DATE COMMENT RESPONSE 22 Originally signed
and dated declarations
M Schippers 07 April17 2 The duly dated and originally signed declarations as completed by the applicant the Environmental Assessment Practitioner and the specialists who compiled the specialist reports as part of the Environmental Impact Assessment Process must be included in the BAR to be submitted to the competent authority
The originally signed declarations will be included in the final BAR which will be submitted to your Department after the conclusion of the revised BAR comment period
23 Proof of public participation
M Schippers 07 April17 3 Proof of Public Participation 31 Proof of the public participation conducted must be included in
the BAR to be submitted to the competent authority please note that the proof must include inter alia the following
311 A copy of the newspaper advertisement (ldquonewspaper clippingrdquo) that was placed indicating the name of the newspaper and date of publication
312 Photographs showing the notice displayed on site and a copy of the text displayed on the notice and
313 With regards to the written notices provided please note the following
bull If registered mail was sent a list of the registered mail sent as obtained from the post office must be provided
bull If regular mail was sent a list of the mail sent as obtained from the post office must be provided
bull If a facsimile was sent a copy of the facsimile report must be provided
bull If an electronic mail was sent a copy of the electronic mail sent and delivery reports must be provided and
bull If a ldquomail droprdquo was done a signed register of ldquomail dropsrdquo must be provided
Proof of public participation has been included in the revised BAR as follows bull Newspaper advertisement ndash Appendix F2 bull Site notice ndash Appendix F2 and bull Written notifications ndash Appendix F3 Please note that as e-mail addresses were available for all IampAPs registered on the database the formal notification letter was sent by means of electronic mail However delivery reports were not requested as this requirement is not stated in the relevant legislation nor in any guideline document on public participation of which we are aware Thus we have included a copy of the e-mail notification sent as adequate proof of distribution Hard copies of letters were delivered to representatives of commenting authorities proof of which is also included in Appendix F3
3 COMMENTS FROM SALDANHA BAY MUNICIPALITY 31 Critical
Biodiversity Areas
Mr E Mmbadi 20170410 1 Basic Assessment Report for the Proposed New Access Roads to the Saldanha Bay Industrial Development Zone dated 07 March 2017 refers
2 Even though the site is located outside the Critical Biodiversity Area it may function as a ldquostepping stonerdquo corridor that allows for animal and plant movement across the landscape Development within such sites should consider ecological connectivity of the landscape and care should be taken not to disrupt this connectivity especially for a site surrounded by Critical Biodiversity Areas
The draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest Western Cape Biodiversity Spatial Plan became available in April 2017 and was taken into consideration in the revised BAR which will be made available for a further review and comment period
32 Cumulative Mr E Mmbadi 20170410 3 The report should highlight the potential cumulative impacts of These comments have been noted As the
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
4
NO ISSUE NAME DATE COMMENT RESPONSE impact of construction on ambient air quality
several construction activities on ambient air quality Viewing the impacts of access roads construction in isolation may only reveal limited potential impacts on the ambient air quality The report should also look at the possible release of iron ore dust trapped on vegetation into the atmosphere
construction phase of the proposed project has not yet been scheduled it cannot be assumed that it will occur while other road construction projects in the area are in progress Reference to the implications of the possible release of iron ore dust trapped on vegetation for dust generation and control during the construction phase has been incorporated into the revised BAR (see Sections F2(b) and F615) and the Construction EMP (see Section 312(b))
33 Road maintenance after completion
Mr E Mmbadi 20170410 4 In most cases after the construction work is completed the roads are handed over to local authority to maintain and service If it is envisaged to hand over the proposed access roads to Saldanha Bay Municipality (ldquoSBMrdquo) the report should acknowledge such intention Also ensure that all the requirements from SBM with regard to roads are met Please contact Manager Roads amp Stormwater (jeremyjarvissbmgovza 022 701 7049) in this regard
The design engineers have engaged with SBM regarding the future management of the roads as is indicated by the following statement in the BAR ldquoSaldanha Bay Municipality has requested that the road reserve should be registered as a separate erf which would be a portion of this propertyrdquo (see Section A2)
34 Water use during construction phase
Mr E Mmbadi 20170410 5 SBM commenced with the implementation of level 3 water restriction Please advise if there is confirmation from the municipality with regard to the supply of water to the proposed development SBM discourages the use of potable water as a dust suppression measure or for any construction purpose please indicate the developmentrsquos potential water source The use of treated effluent from the waste water treatment works could be an option Please contact Manager of Bulk Water and Sanitation (gavinwilliamasbmgovza 022 701 7047) in this regard Also consult with the Department of Water and Sanitation with regard to the water use application process
These comments regarding water conservation have been noted and relevant measures to prevent the use of potable water for dust suppression have been included in the revised BAR (see Sections F2(b) F3 and E615 of the revised BAR and Section 312(a) of the Construction EMP) Please note that the road development would only require a limited supply of water during the construction phase which the Contractor would be required to source from available resources Consultation with DWS regarding a water use application may thus not be relevant
35 Palaeontological and archaeological findings
Mr E Mmbadi 20170410 6 Please inform the Environment amp Heritage Section of the SBM on any Palaeontological and Archaeological findings for our records
This request has been included in the revised BAR (see Section F617) as well as the Construction EMP (see Section 3102(e))
4 COMMENTS FROM CAPENATURE 41 Status of
vegetation types Alana Duffell-Canham
20170410 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road 1 The proposed eastern access road passes through an area
These comments regarding the status of the vegetation types on the project site have been noted On the basis of the botanical assessment undertaken as part of the Basic Assessment process the condition of the Saldahna Limestone
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
5
NO ISSUE NAME DATE COMMENT RESPONSE covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet [been] listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6 000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
Strandveld vegetation located on the limestone ridge has indeed been described as of high botanical sensitivity in the draft BAR As to the status of the vegetation please take cognisance of DEAampDPrsquos position that only the formal classification of vegetation in terms of NEMBA is considered applicable in relation to the NEMA EIA Regulations This was in response to our indication in the draft BAR that Saldahna Flats Strandveld which is classified ldquoVulnerablerdquo should be considered ldquoEndangeredrdquo on the basis of a 2014 CapeNature status report Please refer to Comment and Response 21 above We thus have to assume that DEAampDP would consider the formal classification of Saldahna Limestone Strandveld as ldquoLeast Threatenedrdquo in terms of NEMBA as applicable
42 Critical Biodiversity Areas
Alana Duffell-Canham
20170410 2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent land cover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truth where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data
A mentioned in Response 31 above the draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest WCBSP which became available in April 2017 has been taken into consideration in the revised BAR Our observation regarding the mapping of the CBAs is that this covers a large area on the specific property and extends notably further northwards than the intact vegetation on the limestone ridge According to the ground-truthing of the botanical
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
Proposed north-south access road
Proposed eastern access road
Trunk Road 85
Main Road 559 Minor Road 7645
Saldanha Bay Industrial Development Zone
Duferco
Future Afrisam cement plant
Proposed north-south access road
Proposed eastern access road
From Ena de VilliersTo Ena de VilliersBcc gerritsmithsbmgovza malcolmwatterswesterncapegovza corvdwelsenburgcom aduffell-canhamcapenaturecoza
melaneseschipperswesterncapegovzaSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
REMINDER OF CLOSURE OF BAR COMMENT PERIODDate 04 April 2017 110142 AMAttachments image6c48afPNG
Dear SirsMadams We would like to take this opportunity to remind you of the closure of the comment period for the above-mentioned projecton 10 April 2017 Kindly submit your comments to Mandy Kula (mkulaslrconsultingcom) or myself at the contact particularsbelow You are welcome to contact us regarding any enquiries Thanks and best regardsEna
Ena de VilliersEnvironmental ConsultantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
APPENDIX F4
DRAFT BAR COMMENTS AND RESPONSES REPORT
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
1
DRAFT BASIC ASSESSMENT REPORT (BAR)
COMMENTS AND RESPONSES REPORT
Written submissions were received from the following commenting authorities and other Interested and Affected Parties (IampAPs) during the BAR comment period
SUBMITTED BY METHOD AND DATE Authorities 1 West Coast District Municipality ndash Ms Doretha Kotze Email - 29 March 2017
2 Department of Environmental Affairs and Development Planning ndash Ms M Schippers Fax - 07 April 2017
3 Saldanha Bay Municipality ndash Mr E Mmbadi Email - 10 April 2017
4 CapeNature ndash Ms Alana Duffell-Canham Email - 11 April 2017
Other IampAPs 1 Phillips Group ndash Mr Jan Phillips Email - 10 March 2017
Copies of the written comments are attached as Attachment A to this report arranged according to the order indicated in the table above The comments received are presented in Table 1 below and have been categorised as follows A Authority comments and issues 1 Comments received from West Coast District Municipality
11 Implications of Draft EMF for Saldanha region 12 Servitudes on the property
2 Comments received from Department of Environmental Affairs and Development Planning 21 Applicable listed Activities 22 Originally signed and dated declarations 23 Proof of Public Participation
3 Comments received from Saldanha Bay Municipality 31 Critical Biodiversity Areas 32 Cumulative impact of construction on ambient air quality 33 Road maintenance after completion 34 Water use during construction phase 35 Palaeontological and archaeological findings
4 Comments received from CapeNature 41 Status of vegetation types 42 Critical Biodiversity Areas 43 Implications for proposed eastern access route alignment 44 Proposed north-south access road 45 Rights reserved
B Other IampAP comments and issues 1 Comments received from Phillips Group
11 Effect of proposed project on traffic flow and businesses in the area 2 Comments received from Afrisam
21 Late submission of comments 22 South-north access road currently under construction 23 Zoning of Farm 1139 24 Suggestions for amending proposed mitigation measures 25 Details regarding activity information
No importance should be given to the order in which the categories are presented
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
2
Table 1 Summary table of comments received on the draft BAR with responses from SLR and the project technical team as appropriate
NO ISSUE NAME DATE COMMENT RESPONSE
A AUTHORITY COMMENTS AND ISSUES
1 COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY 11 Implications of
Draft EMF for Saldanha region
Doretha Kotze 20170329 1 Your letter dated 9 March 2017 and the information contained in the Draft BAR for the proposal refer
2 The Environmental Management Framework (EMF) for the Saldanha region is currently being revisited as part of the drafting of the Greater Saldanha Regional Spatial Implementation Framework by the Western Cape Provincial Department of Environmental Affairs and Development Planning It is recommended that this proposal be aligned with the outcomes of the different studies being undertaken as part of the finalisation of the EMF since Farm 1139 is situated in an area that has been identified as a Conflict Area in terms of the Urban Conservation Zone and Industrial Development Zone For more information of the EMF process kindly contact Ryan Nel at GIBB Consulting (rnelgibbcoza or Tel 011 519 4600)
We have taken the Draft EMF into consideration in the revised BAR (refer to Section D2(c)) However the document has not yet been formally adopted Thus the implied action by the Saldanha Municipality namely to resolve the conflict in the process of updating their Spatial Development Framework has not yet been undertaken Thus the formal land use status of the property remains intended for industrial development
12 Servitudes on the property
Doretha Kotze 20170329 3 Several servitudes had been registered over Farm 1139 over the years accommodating power lines water pipelines and rights of way Two bulk water pipelines of the West Coast District Municipality traversing the property in the northwest will be crossed by the proposed new access roads Care should be taken during the construction phase to prevent negative impacts on these pipelines
The project design engineers are aware of the existence of servitudes As necessary application would be made for wayleaves from the district and local municipalities if any works occur near water or other bulk services infrastructure
2 COMMENTS FROM DEPARTMENT OF ENVIRONMENTAL AFFAIRS AND DEVELOPMENT PLANNING 21 Applicable listed
activities M Schippers 20170407 The draft BAR dated March 2017 and received by this Department
on 09 March 2017 refer 1 Applicable listed activities 11 It is noted that Activity 12 of GN No R985 is being applied for 12 Please note that the abovementioned activity is not applicable
to the proposed development since the vegetation occurring on the proposed site has not been classified as a critically endangered or endangered ecosystem in terms of the National Environmental Management Biodiversity Act of 2004 (ldquoNEMBArdquo) List of Threatened Ecosystems in Need of Protection December 2011)
13 This activity must be excluded from the application
We have noted the comments in Item 1 and have amended the revised BAR accordingly ndash see Sections A1(c) and B5(c) and (d)
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
3
NO ISSUE NAME DATE COMMENT RESPONSE 22 Originally signed
and dated declarations
M Schippers 07 April17 2 The duly dated and originally signed declarations as completed by the applicant the Environmental Assessment Practitioner and the specialists who compiled the specialist reports as part of the Environmental Impact Assessment Process must be included in the BAR to be submitted to the competent authority
The originally signed declarations will be included in the final BAR which will be submitted to your Department after the conclusion of the revised BAR comment period
23 Proof of public participation
M Schippers 07 April17 3 Proof of Public Participation 31 Proof of the public participation conducted must be included in
the BAR to be submitted to the competent authority please note that the proof must include inter alia the following
311 A copy of the newspaper advertisement (ldquonewspaper clippingrdquo) that was placed indicating the name of the newspaper and date of publication
312 Photographs showing the notice displayed on site and a copy of the text displayed on the notice and
313 With regards to the written notices provided please note the following
bull If registered mail was sent a list of the registered mail sent as obtained from the post office must be provided
bull If regular mail was sent a list of the mail sent as obtained from the post office must be provided
bull If a facsimile was sent a copy of the facsimile report must be provided
bull If an electronic mail was sent a copy of the electronic mail sent and delivery reports must be provided and
bull If a ldquomail droprdquo was done a signed register of ldquomail dropsrdquo must be provided
Proof of public participation has been included in the revised BAR as follows bull Newspaper advertisement ndash Appendix F2 bull Site notice ndash Appendix F2 and bull Written notifications ndash Appendix F3 Please note that as e-mail addresses were available for all IampAPs registered on the database the formal notification letter was sent by means of electronic mail However delivery reports were not requested as this requirement is not stated in the relevant legislation nor in any guideline document on public participation of which we are aware Thus we have included a copy of the e-mail notification sent as adequate proof of distribution Hard copies of letters were delivered to representatives of commenting authorities proof of which is also included in Appendix F3
3 COMMENTS FROM SALDANHA BAY MUNICIPALITY 31 Critical
Biodiversity Areas
Mr E Mmbadi 20170410 1 Basic Assessment Report for the Proposed New Access Roads to the Saldanha Bay Industrial Development Zone dated 07 March 2017 refers
2 Even though the site is located outside the Critical Biodiversity Area it may function as a ldquostepping stonerdquo corridor that allows for animal and plant movement across the landscape Development within such sites should consider ecological connectivity of the landscape and care should be taken not to disrupt this connectivity especially for a site surrounded by Critical Biodiversity Areas
The draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest Western Cape Biodiversity Spatial Plan became available in April 2017 and was taken into consideration in the revised BAR which will be made available for a further review and comment period
32 Cumulative Mr E Mmbadi 20170410 3 The report should highlight the potential cumulative impacts of These comments have been noted As the
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
4
NO ISSUE NAME DATE COMMENT RESPONSE impact of construction on ambient air quality
several construction activities on ambient air quality Viewing the impacts of access roads construction in isolation may only reveal limited potential impacts on the ambient air quality The report should also look at the possible release of iron ore dust trapped on vegetation into the atmosphere
construction phase of the proposed project has not yet been scheduled it cannot be assumed that it will occur while other road construction projects in the area are in progress Reference to the implications of the possible release of iron ore dust trapped on vegetation for dust generation and control during the construction phase has been incorporated into the revised BAR (see Sections F2(b) and F615) and the Construction EMP (see Section 312(b))
33 Road maintenance after completion
Mr E Mmbadi 20170410 4 In most cases after the construction work is completed the roads are handed over to local authority to maintain and service If it is envisaged to hand over the proposed access roads to Saldanha Bay Municipality (ldquoSBMrdquo) the report should acknowledge such intention Also ensure that all the requirements from SBM with regard to roads are met Please contact Manager Roads amp Stormwater (jeremyjarvissbmgovza 022 701 7049) in this regard
The design engineers have engaged with SBM regarding the future management of the roads as is indicated by the following statement in the BAR ldquoSaldanha Bay Municipality has requested that the road reserve should be registered as a separate erf which would be a portion of this propertyrdquo (see Section A2)
34 Water use during construction phase
Mr E Mmbadi 20170410 5 SBM commenced with the implementation of level 3 water restriction Please advise if there is confirmation from the municipality with regard to the supply of water to the proposed development SBM discourages the use of potable water as a dust suppression measure or for any construction purpose please indicate the developmentrsquos potential water source The use of treated effluent from the waste water treatment works could be an option Please contact Manager of Bulk Water and Sanitation (gavinwilliamasbmgovza 022 701 7047) in this regard Also consult with the Department of Water and Sanitation with regard to the water use application process
These comments regarding water conservation have been noted and relevant measures to prevent the use of potable water for dust suppression have been included in the revised BAR (see Sections F2(b) F3 and E615 of the revised BAR and Section 312(a) of the Construction EMP) Please note that the road development would only require a limited supply of water during the construction phase which the Contractor would be required to source from available resources Consultation with DWS regarding a water use application may thus not be relevant
35 Palaeontological and archaeological findings
Mr E Mmbadi 20170410 6 Please inform the Environment amp Heritage Section of the SBM on any Palaeontological and Archaeological findings for our records
This request has been included in the revised BAR (see Section F617) as well as the Construction EMP (see Section 3102(e))
4 COMMENTS FROM CAPENATURE 41 Status of
vegetation types Alana Duffell-Canham
20170410 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road 1 The proposed eastern access road passes through an area
These comments regarding the status of the vegetation types on the project site have been noted On the basis of the botanical assessment undertaken as part of the Basic Assessment process the condition of the Saldahna Limestone
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
5
NO ISSUE NAME DATE COMMENT RESPONSE covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet [been] listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6 000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
Strandveld vegetation located on the limestone ridge has indeed been described as of high botanical sensitivity in the draft BAR As to the status of the vegetation please take cognisance of DEAampDPrsquos position that only the formal classification of vegetation in terms of NEMBA is considered applicable in relation to the NEMA EIA Regulations This was in response to our indication in the draft BAR that Saldahna Flats Strandveld which is classified ldquoVulnerablerdquo should be considered ldquoEndangeredrdquo on the basis of a 2014 CapeNature status report Please refer to Comment and Response 21 above We thus have to assume that DEAampDP would consider the formal classification of Saldahna Limestone Strandveld as ldquoLeast Threatenedrdquo in terms of NEMBA as applicable
42 Critical Biodiversity Areas
Alana Duffell-Canham
20170410 2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent land cover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truth where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data
A mentioned in Response 31 above the draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest WCBSP which became available in April 2017 has been taken into consideration in the revised BAR Our observation regarding the mapping of the CBAs is that this covers a large area on the specific property and extends notably further northwards than the intact vegetation on the limestone ridge According to the ground-truthing of the botanical
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
Proposed north-south access road
Proposed eastern access road
Trunk Road 85
Main Road 559 Minor Road 7645
Saldanha Bay Industrial Development Zone
Duferco
Future Afrisam cement plant
Proposed north-south access road
Proposed eastern access road
From Ena de VilliersTo Ena de VilliersBcc gerritsmithsbmgovza malcolmwatterswesterncapegovza corvdwelsenburgcom aduffell-canhamcapenaturecoza
melaneseschipperswesterncapegovzaSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
REMINDER OF CLOSURE OF BAR COMMENT PERIODDate 04 April 2017 110142 AMAttachments image6c48afPNG
Dear SirsMadams We would like to take this opportunity to remind you of the closure of the comment period for the above-mentioned projecton 10 April 2017 Kindly submit your comments to Mandy Kula (mkulaslrconsultingcom) or myself at the contact particularsbelow You are welcome to contact us regarding any enquiries Thanks and best regardsEna
Ena de VilliersEnvironmental ConsultantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
APPENDIX F4
DRAFT BAR COMMENTS AND RESPONSES REPORT
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
1
DRAFT BASIC ASSESSMENT REPORT (BAR)
COMMENTS AND RESPONSES REPORT
Written submissions were received from the following commenting authorities and other Interested and Affected Parties (IampAPs) during the BAR comment period
SUBMITTED BY METHOD AND DATE Authorities 1 West Coast District Municipality ndash Ms Doretha Kotze Email - 29 March 2017
2 Department of Environmental Affairs and Development Planning ndash Ms M Schippers Fax - 07 April 2017
3 Saldanha Bay Municipality ndash Mr E Mmbadi Email - 10 April 2017
4 CapeNature ndash Ms Alana Duffell-Canham Email - 11 April 2017
Other IampAPs 1 Phillips Group ndash Mr Jan Phillips Email - 10 March 2017
Copies of the written comments are attached as Attachment A to this report arranged according to the order indicated in the table above The comments received are presented in Table 1 below and have been categorised as follows A Authority comments and issues 1 Comments received from West Coast District Municipality
11 Implications of Draft EMF for Saldanha region 12 Servitudes on the property
2 Comments received from Department of Environmental Affairs and Development Planning 21 Applicable listed Activities 22 Originally signed and dated declarations 23 Proof of Public Participation
3 Comments received from Saldanha Bay Municipality 31 Critical Biodiversity Areas 32 Cumulative impact of construction on ambient air quality 33 Road maintenance after completion 34 Water use during construction phase 35 Palaeontological and archaeological findings
4 Comments received from CapeNature 41 Status of vegetation types 42 Critical Biodiversity Areas 43 Implications for proposed eastern access route alignment 44 Proposed north-south access road 45 Rights reserved
B Other IampAP comments and issues 1 Comments received from Phillips Group
11 Effect of proposed project on traffic flow and businesses in the area 2 Comments received from Afrisam
21 Late submission of comments 22 South-north access road currently under construction 23 Zoning of Farm 1139 24 Suggestions for amending proposed mitigation measures 25 Details regarding activity information
No importance should be given to the order in which the categories are presented
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
2
Table 1 Summary table of comments received on the draft BAR with responses from SLR and the project technical team as appropriate
NO ISSUE NAME DATE COMMENT RESPONSE
A AUTHORITY COMMENTS AND ISSUES
1 COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY 11 Implications of
Draft EMF for Saldanha region
Doretha Kotze 20170329 1 Your letter dated 9 March 2017 and the information contained in the Draft BAR for the proposal refer
2 The Environmental Management Framework (EMF) for the Saldanha region is currently being revisited as part of the drafting of the Greater Saldanha Regional Spatial Implementation Framework by the Western Cape Provincial Department of Environmental Affairs and Development Planning It is recommended that this proposal be aligned with the outcomes of the different studies being undertaken as part of the finalisation of the EMF since Farm 1139 is situated in an area that has been identified as a Conflict Area in terms of the Urban Conservation Zone and Industrial Development Zone For more information of the EMF process kindly contact Ryan Nel at GIBB Consulting (rnelgibbcoza or Tel 011 519 4600)
We have taken the Draft EMF into consideration in the revised BAR (refer to Section D2(c)) However the document has not yet been formally adopted Thus the implied action by the Saldanha Municipality namely to resolve the conflict in the process of updating their Spatial Development Framework has not yet been undertaken Thus the formal land use status of the property remains intended for industrial development
12 Servitudes on the property
Doretha Kotze 20170329 3 Several servitudes had been registered over Farm 1139 over the years accommodating power lines water pipelines and rights of way Two bulk water pipelines of the West Coast District Municipality traversing the property in the northwest will be crossed by the proposed new access roads Care should be taken during the construction phase to prevent negative impacts on these pipelines
The project design engineers are aware of the existence of servitudes As necessary application would be made for wayleaves from the district and local municipalities if any works occur near water or other bulk services infrastructure
2 COMMENTS FROM DEPARTMENT OF ENVIRONMENTAL AFFAIRS AND DEVELOPMENT PLANNING 21 Applicable listed
activities M Schippers 20170407 The draft BAR dated March 2017 and received by this Department
on 09 March 2017 refer 1 Applicable listed activities 11 It is noted that Activity 12 of GN No R985 is being applied for 12 Please note that the abovementioned activity is not applicable
to the proposed development since the vegetation occurring on the proposed site has not been classified as a critically endangered or endangered ecosystem in terms of the National Environmental Management Biodiversity Act of 2004 (ldquoNEMBArdquo) List of Threatened Ecosystems in Need of Protection December 2011)
13 This activity must be excluded from the application
We have noted the comments in Item 1 and have amended the revised BAR accordingly ndash see Sections A1(c) and B5(c) and (d)
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
3
NO ISSUE NAME DATE COMMENT RESPONSE 22 Originally signed
and dated declarations
M Schippers 07 April17 2 The duly dated and originally signed declarations as completed by the applicant the Environmental Assessment Practitioner and the specialists who compiled the specialist reports as part of the Environmental Impact Assessment Process must be included in the BAR to be submitted to the competent authority
The originally signed declarations will be included in the final BAR which will be submitted to your Department after the conclusion of the revised BAR comment period
23 Proof of public participation
M Schippers 07 April17 3 Proof of Public Participation 31 Proof of the public participation conducted must be included in
the BAR to be submitted to the competent authority please note that the proof must include inter alia the following
311 A copy of the newspaper advertisement (ldquonewspaper clippingrdquo) that was placed indicating the name of the newspaper and date of publication
312 Photographs showing the notice displayed on site and a copy of the text displayed on the notice and
313 With regards to the written notices provided please note the following
bull If registered mail was sent a list of the registered mail sent as obtained from the post office must be provided
bull If regular mail was sent a list of the mail sent as obtained from the post office must be provided
bull If a facsimile was sent a copy of the facsimile report must be provided
bull If an electronic mail was sent a copy of the electronic mail sent and delivery reports must be provided and
bull If a ldquomail droprdquo was done a signed register of ldquomail dropsrdquo must be provided
Proof of public participation has been included in the revised BAR as follows bull Newspaper advertisement ndash Appendix F2 bull Site notice ndash Appendix F2 and bull Written notifications ndash Appendix F3 Please note that as e-mail addresses were available for all IampAPs registered on the database the formal notification letter was sent by means of electronic mail However delivery reports were not requested as this requirement is not stated in the relevant legislation nor in any guideline document on public participation of which we are aware Thus we have included a copy of the e-mail notification sent as adequate proof of distribution Hard copies of letters were delivered to representatives of commenting authorities proof of which is also included in Appendix F3
3 COMMENTS FROM SALDANHA BAY MUNICIPALITY 31 Critical
Biodiversity Areas
Mr E Mmbadi 20170410 1 Basic Assessment Report for the Proposed New Access Roads to the Saldanha Bay Industrial Development Zone dated 07 March 2017 refers
2 Even though the site is located outside the Critical Biodiversity Area it may function as a ldquostepping stonerdquo corridor that allows for animal and plant movement across the landscape Development within such sites should consider ecological connectivity of the landscape and care should be taken not to disrupt this connectivity especially for a site surrounded by Critical Biodiversity Areas
The draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest Western Cape Biodiversity Spatial Plan became available in April 2017 and was taken into consideration in the revised BAR which will be made available for a further review and comment period
32 Cumulative Mr E Mmbadi 20170410 3 The report should highlight the potential cumulative impacts of These comments have been noted As the
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
4
NO ISSUE NAME DATE COMMENT RESPONSE impact of construction on ambient air quality
several construction activities on ambient air quality Viewing the impacts of access roads construction in isolation may only reveal limited potential impacts on the ambient air quality The report should also look at the possible release of iron ore dust trapped on vegetation into the atmosphere
construction phase of the proposed project has not yet been scheduled it cannot be assumed that it will occur while other road construction projects in the area are in progress Reference to the implications of the possible release of iron ore dust trapped on vegetation for dust generation and control during the construction phase has been incorporated into the revised BAR (see Sections F2(b) and F615) and the Construction EMP (see Section 312(b))
33 Road maintenance after completion
Mr E Mmbadi 20170410 4 In most cases after the construction work is completed the roads are handed over to local authority to maintain and service If it is envisaged to hand over the proposed access roads to Saldanha Bay Municipality (ldquoSBMrdquo) the report should acknowledge such intention Also ensure that all the requirements from SBM with regard to roads are met Please contact Manager Roads amp Stormwater (jeremyjarvissbmgovza 022 701 7049) in this regard
The design engineers have engaged with SBM regarding the future management of the roads as is indicated by the following statement in the BAR ldquoSaldanha Bay Municipality has requested that the road reserve should be registered as a separate erf which would be a portion of this propertyrdquo (see Section A2)
34 Water use during construction phase
Mr E Mmbadi 20170410 5 SBM commenced with the implementation of level 3 water restriction Please advise if there is confirmation from the municipality with regard to the supply of water to the proposed development SBM discourages the use of potable water as a dust suppression measure or for any construction purpose please indicate the developmentrsquos potential water source The use of treated effluent from the waste water treatment works could be an option Please contact Manager of Bulk Water and Sanitation (gavinwilliamasbmgovza 022 701 7047) in this regard Also consult with the Department of Water and Sanitation with regard to the water use application process
These comments regarding water conservation have been noted and relevant measures to prevent the use of potable water for dust suppression have been included in the revised BAR (see Sections F2(b) F3 and E615 of the revised BAR and Section 312(a) of the Construction EMP) Please note that the road development would only require a limited supply of water during the construction phase which the Contractor would be required to source from available resources Consultation with DWS regarding a water use application may thus not be relevant
35 Palaeontological and archaeological findings
Mr E Mmbadi 20170410 6 Please inform the Environment amp Heritage Section of the SBM on any Palaeontological and Archaeological findings for our records
This request has been included in the revised BAR (see Section F617) as well as the Construction EMP (see Section 3102(e))
4 COMMENTS FROM CAPENATURE 41 Status of
vegetation types Alana Duffell-Canham
20170410 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road 1 The proposed eastern access road passes through an area
These comments regarding the status of the vegetation types on the project site have been noted On the basis of the botanical assessment undertaken as part of the Basic Assessment process the condition of the Saldahna Limestone
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
5
NO ISSUE NAME DATE COMMENT RESPONSE covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet [been] listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6 000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
Strandveld vegetation located on the limestone ridge has indeed been described as of high botanical sensitivity in the draft BAR As to the status of the vegetation please take cognisance of DEAampDPrsquos position that only the formal classification of vegetation in terms of NEMBA is considered applicable in relation to the NEMA EIA Regulations This was in response to our indication in the draft BAR that Saldahna Flats Strandveld which is classified ldquoVulnerablerdquo should be considered ldquoEndangeredrdquo on the basis of a 2014 CapeNature status report Please refer to Comment and Response 21 above We thus have to assume that DEAampDP would consider the formal classification of Saldahna Limestone Strandveld as ldquoLeast Threatenedrdquo in terms of NEMBA as applicable
42 Critical Biodiversity Areas
Alana Duffell-Canham
20170410 2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent land cover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truth where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data
A mentioned in Response 31 above the draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest WCBSP which became available in April 2017 has been taken into consideration in the revised BAR Our observation regarding the mapping of the CBAs is that this covers a large area on the specific property and extends notably further northwards than the intact vegetation on the limestone ridge According to the ground-truthing of the botanical
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
Proposed north-south access road
Proposed eastern access road
Trunk Road 85
Main Road 559 Minor Road 7645
Saldanha Bay Industrial Development Zone
Duferco
Future Afrisam cement plant
Proposed north-south access road
Proposed eastern access road
From Ena de VilliersTo Ena de VilliersBcc gerritsmithsbmgovza malcolmwatterswesterncapegovza corvdwelsenburgcom aduffell-canhamcapenaturecoza
melaneseschipperswesterncapegovzaSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
REMINDER OF CLOSURE OF BAR COMMENT PERIODDate 04 April 2017 110142 AMAttachments image6c48afPNG
Dear SirsMadams We would like to take this opportunity to remind you of the closure of the comment period for the above-mentioned projecton 10 April 2017 Kindly submit your comments to Mandy Kula (mkulaslrconsultingcom) or myself at the contact particularsbelow You are welcome to contact us regarding any enquiries Thanks and best regardsEna
Ena de VilliersEnvironmental ConsultantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
APPENDIX F4
DRAFT BAR COMMENTS AND RESPONSES REPORT
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
1
DRAFT BASIC ASSESSMENT REPORT (BAR)
COMMENTS AND RESPONSES REPORT
Written submissions were received from the following commenting authorities and other Interested and Affected Parties (IampAPs) during the BAR comment period
SUBMITTED BY METHOD AND DATE Authorities 1 West Coast District Municipality ndash Ms Doretha Kotze Email - 29 March 2017
2 Department of Environmental Affairs and Development Planning ndash Ms M Schippers Fax - 07 April 2017
3 Saldanha Bay Municipality ndash Mr E Mmbadi Email - 10 April 2017
4 CapeNature ndash Ms Alana Duffell-Canham Email - 11 April 2017
Other IampAPs 1 Phillips Group ndash Mr Jan Phillips Email - 10 March 2017
Copies of the written comments are attached as Attachment A to this report arranged according to the order indicated in the table above The comments received are presented in Table 1 below and have been categorised as follows A Authority comments and issues 1 Comments received from West Coast District Municipality
11 Implications of Draft EMF for Saldanha region 12 Servitudes on the property
2 Comments received from Department of Environmental Affairs and Development Planning 21 Applicable listed Activities 22 Originally signed and dated declarations 23 Proof of Public Participation
3 Comments received from Saldanha Bay Municipality 31 Critical Biodiversity Areas 32 Cumulative impact of construction on ambient air quality 33 Road maintenance after completion 34 Water use during construction phase 35 Palaeontological and archaeological findings
4 Comments received from CapeNature 41 Status of vegetation types 42 Critical Biodiversity Areas 43 Implications for proposed eastern access route alignment 44 Proposed north-south access road 45 Rights reserved
B Other IampAP comments and issues 1 Comments received from Phillips Group
11 Effect of proposed project on traffic flow and businesses in the area 2 Comments received from Afrisam
21 Late submission of comments 22 South-north access road currently under construction 23 Zoning of Farm 1139 24 Suggestions for amending proposed mitigation measures 25 Details regarding activity information
No importance should be given to the order in which the categories are presented
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
2
Table 1 Summary table of comments received on the draft BAR with responses from SLR and the project technical team as appropriate
NO ISSUE NAME DATE COMMENT RESPONSE
A AUTHORITY COMMENTS AND ISSUES
1 COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY 11 Implications of
Draft EMF for Saldanha region
Doretha Kotze 20170329 1 Your letter dated 9 March 2017 and the information contained in the Draft BAR for the proposal refer
2 The Environmental Management Framework (EMF) for the Saldanha region is currently being revisited as part of the drafting of the Greater Saldanha Regional Spatial Implementation Framework by the Western Cape Provincial Department of Environmental Affairs and Development Planning It is recommended that this proposal be aligned with the outcomes of the different studies being undertaken as part of the finalisation of the EMF since Farm 1139 is situated in an area that has been identified as a Conflict Area in terms of the Urban Conservation Zone and Industrial Development Zone For more information of the EMF process kindly contact Ryan Nel at GIBB Consulting (rnelgibbcoza or Tel 011 519 4600)
We have taken the Draft EMF into consideration in the revised BAR (refer to Section D2(c)) However the document has not yet been formally adopted Thus the implied action by the Saldanha Municipality namely to resolve the conflict in the process of updating their Spatial Development Framework has not yet been undertaken Thus the formal land use status of the property remains intended for industrial development
12 Servitudes on the property
Doretha Kotze 20170329 3 Several servitudes had been registered over Farm 1139 over the years accommodating power lines water pipelines and rights of way Two bulk water pipelines of the West Coast District Municipality traversing the property in the northwest will be crossed by the proposed new access roads Care should be taken during the construction phase to prevent negative impacts on these pipelines
The project design engineers are aware of the existence of servitudes As necessary application would be made for wayleaves from the district and local municipalities if any works occur near water or other bulk services infrastructure
2 COMMENTS FROM DEPARTMENT OF ENVIRONMENTAL AFFAIRS AND DEVELOPMENT PLANNING 21 Applicable listed
activities M Schippers 20170407 The draft BAR dated March 2017 and received by this Department
on 09 March 2017 refer 1 Applicable listed activities 11 It is noted that Activity 12 of GN No R985 is being applied for 12 Please note that the abovementioned activity is not applicable
to the proposed development since the vegetation occurring on the proposed site has not been classified as a critically endangered or endangered ecosystem in terms of the National Environmental Management Biodiversity Act of 2004 (ldquoNEMBArdquo) List of Threatened Ecosystems in Need of Protection December 2011)
13 This activity must be excluded from the application
We have noted the comments in Item 1 and have amended the revised BAR accordingly ndash see Sections A1(c) and B5(c) and (d)
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
3
NO ISSUE NAME DATE COMMENT RESPONSE 22 Originally signed
and dated declarations
M Schippers 07 April17 2 The duly dated and originally signed declarations as completed by the applicant the Environmental Assessment Practitioner and the specialists who compiled the specialist reports as part of the Environmental Impact Assessment Process must be included in the BAR to be submitted to the competent authority
The originally signed declarations will be included in the final BAR which will be submitted to your Department after the conclusion of the revised BAR comment period
23 Proof of public participation
M Schippers 07 April17 3 Proof of Public Participation 31 Proof of the public participation conducted must be included in
the BAR to be submitted to the competent authority please note that the proof must include inter alia the following
311 A copy of the newspaper advertisement (ldquonewspaper clippingrdquo) that was placed indicating the name of the newspaper and date of publication
312 Photographs showing the notice displayed on site and a copy of the text displayed on the notice and
313 With regards to the written notices provided please note the following
bull If registered mail was sent a list of the registered mail sent as obtained from the post office must be provided
bull If regular mail was sent a list of the mail sent as obtained from the post office must be provided
bull If a facsimile was sent a copy of the facsimile report must be provided
bull If an electronic mail was sent a copy of the electronic mail sent and delivery reports must be provided and
bull If a ldquomail droprdquo was done a signed register of ldquomail dropsrdquo must be provided
Proof of public participation has been included in the revised BAR as follows bull Newspaper advertisement ndash Appendix F2 bull Site notice ndash Appendix F2 and bull Written notifications ndash Appendix F3 Please note that as e-mail addresses were available for all IampAPs registered on the database the formal notification letter was sent by means of electronic mail However delivery reports were not requested as this requirement is not stated in the relevant legislation nor in any guideline document on public participation of which we are aware Thus we have included a copy of the e-mail notification sent as adequate proof of distribution Hard copies of letters were delivered to representatives of commenting authorities proof of which is also included in Appendix F3
3 COMMENTS FROM SALDANHA BAY MUNICIPALITY 31 Critical
Biodiversity Areas
Mr E Mmbadi 20170410 1 Basic Assessment Report for the Proposed New Access Roads to the Saldanha Bay Industrial Development Zone dated 07 March 2017 refers
2 Even though the site is located outside the Critical Biodiversity Area it may function as a ldquostepping stonerdquo corridor that allows for animal and plant movement across the landscape Development within such sites should consider ecological connectivity of the landscape and care should be taken not to disrupt this connectivity especially for a site surrounded by Critical Biodiversity Areas
The draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest Western Cape Biodiversity Spatial Plan became available in April 2017 and was taken into consideration in the revised BAR which will be made available for a further review and comment period
32 Cumulative Mr E Mmbadi 20170410 3 The report should highlight the potential cumulative impacts of These comments have been noted As the
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
4
NO ISSUE NAME DATE COMMENT RESPONSE impact of construction on ambient air quality
several construction activities on ambient air quality Viewing the impacts of access roads construction in isolation may only reveal limited potential impacts on the ambient air quality The report should also look at the possible release of iron ore dust trapped on vegetation into the atmosphere
construction phase of the proposed project has not yet been scheduled it cannot be assumed that it will occur while other road construction projects in the area are in progress Reference to the implications of the possible release of iron ore dust trapped on vegetation for dust generation and control during the construction phase has been incorporated into the revised BAR (see Sections F2(b) and F615) and the Construction EMP (see Section 312(b))
33 Road maintenance after completion
Mr E Mmbadi 20170410 4 In most cases after the construction work is completed the roads are handed over to local authority to maintain and service If it is envisaged to hand over the proposed access roads to Saldanha Bay Municipality (ldquoSBMrdquo) the report should acknowledge such intention Also ensure that all the requirements from SBM with regard to roads are met Please contact Manager Roads amp Stormwater (jeremyjarvissbmgovza 022 701 7049) in this regard
The design engineers have engaged with SBM regarding the future management of the roads as is indicated by the following statement in the BAR ldquoSaldanha Bay Municipality has requested that the road reserve should be registered as a separate erf which would be a portion of this propertyrdquo (see Section A2)
34 Water use during construction phase
Mr E Mmbadi 20170410 5 SBM commenced with the implementation of level 3 water restriction Please advise if there is confirmation from the municipality with regard to the supply of water to the proposed development SBM discourages the use of potable water as a dust suppression measure or for any construction purpose please indicate the developmentrsquos potential water source The use of treated effluent from the waste water treatment works could be an option Please contact Manager of Bulk Water and Sanitation (gavinwilliamasbmgovza 022 701 7047) in this regard Also consult with the Department of Water and Sanitation with regard to the water use application process
These comments regarding water conservation have been noted and relevant measures to prevent the use of potable water for dust suppression have been included in the revised BAR (see Sections F2(b) F3 and E615 of the revised BAR and Section 312(a) of the Construction EMP) Please note that the road development would only require a limited supply of water during the construction phase which the Contractor would be required to source from available resources Consultation with DWS regarding a water use application may thus not be relevant
35 Palaeontological and archaeological findings
Mr E Mmbadi 20170410 6 Please inform the Environment amp Heritage Section of the SBM on any Palaeontological and Archaeological findings for our records
This request has been included in the revised BAR (see Section F617) as well as the Construction EMP (see Section 3102(e))
4 COMMENTS FROM CAPENATURE 41 Status of
vegetation types Alana Duffell-Canham
20170410 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road 1 The proposed eastern access road passes through an area
These comments regarding the status of the vegetation types on the project site have been noted On the basis of the botanical assessment undertaken as part of the Basic Assessment process the condition of the Saldahna Limestone
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
5
NO ISSUE NAME DATE COMMENT RESPONSE covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet [been] listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6 000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
Strandveld vegetation located on the limestone ridge has indeed been described as of high botanical sensitivity in the draft BAR As to the status of the vegetation please take cognisance of DEAampDPrsquos position that only the formal classification of vegetation in terms of NEMBA is considered applicable in relation to the NEMA EIA Regulations This was in response to our indication in the draft BAR that Saldahna Flats Strandveld which is classified ldquoVulnerablerdquo should be considered ldquoEndangeredrdquo on the basis of a 2014 CapeNature status report Please refer to Comment and Response 21 above We thus have to assume that DEAampDP would consider the formal classification of Saldahna Limestone Strandveld as ldquoLeast Threatenedrdquo in terms of NEMBA as applicable
42 Critical Biodiversity Areas
Alana Duffell-Canham
20170410 2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent land cover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truth where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data
A mentioned in Response 31 above the draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest WCBSP which became available in April 2017 has been taken into consideration in the revised BAR Our observation regarding the mapping of the CBAs is that this covers a large area on the specific property and extends notably further northwards than the intact vegetation on the limestone ridge According to the ground-truthing of the botanical
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
From Ena de VilliersTo Ena de VilliersBcc gerritsmithsbmgovza malcolmwatterswesterncapegovza corvdwelsenburgcom aduffell-canhamcapenaturecoza
melaneseschipperswesterncapegovzaSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
REMINDER OF CLOSURE OF BAR COMMENT PERIODDate 04 April 2017 110142 AMAttachments image6c48afPNG
Dear SirsMadams We would like to take this opportunity to remind you of the closure of the comment period for the above-mentioned projecton 10 April 2017 Kindly submit your comments to Mandy Kula (mkulaslrconsultingcom) or myself at the contact particularsbelow You are welcome to contact us regarding any enquiries Thanks and best regardsEna
Ena de VilliersEnvironmental ConsultantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001
South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
APPENDIX F4
DRAFT BAR COMMENTS AND RESPONSES REPORT
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
1
DRAFT BASIC ASSESSMENT REPORT (BAR)
COMMENTS AND RESPONSES REPORT
Written submissions were received from the following commenting authorities and other Interested and Affected Parties (IampAPs) during the BAR comment period
SUBMITTED BY METHOD AND DATE Authorities 1 West Coast District Municipality ndash Ms Doretha Kotze Email - 29 March 2017
2 Department of Environmental Affairs and Development Planning ndash Ms M Schippers Fax - 07 April 2017
3 Saldanha Bay Municipality ndash Mr E Mmbadi Email - 10 April 2017
4 CapeNature ndash Ms Alana Duffell-Canham Email - 11 April 2017
Other IampAPs 1 Phillips Group ndash Mr Jan Phillips Email - 10 March 2017
Copies of the written comments are attached as Attachment A to this report arranged according to the order indicated in the table above The comments received are presented in Table 1 below and have been categorised as follows A Authority comments and issues 1 Comments received from West Coast District Municipality
11 Implications of Draft EMF for Saldanha region 12 Servitudes on the property
2 Comments received from Department of Environmental Affairs and Development Planning 21 Applicable listed Activities 22 Originally signed and dated declarations 23 Proof of Public Participation
3 Comments received from Saldanha Bay Municipality 31 Critical Biodiversity Areas 32 Cumulative impact of construction on ambient air quality 33 Road maintenance after completion 34 Water use during construction phase 35 Palaeontological and archaeological findings
4 Comments received from CapeNature 41 Status of vegetation types 42 Critical Biodiversity Areas 43 Implications for proposed eastern access route alignment 44 Proposed north-south access road 45 Rights reserved
B Other IampAP comments and issues 1 Comments received from Phillips Group
11 Effect of proposed project on traffic flow and businesses in the area 2 Comments received from Afrisam
21 Late submission of comments 22 South-north access road currently under construction 23 Zoning of Farm 1139 24 Suggestions for amending proposed mitigation measures 25 Details regarding activity information
No importance should be given to the order in which the categories are presented
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
2
Table 1 Summary table of comments received on the draft BAR with responses from SLR and the project technical team as appropriate
NO ISSUE NAME DATE COMMENT RESPONSE
A AUTHORITY COMMENTS AND ISSUES
1 COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY 11 Implications of
Draft EMF for Saldanha region
Doretha Kotze 20170329 1 Your letter dated 9 March 2017 and the information contained in the Draft BAR for the proposal refer
2 The Environmental Management Framework (EMF) for the Saldanha region is currently being revisited as part of the drafting of the Greater Saldanha Regional Spatial Implementation Framework by the Western Cape Provincial Department of Environmental Affairs and Development Planning It is recommended that this proposal be aligned with the outcomes of the different studies being undertaken as part of the finalisation of the EMF since Farm 1139 is situated in an area that has been identified as a Conflict Area in terms of the Urban Conservation Zone and Industrial Development Zone For more information of the EMF process kindly contact Ryan Nel at GIBB Consulting (rnelgibbcoza or Tel 011 519 4600)
We have taken the Draft EMF into consideration in the revised BAR (refer to Section D2(c)) However the document has not yet been formally adopted Thus the implied action by the Saldanha Municipality namely to resolve the conflict in the process of updating their Spatial Development Framework has not yet been undertaken Thus the formal land use status of the property remains intended for industrial development
12 Servitudes on the property
Doretha Kotze 20170329 3 Several servitudes had been registered over Farm 1139 over the years accommodating power lines water pipelines and rights of way Two bulk water pipelines of the West Coast District Municipality traversing the property in the northwest will be crossed by the proposed new access roads Care should be taken during the construction phase to prevent negative impacts on these pipelines
The project design engineers are aware of the existence of servitudes As necessary application would be made for wayleaves from the district and local municipalities if any works occur near water or other bulk services infrastructure
2 COMMENTS FROM DEPARTMENT OF ENVIRONMENTAL AFFAIRS AND DEVELOPMENT PLANNING 21 Applicable listed
activities M Schippers 20170407 The draft BAR dated March 2017 and received by this Department
on 09 March 2017 refer 1 Applicable listed activities 11 It is noted that Activity 12 of GN No R985 is being applied for 12 Please note that the abovementioned activity is not applicable
to the proposed development since the vegetation occurring on the proposed site has not been classified as a critically endangered or endangered ecosystem in terms of the National Environmental Management Biodiversity Act of 2004 (ldquoNEMBArdquo) List of Threatened Ecosystems in Need of Protection December 2011)
13 This activity must be excluded from the application
We have noted the comments in Item 1 and have amended the revised BAR accordingly ndash see Sections A1(c) and B5(c) and (d)
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
3
NO ISSUE NAME DATE COMMENT RESPONSE 22 Originally signed
and dated declarations
M Schippers 07 April17 2 The duly dated and originally signed declarations as completed by the applicant the Environmental Assessment Practitioner and the specialists who compiled the specialist reports as part of the Environmental Impact Assessment Process must be included in the BAR to be submitted to the competent authority
The originally signed declarations will be included in the final BAR which will be submitted to your Department after the conclusion of the revised BAR comment period
23 Proof of public participation
M Schippers 07 April17 3 Proof of Public Participation 31 Proof of the public participation conducted must be included in
the BAR to be submitted to the competent authority please note that the proof must include inter alia the following
311 A copy of the newspaper advertisement (ldquonewspaper clippingrdquo) that was placed indicating the name of the newspaper and date of publication
312 Photographs showing the notice displayed on site and a copy of the text displayed on the notice and
313 With regards to the written notices provided please note the following
bull If registered mail was sent a list of the registered mail sent as obtained from the post office must be provided
bull If regular mail was sent a list of the mail sent as obtained from the post office must be provided
bull If a facsimile was sent a copy of the facsimile report must be provided
bull If an electronic mail was sent a copy of the electronic mail sent and delivery reports must be provided and
bull If a ldquomail droprdquo was done a signed register of ldquomail dropsrdquo must be provided
Proof of public participation has been included in the revised BAR as follows bull Newspaper advertisement ndash Appendix F2 bull Site notice ndash Appendix F2 and bull Written notifications ndash Appendix F3 Please note that as e-mail addresses were available for all IampAPs registered on the database the formal notification letter was sent by means of electronic mail However delivery reports were not requested as this requirement is not stated in the relevant legislation nor in any guideline document on public participation of which we are aware Thus we have included a copy of the e-mail notification sent as adequate proof of distribution Hard copies of letters were delivered to representatives of commenting authorities proof of which is also included in Appendix F3
3 COMMENTS FROM SALDANHA BAY MUNICIPALITY 31 Critical
Biodiversity Areas
Mr E Mmbadi 20170410 1 Basic Assessment Report for the Proposed New Access Roads to the Saldanha Bay Industrial Development Zone dated 07 March 2017 refers
2 Even though the site is located outside the Critical Biodiversity Area it may function as a ldquostepping stonerdquo corridor that allows for animal and plant movement across the landscape Development within such sites should consider ecological connectivity of the landscape and care should be taken not to disrupt this connectivity especially for a site surrounded by Critical Biodiversity Areas
The draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest Western Cape Biodiversity Spatial Plan became available in April 2017 and was taken into consideration in the revised BAR which will be made available for a further review and comment period
32 Cumulative Mr E Mmbadi 20170410 3 The report should highlight the potential cumulative impacts of These comments have been noted As the
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
4
NO ISSUE NAME DATE COMMENT RESPONSE impact of construction on ambient air quality
several construction activities on ambient air quality Viewing the impacts of access roads construction in isolation may only reveal limited potential impacts on the ambient air quality The report should also look at the possible release of iron ore dust trapped on vegetation into the atmosphere
construction phase of the proposed project has not yet been scheduled it cannot be assumed that it will occur while other road construction projects in the area are in progress Reference to the implications of the possible release of iron ore dust trapped on vegetation for dust generation and control during the construction phase has been incorporated into the revised BAR (see Sections F2(b) and F615) and the Construction EMP (see Section 312(b))
33 Road maintenance after completion
Mr E Mmbadi 20170410 4 In most cases after the construction work is completed the roads are handed over to local authority to maintain and service If it is envisaged to hand over the proposed access roads to Saldanha Bay Municipality (ldquoSBMrdquo) the report should acknowledge such intention Also ensure that all the requirements from SBM with regard to roads are met Please contact Manager Roads amp Stormwater (jeremyjarvissbmgovza 022 701 7049) in this regard
The design engineers have engaged with SBM regarding the future management of the roads as is indicated by the following statement in the BAR ldquoSaldanha Bay Municipality has requested that the road reserve should be registered as a separate erf which would be a portion of this propertyrdquo (see Section A2)
34 Water use during construction phase
Mr E Mmbadi 20170410 5 SBM commenced with the implementation of level 3 water restriction Please advise if there is confirmation from the municipality with regard to the supply of water to the proposed development SBM discourages the use of potable water as a dust suppression measure or for any construction purpose please indicate the developmentrsquos potential water source The use of treated effluent from the waste water treatment works could be an option Please contact Manager of Bulk Water and Sanitation (gavinwilliamasbmgovza 022 701 7047) in this regard Also consult with the Department of Water and Sanitation with regard to the water use application process
These comments regarding water conservation have been noted and relevant measures to prevent the use of potable water for dust suppression have been included in the revised BAR (see Sections F2(b) F3 and E615 of the revised BAR and Section 312(a) of the Construction EMP) Please note that the road development would only require a limited supply of water during the construction phase which the Contractor would be required to source from available resources Consultation with DWS regarding a water use application may thus not be relevant
35 Palaeontological and archaeological findings
Mr E Mmbadi 20170410 6 Please inform the Environment amp Heritage Section of the SBM on any Palaeontological and Archaeological findings for our records
This request has been included in the revised BAR (see Section F617) as well as the Construction EMP (see Section 3102(e))
4 COMMENTS FROM CAPENATURE 41 Status of
vegetation types Alana Duffell-Canham
20170410 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road 1 The proposed eastern access road passes through an area
These comments regarding the status of the vegetation types on the project site have been noted On the basis of the botanical assessment undertaken as part of the Basic Assessment process the condition of the Saldahna Limestone
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
5
NO ISSUE NAME DATE COMMENT RESPONSE covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet [been] listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6 000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
Strandveld vegetation located on the limestone ridge has indeed been described as of high botanical sensitivity in the draft BAR As to the status of the vegetation please take cognisance of DEAampDPrsquos position that only the formal classification of vegetation in terms of NEMBA is considered applicable in relation to the NEMA EIA Regulations This was in response to our indication in the draft BAR that Saldahna Flats Strandveld which is classified ldquoVulnerablerdquo should be considered ldquoEndangeredrdquo on the basis of a 2014 CapeNature status report Please refer to Comment and Response 21 above We thus have to assume that DEAampDP would consider the formal classification of Saldahna Limestone Strandveld as ldquoLeast Threatenedrdquo in terms of NEMBA as applicable
42 Critical Biodiversity Areas
Alana Duffell-Canham
20170410 2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent land cover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truth where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data
A mentioned in Response 31 above the draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest WCBSP which became available in April 2017 has been taken into consideration in the revised BAR Our observation regarding the mapping of the CBAs is that this covers a large area on the specific property and extends notably further northwards than the intact vegetation on the limestone ridge According to the ground-truthing of the botanical
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
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SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
APPENDIX F4
DRAFT BAR COMMENTS AND RESPONSES REPORT
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
1
DRAFT BASIC ASSESSMENT REPORT (BAR)
COMMENTS AND RESPONSES REPORT
Written submissions were received from the following commenting authorities and other Interested and Affected Parties (IampAPs) during the BAR comment period
SUBMITTED BY METHOD AND DATE Authorities 1 West Coast District Municipality ndash Ms Doretha Kotze Email - 29 March 2017
2 Department of Environmental Affairs and Development Planning ndash Ms M Schippers Fax - 07 April 2017
3 Saldanha Bay Municipality ndash Mr E Mmbadi Email - 10 April 2017
4 CapeNature ndash Ms Alana Duffell-Canham Email - 11 April 2017
Other IampAPs 1 Phillips Group ndash Mr Jan Phillips Email - 10 March 2017
Copies of the written comments are attached as Attachment A to this report arranged according to the order indicated in the table above The comments received are presented in Table 1 below and have been categorised as follows A Authority comments and issues 1 Comments received from West Coast District Municipality
11 Implications of Draft EMF for Saldanha region 12 Servitudes on the property
2 Comments received from Department of Environmental Affairs and Development Planning 21 Applicable listed Activities 22 Originally signed and dated declarations 23 Proof of Public Participation
3 Comments received from Saldanha Bay Municipality 31 Critical Biodiversity Areas 32 Cumulative impact of construction on ambient air quality 33 Road maintenance after completion 34 Water use during construction phase 35 Palaeontological and archaeological findings
4 Comments received from CapeNature 41 Status of vegetation types 42 Critical Biodiversity Areas 43 Implications for proposed eastern access route alignment 44 Proposed north-south access road 45 Rights reserved
B Other IampAP comments and issues 1 Comments received from Phillips Group
11 Effect of proposed project on traffic flow and businesses in the area 2 Comments received from Afrisam
21 Late submission of comments 22 South-north access road currently under construction 23 Zoning of Farm 1139 24 Suggestions for amending proposed mitigation measures 25 Details regarding activity information
No importance should be given to the order in which the categories are presented
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
2
Table 1 Summary table of comments received on the draft BAR with responses from SLR and the project technical team as appropriate
NO ISSUE NAME DATE COMMENT RESPONSE
A AUTHORITY COMMENTS AND ISSUES
1 COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY 11 Implications of
Draft EMF for Saldanha region
Doretha Kotze 20170329 1 Your letter dated 9 March 2017 and the information contained in the Draft BAR for the proposal refer
2 The Environmental Management Framework (EMF) for the Saldanha region is currently being revisited as part of the drafting of the Greater Saldanha Regional Spatial Implementation Framework by the Western Cape Provincial Department of Environmental Affairs and Development Planning It is recommended that this proposal be aligned with the outcomes of the different studies being undertaken as part of the finalisation of the EMF since Farm 1139 is situated in an area that has been identified as a Conflict Area in terms of the Urban Conservation Zone and Industrial Development Zone For more information of the EMF process kindly contact Ryan Nel at GIBB Consulting (rnelgibbcoza or Tel 011 519 4600)
We have taken the Draft EMF into consideration in the revised BAR (refer to Section D2(c)) However the document has not yet been formally adopted Thus the implied action by the Saldanha Municipality namely to resolve the conflict in the process of updating their Spatial Development Framework has not yet been undertaken Thus the formal land use status of the property remains intended for industrial development
12 Servitudes on the property
Doretha Kotze 20170329 3 Several servitudes had been registered over Farm 1139 over the years accommodating power lines water pipelines and rights of way Two bulk water pipelines of the West Coast District Municipality traversing the property in the northwest will be crossed by the proposed new access roads Care should be taken during the construction phase to prevent negative impacts on these pipelines
The project design engineers are aware of the existence of servitudes As necessary application would be made for wayleaves from the district and local municipalities if any works occur near water or other bulk services infrastructure
2 COMMENTS FROM DEPARTMENT OF ENVIRONMENTAL AFFAIRS AND DEVELOPMENT PLANNING 21 Applicable listed
activities M Schippers 20170407 The draft BAR dated March 2017 and received by this Department
on 09 March 2017 refer 1 Applicable listed activities 11 It is noted that Activity 12 of GN No R985 is being applied for 12 Please note that the abovementioned activity is not applicable
to the proposed development since the vegetation occurring on the proposed site has not been classified as a critically endangered or endangered ecosystem in terms of the National Environmental Management Biodiversity Act of 2004 (ldquoNEMBArdquo) List of Threatened Ecosystems in Need of Protection December 2011)
13 This activity must be excluded from the application
We have noted the comments in Item 1 and have amended the revised BAR accordingly ndash see Sections A1(c) and B5(c) and (d)
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
3
NO ISSUE NAME DATE COMMENT RESPONSE 22 Originally signed
and dated declarations
M Schippers 07 April17 2 The duly dated and originally signed declarations as completed by the applicant the Environmental Assessment Practitioner and the specialists who compiled the specialist reports as part of the Environmental Impact Assessment Process must be included in the BAR to be submitted to the competent authority
The originally signed declarations will be included in the final BAR which will be submitted to your Department after the conclusion of the revised BAR comment period
23 Proof of public participation
M Schippers 07 April17 3 Proof of Public Participation 31 Proof of the public participation conducted must be included in
the BAR to be submitted to the competent authority please note that the proof must include inter alia the following
311 A copy of the newspaper advertisement (ldquonewspaper clippingrdquo) that was placed indicating the name of the newspaper and date of publication
312 Photographs showing the notice displayed on site and a copy of the text displayed on the notice and
313 With regards to the written notices provided please note the following
bull If registered mail was sent a list of the registered mail sent as obtained from the post office must be provided
bull If regular mail was sent a list of the mail sent as obtained from the post office must be provided
bull If a facsimile was sent a copy of the facsimile report must be provided
bull If an electronic mail was sent a copy of the electronic mail sent and delivery reports must be provided and
bull If a ldquomail droprdquo was done a signed register of ldquomail dropsrdquo must be provided
Proof of public participation has been included in the revised BAR as follows bull Newspaper advertisement ndash Appendix F2 bull Site notice ndash Appendix F2 and bull Written notifications ndash Appendix F3 Please note that as e-mail addresses were available for all IampAPs registered on the database the formal notification letter was sent by means of electronic mail However delivery reports were not requested as this requirement is not stated in the relevant legislation nor in any guideline document on public participation of which we are aware Thus we have included a copy of the e-mail notification sent as adequate proof of distribution Hard copies of letters were delivered to representatives of commenting authorities proof of which is also included in Appendix F3
3 COMMENTS FROM SALDANHA BAY MUNICIPALITY 31 Critical
Biodiversity Areas
Mr E Mmbadi 20170410 1 Basic Assessment Report for the Proposed New Access Roads to the Saldanha Bay Industrial Development Zone dated 07 March 2017 refers
2 Even though the site is located outside the Critical Biodiversity Area it may function as a ldquostepping stonerdquo corridor that allows for animal and plant movement across the landscape Development within such sites should consider ecological connectivity of the landscape and care should be taken not to disrupt this connectivity especially for a site surrounded by Critical Biodiversity Areas
The draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest Western Cape Biodiversity Spatial Plan became available in April 2017 and was taken into consideration in the revised BAR which will be made available for a further review and comment period
32 Cumulative Mr E Mmbadi 20170410 3 The report should highlight the potential cumulative impacts of These comments have been noted As the
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
4
NO ISSUE NAME DATE COMMENT RESPONSE impact of construction on ambient air quality
several construction activities on ambient air quality Viewing the impacts of access roads construction in isolation may only reveal limited potential impacts on the ambient air quality The report should also look at the possible release of iron ore dust trapped on vegetation into the atmosphere
construction phase of the proposed project has not yet been scheduled it cannot be assumed that it will occur while other road construction projects in the area are in progress Reference to the implications of the possible release of iron ore dust trapped on vegetation for dust generation and control during the construction phase has been incorporated into the revised BAR (see Sections F2(b) and F615) and the Construction EMP (see Section 312(b))
33 Road maintenance after completion
Mr E Mmbadi 20170410 4 In most cases after the construction work is completed the roads are handed over to local authority to maintain and service If it is envisaged to hand over the proposed access roads to Saldanha Bay Municipality (ldquoSBMrdquo) the report should acknowledge such intention Also ensure that all the requirements from SBM with regard to roads are met Please contact Manager Roads amp Stormwater (jeremyjarvissbmgovza 022 701 7049) in this regard
The design engineers have engaged with SBM regarding the future management of the roads as is indicated by the following statement in the BAR ldquoSaldanha Bay Municipality has requested that the road reserve should be registered as a separate erf which would be a portion of this propertyrdquo (see Section A2)
34 Water use during construction phase
Mr E Mmbadi 20170410 5 SBM commenced with the implementation of level 3 water restriction Please advise if there is confirmation from the municipality with regard to the supply of water to the proposed development SBM discourages the use of potable water as a dust suppression measure or for any construction purpose please indicate the developmentrsquos potential water source The use of treated effluent from the waste water treatment works could be an option Please contact Manager of Bulk Water and Sanitation (gavinwilliamasbmgovza 022 701 7047) in this regard Also consult with the Department of Water and Sanitation with regard to the water use application process
These comments regarding water conservation have been noted and relevant measures to prevent the use of potable water for dust suppression have been included in the revised BAR (see Sections F2(b) F3 and E615 of the revised BAR and Section 312(a) of the Construction EMP) Please note that the road development would only require a limited supply of water during the construction phase which the Contractor would be required to source from available resources Consultation with DWS regarding a water use application may thus not be relevant
35 Palaeontological and archaeological findings
Mr E Mmbadi 20170410 6 Please inform the Environment amp Heritage Section of the SBM on any Palaeontological and Archaeological findings for our records
This request has been included in the revised BAR (see Section F617) as well as the Construction EMP (see Section 3102(e))
4 COMMENTS FROM CAPENATURE 41 Status of
vegetation types Alana Duffell-Canham
20170410 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road 1 The proposed eastern access road passes through an area
These comments regarding the status of the vegetation types on the project site have been noted On the basis of the botanical assessment undertaken as part of the Basic Assessment process the condition of the Saldahna Limestone
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
5
NO ISSUE NAME DATE COMMENT RESPONSE covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet [been] listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6 000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
Strandveld vegetation located on the limestone ridge has indeed been described as of high botanical sensitivity in the draft BAR As to the status of the vegetation please take cognisance of DEAampDPrsquos position that only the formal classification of vegetation in terms of NEMBA is considered applicable in relation to the NEMA EIA Regulations This was in response to our indication in the draft BAR that Saldahna Flats Strandveld which is classified ldquoVulnerablerdquo should be considered ldquoEndangeredrdquo on the basis of a 2014 CapeNature status report Please refer to Comment and Response 21 above We thus have to assume that DEAampDP would consider the formal classification of Saldahna Limestone Strandveld as ldquoLeast Threatenedrdquo in terms of NEMBA as applicable
42 Critical Biodiversity Areas
Alana Duffell-Canham
20170410 2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent land cover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truth where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data
A mentioned in Response 31 above the draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest WCBSP which became available in April 2017 has been taken into consideration in the revised BAR Our observation regarding the mapping of the CBAs is that this covers a large area on the specific property and extends notably further northwards than the intact vegetation on the limestone ridge According to the ground-truthing of the botanical
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
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SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
1
DRAFT BASIC ASSESSMENT REPORT (BAR)
COMMENTS AND RESPONSES REPORT
Written submissions were received from the following commenting authorities and other Interested and Affected Parties (IampAPs) during the BAR comment period
SUBMITTED BY METHOD AND DATE Authorities 1 West Coast District Municipality ndash Ms Doretha Kotze Email - 29 March 2017
2 Department of Environmental Affairs and Development Planning ndash Ms M Schippers Fax - 07 April 2017
3 Saldanha Bay Municipality ndash Mr E Mmbadi Email - 10 April 2017
4 CapeNature ndash Ms Alana Duffell-Canham Email - 11 April 2017
Other IampAPs 1 Phillips Group ndash Mr Jan Phillips Email - 10 March 2017
Copies of the written comments are attached as Attachment A to this report arranged according to the order indicated in the table above The comments received are presented in Table 1 below and have been categorised as follows A Authority comments and issues 1 Comments received from West Coast District Municipality
11 Implications of Draft EMF for Saldanha region 12 Servitudes on the property
2 Comments received from Department of Environmental Affairs and Development Planning 21 Applicable listed Activities 22 Originally signed and dated declarations 23 Proof of Public Participation
3 Comments received from Saldanha Bay Municipality 31 Critical Biodiversity Areas 32 Cumulative impact of construction on ambient air quality 33 Road maintenance after completion 34 Water use during construction phase 35 Palaeontological and archaeological findings
4 Comments received from CapeNature 41 Status of vegetation types 42 Critical Biodiversity Areas 43 Implications for proposed eastern access route alignment 44 Proposed north-south access road 45 Rights reserved
B Other IampAP comments and issues 1 Comments received from Phillips Group
11 Effect of proposed project on traffic flow and businesses in the area 2 Comments received from Afrisam
21 Late submission of comments 22 South-north access road currently under construction 23 Zoning of Farm 1139 24 Suggestions for amending proposed mitigation measures 25 Details regarding activity information
No importance should be given to the order in which the categories are presented
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
2
Table 1 Summary table of comments received on the draft BAR with responses from SLR and the project technical team as appropriate
NO ISSUE NAME DATE COMMENT RESPONSE
A AUTHORITY COMMENTS AND ISSUES
1 COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY 11 Implications of
Draft EMF for Saldanha region
Doretha Kotze 20170329 1 Your letter dated 9 March 2017 and the information contained in the Draft BAR for the proposal refer
2 The Environmental Management Framework (EMF) for the Saldanha region is currently being revisited as part of the drafting of the Greater Saldanha Regional Spatial Implementation Framework by the Western Cape Provincial Department of Environmental Affairs and Development Planning It is recommended that this proposal be aligned with the outcomes of the different studies being undertaken as part of the finalisation of the EMF since Farm 1139 is situated in an area that has been identified as a Conflict Area in terms of the Urban Conservation Zone and Industrial Development Zone For more information of the EMF process kindly contact Ryan Nel at GIBB Consulting (rnelgibbcoza or Tel 011 519 4600)
We have taken the Draft EMF into consideration in the revised BAR (refer to Section D2(c)) However the document has not yet been formally adopted Thus the implied action by the Saldanha Municipality namely to resolve the conflict in the process of updating their Spatial Development Framework has not yet been undertaken Thus the formal land use status of the property remains intended for industrial development
12 Servitudes on the property
Doretha Kotze 20170329 3 Several servitudes had been registered over Farm 1139 over the years accommodating power lines water pipelines and rights of way Two bulk water pipelines of the West Coast District Municipality traversing the property in the northwest will be crossed by the proposed new access roads Care should be taken during the construction phase to prevent negative impacts on these pipelines
The project design engineers are aware of the existence of servitudes As necessary application would be made for wayleaves from the district and local municipalities if any works occur near water or other bulk services infrastructure
2 COMMENTS FROM DEPARTMENT OF ENVIRONMENTAL AFFAIRS AND DEVELOPMENT PLANNING 21 Applicable listed
activities M Schippers 20170407 The draft BAR dated March 2017 and received by this Department
on 09 March 2017 refer 1 Applicable listed activities 11 It is noted that Activity 12 of GN No R985 is being applied for 12 Please note that the abovementioned activity is not applicable
to the proposed development since the vegetation occurring on the proposed site has not been classified as a critically endangered or endangered ecosystem in terms of the National Environmental Management Biodiversity Act of 2004 (ldquoNEMBArdquo) List of Threatened Ecosystems in Need of Protection December 2011)
13 This activity must be excluded from the application
We have noted the comments in Item 1 and have amended the revised BAR accordingly ndash see Sections A1(c) and B5(c) and (d)
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
3
NO ISSUE NAME DATE COMMENT RESPONSE 22 Originally signed
and dated declarations
M Schippers 07 April17 2 The duly dated and originally signed declarations as completed by the applicant the Environmental Assessment Practitioner and the specialists who compiled the specialist reports as part of the Environmental Impact Assessment Process must be included in the BAR to be submitted to the competent authority
The originally signed declarations will be included in the final BAR which will be submitted to your Department after the conclusion of the revised BAR comment period
23 Proof of public participation
M Schippers 07 April17 3 Proof of Public Participation 31 Proof of the public participation conducted must be included in
the BAR to be submitted to the competent authority please note that the proof must include inter alia the following
311 A copy of the newspaper advertisement (ldquonewspaper clippingrdquo) that was placed indicating the name of the newspaper and date of publication
312 Photographs showing the notice displayed on site and a copy of the text displayed on the notice and
313 With regards to the written notices provided please note the following
bull If registered mail was sent a list of the registered mail sent as obtained from the post office must be provided
bull If regular mail was sent a list of the mail sent as obtained from the post office must be provided
bull If a facsimile was sent a copy of the facsimile report must be provided
bull If an electronic mail was sent a copy of the electronic mail sent and delivery reports must be provided and
bull If a ldquomail droprdquo was done a signed register of ldquomail dropsrdquo must be provided
Proof of public participation has been included in the revised BAR as follows bull Newspaper advertisement ndash Appendix F2 bull Site notice ndash Appendix F2 and bull Written notifications ndash Appendix F3 Please note that as e-mail addresses were available for all IampAPs registered on the database the formal notification letter was sent by means of electronic mail However delivery reports were not requested as this requirement is not stated in the relevant legislation nor in any guideline document on public participation of which we are aware Thus we have included a copy of the e-mail notification sent as adequate proof of distribution Hard copies of letters were delivered to representatives of commenting authorities proof of which is also included in Appendix F3
3 COMMENTS FROM SALDANHA BAY MUNICIPALITY 31 Critical
Biodiversity Areas
Mr E Mmbadi 20170410 1 Basic Assessment Report for the Proposed New Access Roads to the Saldanha Bay Industrial Development Zone dated 07 March 2017 refers
2 Even though the site is located outside the Critical Biodiversity Area it may function as a ldquostepping stonerdquo corridor that allows for animal and plant movement across the landscape Development within such sites should consider ecological connectivity of the landscape and care should be taken not to disrupt this connectivity especially for a site surrounded by Critical Biodiversity Areas
The draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest Western Cape Biodiversity Spatial Plan became available in April 2017 and was taken into consideration in the revised BAR which will be made available for a further review and comment period
32 Cumulative Mr E Mmbadi 20170410 3 The report should highlight the potential cumulative impacts of These comments have been noted As the
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
4
NO ISSUE NAME DATE COMMENT RESPONSE impact of construction on ambient air quality
several construction activities on ambient air quality Viewing the impacts of access roads construction in isolation may only reveal limited potential impacts on the ambient air quality The report should also look at the possible release of iron ore dust trapped on vegetation into the atmosphere
construction phase of the proposed project has not yet been scheduled it cannot be assumed that it will occur while other road construction projects in the area are in progress Reference to the implications of the possible release of iron ore dust trapped on vegetation for dust generation and control during the construction phase has been incorporated into the revised BAR (see Sections F2(b) and F615) and the Construction EMP (see Section 312(b))
33 Road maintenance after completion
Mr E Mmbadi 20170410 4 In most cases after the construction work is completed the roads are handed over to local authority to maintain and service If it is envisaged to hand over the proposed access roads to Saldanha Bay Municipality (ldquoSBMrdquo) the report should acknowledge such intention Also ensure that all the requirements from SBM with regard to roads are met Please contact Manager Roads amp Stormwater (jeremyjarvissbmgovza 022 701 7049) in this regard
The design engineers have engaged with SBM regarding the future management of the roads as is indicated by the following statement in the BAR ldquoSaldanha Bay Municipality has requested that the road reserve should be registered as a separate erf which would be a portion of this propertyrdquo (see Section A2)
34 Water use during construction phase
Mr E Mmbadi 20170410 5 SBM commenced with the implementation of level 3 water restriction Please advise if there is confirmation from the municipality with regard to the supply of water to the proposed development SBM discourages the use of potable water as a dust suppression measure or for any construction purpose please indicate the developmentrsquos potential water source The use of treated effluent from the waste water treatment works could be an option Please contact Manager of Bulk Water and Sanitation (gavinwilliamasbmgovza 022 701 7047) in this regard Also consult with the Department of Water and Sanitation with regard to the water use application process
These comments regarding water conservation have been noted and relevant measures to prevent the use of potable water for dust suppression have been included in the revised BAR (see Sections F2(b) F3 and E615 of the revised BAR and Section 312(a) of the Construction EMP) Please note that the road development would only require a limited supply of water during the construction phase which the Contractor would be required to source from available resources Consultation with DWS regarding a water use application may thus not be relevant
35 Palaeontological and archaeological findings
Mr E Mmbadi 20170410 6 Please inform the Environment amp Heritage Section of the SBM on any Palaeontological and Archaeological findings for our records
This request has been included in the revised BAR (see Section F617) as well as the Construction EMP (see Section 3102(e))
4 COMMENTS FROM CAPENATURE 41 Status of
vegetation types Alana Duffell-Canham
20170410 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road 1 The proposed eastern access road passes through an area
These comments regarding the status of the vegetation types on the project site have been noted On the basis of the botanical assessment undertaken as part of the Basic Assessment process the condition of the Saldahna Limestone
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
5
NO ISSUE NAME DATE COMMENT RESPONSE covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet [been] listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6 000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
Strandveld vegetation located on the limestone ridge has indeed been described as of high botanical sensitivity in the draft BAR As to the status of the vegetation please take cognisance of DEAampDPrsquos position that only the formal classification of vegetation in terms of NEMBA is considered applicable in relation to the NEMA EIA Regulations This was in response to our indication in the draft BAR that Saldahna Flats Strandveld which is classified ldquoVulnerablerdquo should be considered ldquoEndangeredrdquo on the basis of a 2014 CapeNature status report Please refer to Comment and Response 21 above We thus have to assume that DEAampDP would consider the formal classification of Saldahna Limestone Strandveld as ldquoLeast Threatenedrdquo in terms of NEMBA as applicable
42 Critical Biodiversity Areas
Alana Duffell-Canham
20170410 2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent land cover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truth where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data
A mentioned in Response 31 above the draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest WCBSP which became available in April 2017 has been taken into consideration in the revised BAR Our observation regarding the mapping of the CBAs is that this covers a large area on the specific property and extends notably further northwards than the intact vegetation on the limestone ridge According to the ground-truthing of the botanical
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
2
Table 1 Summary table of comments received on the draft BAR with responses from SLR and the project technical team as appropriate
NO ISSUE NAME DATE COMMENT RESPONSE
A AUTHORITY COMMENTS AND ISSUES
1 COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY 11 Implications of
Draft EMF for Saldanha region
Doretha Kotze 20170329 1 Your letter dated 9 March 2017 and the information contained in the Draft BAR for the proposal refer
2 The Environmental Management Framework (EMF) for the Saldanha region is currently being revisited as part of the drafting of the Greater Saldanha Regional Spatial Implementation Framework by the Western Cape Provincial Department of Environmental Affairs and Development Planning It is recommended that this proposal be aligned with the outcomes of the different studies being undertaken as part of the finalisation of the EMF since Farm 1139 is situated in an area that has been identified as a Conflict Area in terms of the Urban Conservation Zone and Industrial Development Zone For more information of the EMF process kindly contact Ryan Nel at GIBB Consulting (rnelgibbcoza or Tel 011 519 4600)
We have taken the Draft EMF into consideration in the revised BAR (refer to Section D2(c)) However the document has not yet been formally adopted Thus the implied action by the Saldanha Municipality namely to resolve the conflict in the process of updating their Spatial Development Framework has not yet been undertaken Thus the formal land use status of the property remains intended for industrial development
12 Servitudes on the property
Doretha Kotze 20170329 3 Several servitudes had been registered over Farm 1139 over the years accommodating power lines water pipelines and rights of way Two bulk water pipelines of the West Coast District Municipality traversing the property in the northwest will be crossed by the proposed new access roads Care should be taken during the construction phase to prevent negative impacts on these pipelines
The project design engineers are aware of the existence of servitudes As necessary application would be made for wayleaves from the district and local municipalities if any works occur near water or other bulk services infrastructure
2 COMMENTS FROM DEPARTMENT OF ENVIRONMENTAL AFFAIRS AND DEVELOPMENT PLANNING 21 Applicable listed
activities M Schippers 20170407 The draft BAR dated March 2017 and received by this Department
on 09 March 2017 refer 1 Applicable listed activities 11 It is noted that Activity 12 of GN No R985 is being applied for 12 Please note that the abovementioned activity is not applicable
to the proposed development since the vegetation occurring on the proposed site has not been classified as a critically endangered or endangered ecosystem in terms of the National Environmental Management Biodiversity Act of 2004 (ldquoNEMBArdquo) List of Threatened Ecosystems in Need of Protection December 2011)
13 This activity must be excluded from the application
We have noted the comments in Item 1 and have amended the revised BAR accordingly ndash see Sections A1(c) and B5(c) and (d)
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
3
NO ISSUE NAME DATE COMMENT RESPONSE 22 Originally signed
and dated declarations
M Schippers 07 April17 2 The duly dated and originally signed declarations as completed by the applicant the Environmental Assessment Practitioner and the specialists who compiled the specialist reports as part of the Environmental Impact Assessment Process must be included in the BAR to be submitted to the competent authority
The originally signed declarations will be included in the final BAR which will be submitted to your Department after the conclusion of the revised BAR comment period
23 Proof of public participation
M Schippers 07 April17 3 Proof of Public Participation 31 Proof of the public participation conducted must be included in
the BAR to be submitted to the competent authority please note that the proof must include inter alia the following
311 A copy of the newspaper advertisement (ldquonewspaper clippingrdquo) that was placed indicating the name of the newspaper and date of publication
312 Photographs showing the notice displayed on site and a copy of the text displayed on the notice and
313 With regards to the written notices provided please note the following
bull If registered mail was sent a list of the registered mail sent as obtained from the post office must be provided
bull If regular mail was sent a list of the mail sent as obtained from the post office must be provided
bull If a facsimile was sent a copy of the facsimile report must be provided
bull If an electronic mail was sent a copy of the electronic mail sent and delivery reports must be provided and
bull If a ldquomail droprdquo was done a signed register of ldquomail dropsrdquo must be provided
Proof of public participation has been included in the revised BAR as follows bull Newspaper advertisement ndash Appendix F2 bull Site notice ndash Appendix F2 and bull Written notifications ndash Appendix F3 Please note that as e-mail addresses were available for all IampAPs registered on the database the formal notification letter was sent by means of electronic mail However delivery reports were not requested as this requirement is not stated in the relevant legislation nor in any guideline document on public participation of which we are aware Thus we have included a copy of the e-mail notification sent as adequate proof of distribution Hard copies of letters were delivered to representatives of commenting authorities proof of which is also included in Appendix F3
3 COMMENTS FROM SALDANHA BAY MUNICIPALITY 31 Critical
Biodiversity Areas
Mr E Mmbadi 20170410 1 Basic Assessment Report for the Proposed New Access Roads to the Saldanha Bay Industrial Development Zone dated 07 March 2017 refers
2 Even though the site is located outside the Critical Biodiversity Area it may function as a ldquostepping stonerdquo corridor that allows for animal and plant movement across the landscape Development within such sites should consider ecological connectivity of the landscape and care should be taken not to disrupt this connectivity especially for a site surrounded by Critical Biodiversity Areas
The draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest Western Cape Biodiversity Spatial Plan became available in April 2017 and was taken into consideration in the revised BAR which will be made available for a further review and comment period
32 Cumulative Mr E Mmbadi 20170410 3 The report should highlight the potential cumulative impacts of These comments have been noted As the
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
4
NO ISSUE NAME DATE COMMENT RESPONSE impact of construction on ambient air quality
several construction activities on ambient air quality Viewing the impacts of access roads construction in isolation may only reveal limited potential impacts on the ambient air quality The report should also look at the possible release of iron ore dust trapped on vegetation into the atmosphere
construction phase of the proposed project has not yet been scheduled it cannot be assumed that it will occur while other road construction projects in the area are in progress Reference to the implications of the possible release of iron ore dust trapped on vegetation for dust generation and control during the construction phase has been incorporated into the revised BAR (see Sections F2(b) and F615) and the Construction EMP (see Section 312(b))
33 Road maintenance after completion
Mr E Mmbadi 20170410 4 In most cases after the construction work is completed the roads are handed over to local authority to maintain and service If it is envisaged to hand over the proposed access roads to Saldanha Bay Municipality (ldquoSBMrdquo) the report should acknowledge such intention Also ensure that all the requirements from SBM with regard to roads are met Please contact Manager Roads amp Stormwater (jeremyjarvissbmgovza 022 701 7049) in this regard
The design engineers have engaged with SBM regarding the future management of the roads as is indicated by the following statement in the BAR ldquoSaldanha Bay Municipality has requested that the road reserve should be registered as a separate erf which would be a portion of this propertyrdquo (see Section A2)
34 Water use during construction phase
Mr E Mmbadi 20170410 5 SBM commenced with the implementation of level 3 water restriction Please advise if there is confirmation from the municipality with regard to the supply of water to the proposed development SBM discourages the use of potable water as a dust suppression measure or for any construction purpose please indicate the developmentrsquos potential water source The use of treated effluent from the waste water treatment works could be an option Please contact Manager of Bulk Water and Sanitation (gavinwilliamasbmgovza 022 701 7047) in this regard Also consult with the Department of Water and Sanitation with regard to the water use application process
These comments regarding water conservation have been noted and relevant measures to prevent the use of potable water for dust suppression have been included in the revised BAR (see Sections F2(b) F3 and E615 of the revised BAR and Section 312(a) of the Construction EMP) Please note that the road development would only require a limited supply of water during the construction phase which the Contractor would be required to source from available resources Consultation with DWS regarding a water use application may thus not be relevant
35 Palaeontological and archaeological findings
Mr E Mmbadi 20170410 6 Please inform the Environment amp Heritage Section of the SBM on any Palaeontological and Archaeological findings for our records
This request has been included in the revised BAR (see Section F617) as well as the Construction EMP (see Section 3102(e))
4 COMMENTS FROM CAPENATURE 41 Status of
vegetation types Alana Duffell-Canham
20170410 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road 1 The proposed eastern access road passes through an area
These comments regarding the status of the vegetation types on the project site have been noted On the basis of the botanical assessment undertaken as part of the Basic Assessment process the condition of the Saldahna Limestone
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
5
NO ISSUE NAME DATE COMMENT RESPONSE covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet [been] listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6 000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
Strandveld vegetation located on the limestone ridge has indeed been described as of high botanical sensitivity in the draft BAR As to the status of the vegetation please take cognisance of DEAampDPrsquos position that only the formal classification of vegetation in terms of NEMBA is considered applicable in relation to the NEMA EIA Regulations This was in response to our indication in the draft BAR that Saldahna Flats Strandveld which is classified ldquoVulnerablerdquo should be considered ldquoEndangeredrdquo on the basis of a 2014 CapeNature status report Please refer to Comment and Response 21 above We thus have to assume that DEAampDP would consider the formal classification of Saldahna Limestone Strandveld as ldquoLeast Threatenedrdquo in terms of NEMBA as applicable
42 Critical Biodiversity Areas
Alana Duffell-Canham
20170410 2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent land cover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truth where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data
A mentioned in Response 31 above the draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest WCBSP which became available in April 2017 has been taken into consideration in the revised BAR Our observation regarding the mapping of the CBAs is that this covers a large area on the specific property and extends notably further northwards than the intact vegetation on the limestone ridge According to the ground-truthing of the botanical
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
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SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
3
NO ISSUE NAME DATE COMMENT RESPONSE 22 Originally signed
and dated declarations
M Schippers 07 April17 2 The duly dated and originally signed declarations as completed by the applicant the Environmental Assessment Practitioner and the specialists who compiled the specialist reports as part of the Environmental Impact Assessment Process must be included in the BAR to be submitted to the competent authority
The originally signed declarations will be included in the final BAR which will be submitted to your Department after the conclusion of the revised BAR comment period
23 Proof of public participation
M Schippers 07 April17 3 Proof of Public Participation 31 Proof of the public participation conducted must be included in
the BAR to be submitted to the competent authority please note that the proof must include inter alia the following
311 A copy of the newspaper advertisement (ldquonewspaper clippingrdquo) that was placed indicating the name of the newspaper and date of publication
312 Photographs showing the notice displayed on site and a copy of the text displayed on the notice and
313 With regards to the written notices provided please note the following
bull If registered mail was sent a list of the registered mail sent as obtained from the post office must be provided
bull If regular mail was sent a list of the mail sent as obtained from the post office must be provided
bull If a facsimile was sent a copy of the facsimile report must be provided
bull If an electronic mail was sent a copy of the electronic mail sent and delivery reports must be provided and
bull If a ldquomail droprdquo was done a signed register of ldquomail dropsrdquo must be provided
Proof of public participation has been included in the revised BAR as follows bull Newspaper advertisement ndash Appendix F2 bull Site notice ndash Appendix F2 and bull Written notifications ndash Appendix F3 Please note that as e-mail addresses were available for all IampAPs registered on the database the formal notification letter was sent by means of electronic mail However delivery reports were not requested as this requirement is not stated in the relevant legislation nor in any guideline document on public participation of which we are aware Thus we have included a copy of the e-mail notification sent as adequate proof of distribution Hard copies of letters were delivered to representatives of commenting authorities proof of which is also included in Appendix F3
3 COMMENTS FROM SALDANHA BAY MUNICIPALITY 31 Critical
Biodiversity Areas
Mr E Mmbadi 20170410 1 Basic Assessment Report for the Proposed New Access Roads to the Saldanha Bay Industrial Development Zone dated 07 March 2017 refers
2 Even though the site is located outside the Critical Biodiversity Area it may function as a ldquostepping stonerdquo corridor that allows for animal and plant movement across the landscape Development within such sites should consider ecological connectivity of the landscape and care should be taken not to disrupt this connectivity especially for a site surrounded by Critical Biodiversity Areas
The draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest Western Cape Biodiversity Spatial Plan became available in April 2017 and was taken into consideration in the revised BAR which will be made available for a further review and comment period
32 Cumulative Mr E Mmbadi 20170410 3 The report should highlight the potential cumulative impacts of These comments have been noted As the
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
4
NO ISSUE NAME DATE COMMENT RESPONSE impact of construction on ambient air quality
several construction activities on ambient air quality Viewing the impacts of access roads construction in isolation may only reveal limited potential impacts on the ambient air quality The report should also look at the possible release of iron ore dust trapped on vegetation into the atmosphere
construction phase of the proposed project has not yet been scheduled it cannot be assumed that it will occur while other road construction projects in the area are in progress Reference to the implications of the possible release of iron ore dust trapped on vegetation for dust generation and control during the construction phase has been incorporated into the revised BAR (see Sections F2(b) and F615) and the Construction EMP (see Section 312(b))
33 Road maintenance after completion
Mr E Mmbadi 20170410 4 In most cases after the construction work is completed the roads are handed over to local authority to maintain and service If it is envisaged to hand over the proposed access roads to Saldanha Bay Municipality (ldquoSBMrdquo) the report should acknowledge such intention Also ensure that all the requirements from SBM with regard to roads are met Please contact Manager Roads amp Stormwater (jeremyjarvissbmgovza 022 701 7049) in this regard
The design engineers have engaged with SBM regarding the future management of the roads as is indicated by the following statement in the BAR ldquoSaldanha Bay Municipality has requested that the road reserve should be registered as a separate erf which would be a portion of this propertyrdquo (see Section A2)
34 Water use during construction phase
Mr E Mmbadi 20170410 5 SBM commenced with the implementation of level 3 water restriction Please advise if there is confirmation from the municipality with regard to the supply of water to the proposed development SBM discourages the use of potable water as a dust suppression measure or for any construction purpose please indicate the developmentrsquos potential water source The use of treated effluent from the waste water treatment works could be an option Please contact Manager of Bulk Water and Sanitation (gavinwilliamasbmgovza 022 701 7047) in this regard Also consult with the Department of Water and Sanitation with regard to the water use application process
These comments regarding water conservation have been noted and relevant measures to prevent the use of potable water for dust suppression have been included in the revised BAR (see Sections F2(b) F3 and E615 of the revised BAR and Section 312(a) of the Construction EMP) Please note that the road development would only require a limited supply of water during the construction phase which the Contractor would be required to source from available resources Consultation with DWS regarding a water use application may thus not be relevant
35 Palaeontological and archaeological findings
Mr E Mmbadi 20170410 6 Please inform the Environment amp Heritage Section of the SBM on any Palaeontological and Archaeological findings for our records
This request has been included in the revised BAR (see Section F617) as well as the Construction EMP (see Section 3102(e))
4 COMMENTS FROM CAPENATURE 41 Status of
vegetation types Alana Duffell-Canham
20170410 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road 1 The proposed eastern access road passes through an area
These comments regarding the status of the vegetation types on the project site have been noted On the basis of the botanical assessment undertaken as part of the Basic Assessment process the condition of the Saldahna Limestone
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
5
NO ISSUE NAME DATE COMMENT RESPONSE covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet [been] listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6 000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
Strandveld vegetation located on the limestone ridge has indeed been described as of high botanical sensitivity in the draft BAR As to the status of the vegetation please take cognisance of DEAampDPrsquos position that only the formal classification of vegetation in terms of NEMBA is considered applicable in relation to the NEMA EIA Regulations This was in response to our indication in the draft BAR that Saldahna Flats Strandveld which is classified ldquoVulnerablerdquo should be considered ldquoEndangeredrdquo on the basis of a 2014 CapeNature status report Please refer to Comment and Response 21 above We thus have to assume that DEAampDP would consider the formal classification of Saldahna Limestone Strandveld as ldquoLeast Threatenedrdquo in terms of NEMBA as applicable
42 Critical Biodiversity Areas
Alana Duffell-Canham
20170410 2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent land cover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truth where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data
A mentioned in Response 31 above the draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest WCBSP which became available in April 2017 has been taken into consideration in the revised BAR Our observation regarding the mapping of the CBAs is that this covers a large area on the specific property and extends notably further northwards than the intact vegetation on the limestone ridge According to the ground-truthing of the botanical
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
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The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
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SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
4
NO ISSUE NAME DATE COMMENT RESPONSE impact of construction on ambient air quality
several construction activities on ambient air quality Viewing the impacts of access roads construction in isolation may only reveal limited potential impacts on the ambient air quality The report should also look at the possible release of iron ore dust trapped on vegetation into the atmosphere
construction phase of the proposed project has not yet been scheduled it cannot be assumed that it will occur while other road construction projects in the area are in progress Reference to the implications of the possible release of iron ore dust trapped on vegetation for dust generation and control during the construction phase has been incorporated into the revised BAR (see Sections F2(b) and F615) and the Construction EMP (see Section 312(b))
33 Road maintenance after completion
Mr E Mmbadi 20170410 4 In most cases after the construction work is completed the roads are handed over to local authority to maintain and service If it is envisaged to hand over the proposed access roads to Saldanha Bay Municipality (ldquoSBMrdquo) the report should acknowledge such intention Also ensure that all the requirements from SBM with regard to roads are met Please contact Manager Roads amp Stormwater (jeremyjarvissbmgovza 022 701 7049) in this regard
The design engineers have engaged with SBM regarding the future management of the roads as is indicated by the following statement in the BAR ldquoSaldanha Bay Municipality has requested that the road reserve should be registered as a separate erf which would be a portion of this propertyrdquo (see Section A2)
34 Water use during construction phase
Mr E Mmbadi 20170410 5 SBM commenced with the implementation of level 3 water restriction Please advise if there is confirmation from the municipality with regard to the supply of water to the proposed development SBM discourages the use of potable water as a dust suppression measure or for any construction purpose please indicate the developmentrsquos potential water source The use of treated effluent from the waste water treatment works could be an option Please contact Manager of Bulk Water and Sanitation (gavinwilliamasbmgovza 022 701 7047) in this regard Also consult with the Department of Water and Sanitation with regard to the water use application process
These comments regarding water conservation have been noted and relevant measures to prevent the use of potable water for dust suppression have been included in the revised BAR (see Sections F2(b) F3 and E615 of the revised BAR and Section 312(a) of the Construction EMP) Please note that the road development would only require a limited supply of water during the construction phase which the Contractor would be required to source from available resources Consultation with DWS regarding a water use application may thus not be relevant
35 Palaeontological and archaeological findings
Mr E Mmbadi 20170410 6 Please inform the Environment amp Heritage Section of the SBM on any Palaeontological and Archaeological findings for our records
This request has been included in the revised BAR (see Section F617) as well as the Construction EMP (see Section 3102(e))
4 COMMENTS FROM CAPENATURE 41 Status of
vegetation types Alana Duffell-Canham
20170410 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road 1 The proposed eastern access road passes through an area
These comments regarding the status of the vegetation types on the project site have been noted On the basis of the botanical assessment undertaken as part of the Basic Assessment process the condition of the Saldahna Limestone
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
5
NO ISSUE NAME DATE COMMENT RESPONSE covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet [been] listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6 000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
Strandveld vegetation located on the limestone ridge has indeed been described as of high botanical sensitivity in the draft BAR As to the status of the vegetation please take cognisance of DEAampDPrsquos position that only the formal classification of vegetation in terms of NEMBA is considered applicable in relation to the NEMA EIA Regulations This was in response to our indication in the draft BAR that Saldahna Flats Strandveld which is classified ldquoVulnerablerdquo should be considered ldquoEndangeredrdquo on the basis of a 2014 CapeNature status report Please refer to Comment and Response 21 above We thus have to assume that DEAampDP would consider the formal classification of Saldahna Limestone Strandveld as ldquoLeast Threatenedrdquo in terms of NEMBA as applicable
42 Critical Biodiversity Areas
Alana Duffell-Canham
20170410 2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent land cover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truth where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data
A mentioned in Response 31 above the draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest WCBSP which became available in April 2017 has been taken into consideration in the revised BAR Our observation regarding the mapping of the CBAs is that this covers a large area on the specific property and extends notably further northwards than the intact vegetation on the limestone ridge According to the ground-truthing of the botanical
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
5
NO ISSUE NAME DATE COMMENT RESPONSE covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet [been] listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6 000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
Strandveld vegetation located on the limestone ridge has indeed been described as of high botanical sensitivity in the draft BAR As to the status of the vegetation please take cognisance of DEAampDPrsquos position that only the formal classification of vegetation in terms of NEMBA is considered applicable in relation to the NEMA EIA Regulations This was in response to our indication in the draft BAR that Saldahna Flats Strandveld which is classified ldquoVulnerablerdquo should be considered ldquoEndangeredrdquo on the basis of a 2014 CapeNature status report Please refer to Comment and Response 21 above We thus have to assume that DEAampDP would consider the formal classification of Saldahna Limestone Strandveld as ldquoLeast Threatenedrdquo in terms of NEMBA as applicable
42 Critical Biodiversity Areas
Alana Duffell-Canham
20170410 2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent land cover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truth where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data
A mentioned in Response 31 above the draft BAR indicated that there were no terrestrial or aquatic CBAs or ESAs within the study area which was accurate when the report was compiled in March 2017 However the latest WCBSP which became available in April 2017 has been taken into consideration in the revised BAR Our observation regarding the mapping of the CBAs is that this covers a large area on the specific property and extends notably further northwards than the intact vegetation on the limestone ridge According to the ground-truthing of the botanical
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
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SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
6
NO ISSUE NAME DATE COMMENT RESPONSE and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 2011 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
[Note The submission included a Google image of the study area and surrounding showing CBAs Please refer to the original version of the letter in Annexure A to this report]
assessment report for this proposed project the vegetation on the low-lying areas of the property is of low botanical value The rationale for mapping most of the property as ESAs given its location in the midst of existing industries and ongoing industrial development in the surrounding areas it thus not clear
43 Alignment of proposed eastern access road
Alana Duffell-Canham
20170410 4 Considering that the existing track through the limestone ridge can barely be considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326 m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30 ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be make for the impact to be reduced to medium
Please note that the updated project description in the revised BAR states that the road reserve would be 30 m wide It should be noted that although the full width of the road reserve would be proclaimed the cross section of the road that would be developed at this stage is 126 m The vegetation would not be disturbed in the undeveloped portion of the road but would in effect be maintained in its natural condition While the intention of the 30 m wide road reserve is to dual the road in the long term once traffic volumes have increased to warrant it there is no immediate prospect of developing a ldquodouble lane highwayrdquo and it is thus not entirely accurate to compare the existing dirt road with the barrier effect of a road of that scale
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
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SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
7
NO ISSUE NAME DATE COMMENT RESPONSE negative this would still require a biodiversity offset
5Based on the information presented in this application as well as other information as discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
The botanical specialist was requested to review the original botanical assessment report in the light of the WCBSP 2017 as well as these comments He provided a botanical statement in which he reviewed his original assessment and stated his agreement with the views of CapeNature that crossing the limestone ridge would result in HIGH NEGATIVE impacts on the vegetation The revised BAR has been amended accordingly It should be noted that a biodiversity offset has not been recommended in this case as the original extent of Saldanha Limestone Strandveld was small and it is not considered feasible to find a viable offset area within the scope of this process An alternative route for the proposed eastern access road was explored in response to CapeNaturersquos submission as well as the amended CBA mapping for the project site However based on the findings of the investigation as described in Section E(c) of the revised BAR it was concluded that a viable alternative does not exist
44 Proposed north-south access road
Alana Duffell-Canham
20170410 North-South Access Road 6 The north-south access road would have passed through
Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
These comments have been noted
45 Rights reserved Alana Duffell-Canham
20170410 CapeNature reserves the right to revise initial comments and request further information base on any additional information that may be received
These comments have been noted
B OTHER IampAP COMMENTS AND ISSUE 1 COMMENTS FROM PHILLIPS GROUP 11 Effect of
proposed project on traffic flow and businesses in the area
Jan Phillips 20170310 I am the owner of erf no 13 of 12737 situated at 63 Platinum street Saldanha The property services various small businesses and a Puma fuel service station Clearly as a businessman I welcome any development in the area
SLR provided the following response to Mr Phillips by e-mail on 31 March 2017 ldquoThank you for your comments contained in your letter of 10 March 2017 We have referred your enquiry to the Applicant and project design engineers
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
8
NO ISSUE NAME DATE COMMENT RESPONSE of my business Although your plans of new road links are fairly clear I find it hard to draw conclusions of how it would affect my fuel site Possibly you or somebody from your department could give me a clearer indication of how the effect if any of traffic flow on the main Saldanha Mykonos road will be affected Also to what extent the two new roads will in any way link up with the above main road
for input and can provide the following response To respond to your last question namely ldquoto what extent the two new roads will in any way link up with the main SaldanhaMykonos Roadrdquo first The proposed new eastern access road would link to the main SaldanhaMykonos Road (Main Road (MR) 559) as follows bull At its eastern end it would intersect with Minor
Road (OP) 7645 (Port Road) which in turn intersects with MR559 at its southern end
bull At its western end it would intersect with the new road which will provide access to the security entrance to the Saldanha Bay Industrial Development Zone (SBIDZ) which is currently under construction and will be open by mid-2017 This latter road (referred to as Street 2) will intersect with MR559 at its southern end
The proposed new north-south access road would link to MR599 via Street 2 given that its southern end would link to the northern end of Street 2 In relation to the anticipated effect on traffic flow on the main Saldanha Mykonos Road (MR559) The intersection between MR559 and Street 2 is currently under construction and will be open by mid-2017 Street 2 and its extension in the form of the proposed new north-south access road would both provide permanent links between the SBIDZ and MR559 as well as the businesses located along the eastern section of Platinum Street The proposed new eastern access road would be a permanent link between the SBIDZ and OP7645 Traffic from Platinum Street and the SBIDZ will therefore flow to both MR559 and OP7645 As the new bridge crossing of MR559 that is currently being constructed would cut off through traffic on Platinum Street businesses to the west of
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
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SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
9
NO ISSUE NAME DATE COMMENT RESPONSE the bridge would gain access to MR559 via the existing access point just south of your filling station Businesses to the east of the bridge would gain access via the new Street 2 from MR559 or from Port Road via the proposed new eastern access roadrdquo It should further be noted that as this is the nearest fuel station to the proposed SBIDZ local changes in the traffic flow proposed are not expect to affect customer visits materially
2 COMMENTS FROM AFRISAM 21 Late submission
of comments Gavin Venter 20170425 I was under the impression that these comments had been sent off
but I cannot find a record of this mail If possible please consider these items
The comments submitted by the landownerrsquos representative have been included in this Comments and Responses Report even though they were received after the closure of the comments period
22 South-north access road currently under construction
Gavin Venter 20170425 Executive Summary 1 No obvious mention has been made on the impact of the currently
under construction south-north access Road (Seems to have escaped a scoping reportEIA)
The south-north road currently under construction (also referred to as Street 2) was included in the Scoping and EIA study undertaken for the development of the SBIDZ and thus in the Environmental Authorisation issued in 2015 The project description has been amended in the revised BAR and now includes reference to Street 2
23 Zoning of Farm 1139
Gavin Venter 20170425 2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated as SPZ)
The Revised BAR has been amended to reflect the following regarding the property In terms of the Local Spatial Policy for Saldanha Bay (Plan 4 of the Saldanha Bay Municipality Spatial Development Framework 2011) the northern portion the property is designated ldquorestricted industryrdquo and the southern portion ldquorestricted development areardquo The most recent available zoning map in relation to the SBIDZ prepared by Urban Dynamics Western Cape Town and Regional Planners in November 2013 indicated the zoning status of the property as ldquosubdivision areardquo (see Section D1)
24 Suggestions for amending proposed mitigation
Gavin Venter 20170425 Paragraph 6 Possibly amend the following paragraphs to better state bull Demarcate as a No-go area during the construction stage the
remnant of Saldanha Flats Strandveld south of the
These suggestions have been considered as suggested However in respect to the first two bullet items it is
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
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TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
10
NO ISSUE NAME DATE COMMENT RESPONSE measures easternnorth-south access roads intersection and prohibit any
movement of construction vehicles and workers in these areas bull Demarcate during the construction stage the vegetation north
and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis to an unaffected area[s] of the road reserve (Moving these to another area in an industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocating unless to a defined unaffected area will not help)
not consider necessary to specify that the No-go areas relate to the construction phase as the mitigation measure is clearly intended to prohibit the movement of construction vehicles and workers in the indicated areas In respect to the third bullet item ldquoa designated safe receptor areardquo is specified This clearly states that an appropriate safe area should be identified which would not necessarily be confined to the road reserve or to the same property The implication is thus that the bulbs may be relocated to an existing conservation area suitable for the purpose In respect to the last bullet item the intention is also to identify a safe site in this case specifically on the limestone ridge on the property If approval is granted for the construction of the eastern access road the onus will be on the holder of the authorisation and hisher service providers to implement the mitigation measure
24 Details regarding activity information
Gavin Venter 20170425 Section A - Activity Information 1 The EastWest road cuts off the southern portion of the remainder
of Farm 1139 which will be an industrial facility and no logical access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoretically access opposite the entrance to Gold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road The understanding is the road will link up with Gold Street and not go higher One statement says 630 meters the next says the southern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2 1 Figures 2 to 4 conflict with Appendix B Site plans and description
in Executive summary where no mention is made of widening the
The activity information provided in the revised BAR has been amended as follows bull The project description refers to allowance for
accesses to the south of the proposed eastern access road and to the east of the proposed south-north access which responds to items 1 and 2 of the comments (see Section A1(b))
bull The proposed north-south road would be 700 m long and its northern end would intersect with Gold and Platinum Streets (see Sections A1(b) and Section A2) Relevant locality maps and site layout plans have been amended to reflect this accurately This responds to item 3 of the comments
bull The size of the property has been updated to reflect the information provided in item 4 of the comments (see Sections A2)
bull In respect to the last comment The road reserve
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
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This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
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SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
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TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Proposed new access roads to the Saldanha Bay IDZ Basic Assessment Report
SLR Ref 7201908300005 June 2017 Draft BAR Comments and Responses Report
11
NO ISSUE NAME DATE COMMENT RESPONSE NorthSouth road reserve to 54 meters on the Northern end of the proposed south-north road would be 30 m
wide Its southern end would link with Street 2 (at the same point as the western end of the proposed eastern access road) at the intersection provided for in the wider road reserve associated with Street 2 The project description has been updated to clearly reflect this information (see Section A1(b))
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
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SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
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SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
ATTACHMENT A
COMMENTS RECEIVED ON THE DRAFT BAR
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
Ena de Villiers SLR Consulting By email edevilliersslrconsultingcom Dear Ms De Villiers Re Proposed new access roads to the Saldanha Bay Industrial Development Zone ndash Draft Basic Assessment Report DEAampDP ref 16331F417301117 CapeNature would like to thank you for the opportunity to comment on the proposed access roads and wish to make the following comments Eastern Access Road
1 The proposed eastern access road passes through an area covered by Saldanha Flats Strandveld and Saldanha Limestone Strandveld In an effort to utilize best available science (including the abovementioned land cover and ecosystem mapping datasets) and to generate figures which more accurately reflect the current degree of habitat loss in the Western Cape CapeNature has recently produced updated provincial ecosystem status statistics in accordance with the National principles criteria and approach1 The key findings relevant to this study show that under criterion A1 (irreversible loss of habitat) Saldanha Flats Strandveld which only has less than 35 of its original extent remaining meets the criteria for listing as Endangered in terms of Section 52 of the Biodiversity Act Although Saldanha Limestone Strandveld is not yet listed as a threatened ecosystem it must be remembered that the original extent of this vegetation type was very small relative to many other habitats (less than 6000 hectares) and thus should be treated differently when the listings were done Both of these vegetation types have undergone extensive loss in the Saldanha Bay region due to industrial urban and mining development over the last few years The Saldanha Flats Strandveld portion of the site has been previously heavily disturbed and is of low conservation value However the Saldanha Limestone Strandveld vegetation located on the limestone ridge is mostly intact and contains several endemic Species of Conservation Concern and is regarded of high botanical sensitivity (this was also confirmed by the botanical specialist for this application)
1 Government Gazette 34809 No 1002 National list of ecosystems that are threatened and in need of protection National
Environmental Management Biodiversity Act 9 December 2011
SCIENTIFIC SERVICES
postal Private Bag X5014 Stellenbosch 7599
physical Assegaaibosch Nature Reserve Jonkershoek
website wwwcapenaturecoza
enquiries Alana Duffell-Canham
telephone +27 21 866 8000 fax +27 21 866 1523
email aduffell-canhamcapenaturecoza
reference SSD14261841139_Roads_IDZ
date 11 April 2017
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
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The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
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SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
2 CapeNature recently produced the Western Cape Biodiversity Spatial Plan (WCBSP) (released as a ldquobetardquo version last year and released as the final version2 in March of this year) The WCBSP replaces the previous Western Cape Biodiversity Framework and Biodiversity Sector Plans The WCBSP has made use of far more recent landcover imagery which was not available for the entire province previously and has also made use of data obtained from ground-truthing where available Every effort was made to avoid conflict in known industrial and urban expansion areas but where certain features and remnants were considered irreplaceable it was still necessary to select them as Critical Biodiversity Areas (CBAs) The area of Saldanha surrounding the IDZ was one area where we were fortunate to obtain detailed ground-truthing data and make use of numerous studies done in the area A notable study is one that was conducted by Nick Helme which was conducted specifically for the IDZ in 20113 This study made recommendations on which areas should be included as CBAs and also which areas no longer qualified as CBAs (either due to new disturbance or being in a condition where rehabilitation was no longer considered to be feasible) It should be noted that detailed ground-truthing was undertaken for this study as well as use of CREW data
3 One of the areas confirmed as qualifying as CBA includes the limestone ridge that will be heavily impacted should the access road be authorised This recommendation was taken up in our WCBSP 2016 Beta version and in our final 2017 version See Figure 1 below This area has become of higher conservation importance due to losses elsewhere It should also be noted that one of the reasons Afrisam avoided placing their processing plant on or near this limestone ridge was because they already have an environmental authorisation condition which requires an offset for the loss of Saldanha Limestone Strandveld on their mining site
Figure 1 Critical Biodiversity Areas (indicated in green)on and around the study area as determined for
the Western Cape Biodiversity Spatial Plan 2017 (Image created using Cape Farm Mapper)
4 Considering that the existing track through the limestone ridge can barely be
considered a ldquotwee-spoorrdquo track and that the proposed access road has a road reserve of 326m (and there is clear intention to widen the road and make use of this road reserve in the future) CapeNature is of the opinion that aligning the road along the existing track is not sufficient mitigation to reduce the impact from high to medium negative especially given that the botanical specialist for this study (as well as other
2 Shapefiles are available via SANBIs BGIS website (bgissanbiorg) and maps are available for viewing on Cape Farm Mapper
(giselsenburgcomappscfm) 3 Nick Helme Botanical Inputs to Saldanha IDS Western Cape Compiled for MEGA Cape Town 8 November
2011
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
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SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
The Western Cape Nature Conservation Board trading as CapeNature
Board Members Ms Merle McOmbring-Hodges (Chairperson) Dr Colin Johnson (Vice Chairperson) Mr Mervyn Burton Prof Denver Hendricks Dr
Bruce McKenzie Adv Mandla Mdludlu Mr Danie Nel Prof Aubrey Redlinghuis Mr Paul Slack
studies) has confirmed that the site has high botanical sensitivity The road will essentially bisect a 30ha area which will further fragment the remnant and create additional edge effects A double lane highway will certainly provide a greater barrier to ecological processes than a dirt track This will place the long-term ability of the communities on site to persist into question Even if the argument could be made for the impact to be reduced to medium negative this would still require a biodiversity offset
5 Based on the information presented in this application as well as other information as
discussed above CapeNature objects to the eastern access road as proposed and suggest that alternative routing be explored
North-South Access Road
6 The north-south access road would have passed through Saldanha Flats Strandveld but has become heavily degraded largely due to overgrazing on the property We do not object to the proposed north-south access road
CapeNature reserves the right to revise initial comments and request further information based on any additional information that may be received Yours sincerely
Alana Duffell-Canham For Manager (Scientific Services)
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
From Gavin VenterTo Mandy KulaSubject Fw PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO 16331F417301117)
NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEW AND COMMENTDate 25 April 2017 102347 AMAttachments ATT00002png
Exec Summary - Basic Assessment Report (9Mar17)pdfLet BAR Notification (9Mar17)pdf
Mandy Hi
I was under the impression that these comments had been sent off but I cannot find a record of this mail If possible pleaseconsider these items
Executive Summary
1 No obvious mention has been made on the impact of the currently under construction south - north access Road (Seemsto have escaped a scoping reportEIA)
2 Paragraph 4 incorrectly states that Farm 1139 is zoned industrial (In the current valuation from the SBM it is stated asSPZ)
3 Paragraph 6
Possibly amend the following paragraphs to better state
bull Demarcate as a No-go area during the construction stagethe remnant of Saldanha Flats Strandveld south of theeasternnorth-south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate during the construction stagethe vegetation north and south of the construction zone on the limestone ridge asNo-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularlyBoophone haemanthoides and Brunsvigia orientalis to an unaffected areas of the road reserve (Moving these to another area inan industrial property does not make sense)
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outsideof the development footprint (Not sure how successful this statement is Farm 1139 is an envisaged industrial site and relocatingunless to a defined unaffected area will not help
Section A - Activity Information
1 The EastWest road cuts off the southern portion of the remainder of Farm 1139 which will be an industrial facility and nological access has been provided PRE has already stated that no additional access will be tolerated off the OP
2 Similar comment for the area allocated to the future gas to power plant Could theoreticall access opposite the entrance toGold Street (See point below)
3 Figure A2 to A5 (Maps) and are contradictory and show different lengths of the planned NS access road Theunderstanding is the the road will link up with Gold Street and not go higher One statement says 630 meters the next says thesouthern entrance of Duferco (820 m)
4 Page 3 Part 2 Small Technicality Remainder of Farm 1139 is 18024 Ha and no longer 196 Ha
Appendix D2
1 Figures 2 to 4 conflict with Appendix B Site plans and description in Executive summary where no mention is made ofwidening the NorthSouth road reserve to 54 meters on the Northern end
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
SLR Consulting (South Africa) (Pty) Ltd Page iv
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
EXECUTIVE SUMMARY 1 INTRODUCTION The Applicant Saldanha Bay IDZ Licencing Company SOC Ltd (SBIDZ-LC) is proposing to develop two new access roads to the Saldanha Bay Industrial Development Zone (SBIDZ) (see Figure 1) The proposed additions to the road network for the SBIDZ would entail the following bull A new eastern access road and new intersection on Minor Road (OP) 7645 in order to provide
access to the SBIDZ area to the north of Main Road (MR) 559 as well as to a new Afrisam cement plant and
bull A new north-south access road along the SBIDZ eastern boundary to provide an alternative access to the Duferco steel processing plant
SMEC South Africa (Pty) Ltd (SMEC) has been appointed to undertake the design and construction supervision of the access road In turn SMEC appointed SLR Consulting (South Africa) (Pty) Ltd (SLR) as the independent environmental assessment practitioner responsible for undertaking the required Environmental Authorisation (EA) process for the proposed project This Basic Assessment Report (BAR) and Environmental Management Programme Report (EMPR) has been distributed for a 30-day public review and comment period from 10 March to 10 April 2017 (including an additional day to cover the public holiday on 21 March 2017) Copies of the report have been made available at the following locations bull Saldanha Public Library bull Offices of SLR and bull On the following website wwwslrconsultingcomza Any written comments on the BAR and EMPR must reach SLR at the following contact details by no later than 10 April 2017
SLR Consulting (Pty) Ltd Unit 39 Roeland Square
30 Drury Lane Cape Town 8001
Attention Ena de Villiers
Tel (021) 461 1118 9 Fax (021) 461 1120
E-mail edevilliersslrconsultingcom
After the comment period the BAR and EMPR will be submitted to the Department of Environmental Affairs and Development Planning (DEAampDP) for consideration of the application All comments received will be collated into a Comments and Responses Report which will be submitted to DEAampDP together with the report After DEAampDP has reached a decision all registered Interested and Affected Parties (IampAPs) will be notified of the outcome of the application and the reasons for the decision A statutory Appeal Period in terms of the National Appeal Regulations 2014 will follow the issuing of the decision 2 APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) R982) promulgated in terms of the National Environmental Management Act No 107 of 1998 (NEMA) as amended as the proposed project triggers the following listed activities in terms of GN R983 and GN R985 of the regulations
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
SLR Consulting (South Africa) (Pty) Ltd Page v
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
GN R983 Listed Activities ndash Listing Notice 1 Project Description 24 The development of ndash
(ii) a road with a reserve wider than 135 meters or where no reserve exists where the road is wider than 8 metres hellip
but excluding ndash (b) roads where the entire road falls within an urban area
The proposed eastern access road reserve would be 326 m wide The road reserve for the north-south road would be 30 m wide except at the southern end where it would be 54 m wide in order to accommodate the intersection with the eastern access road
GN R985 Listed Activities ndash Listing Notice 3 Project Description 12 The clearance of an area of 300 square metres or more of
indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan (a) In Western Cape i Within any critically endangered or endangered
ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004
The proposed project would require the removal of more than 300 m2 of two indigenous vegetation types Saldanha Limestone Strandveld is classified as Least Threatened and Saldanha Flats Strandveld as Vulnerable in terms of Section 52 of NEMBA A 2014 CapeNature (Pence 2014) status update document however increased the threat status to Endangered and it is thus assessed as such
18 The widening of a road by more than 4 metres or the lengthening of a road by more than 1 kilometre (f) ) In Western Cape i All areas outside urban areas (aa) Areas containing indigenous vegetation hellip
The development of the proposed intersection between the new eastern access road and the existing OP7645 would entail the widening of the latter road by approximately 55 m at the intersection point
3 PROJECT DESCRIPTION The additional access roads are required to facilitate heavy freight access to the SBIDZ which was officially designated in October 2013 It is regarded as an important development node to foster economic growth in the West Coast region by utilising existing resources such as Saldanha Bayrsquos deep-water port neighbouring industrial areas and undeveloped land in the area The overall implications of increased traffic volume linked to the SBIDZ were assessed in the overarching EIA process undertaken for the SBIDZ for which an EA was issued in November 2015 The development of internal road networks associated with Phases 1 and 2 of the SBIDZ development which was authorised in terms of that process is nearing completion The currently proposed eastern access road was included as a potential future road link in the original SBIDZ EIA The Western Cape Government Department of Transport and Public Works (DTPW) also plans a range of road network improvements required to support economic development in the Saldanha Bay area This would ultimately include a designated freight route along the R45 from Saldanha to the N7 just north of Malmesbury These improvements include the upgrading of Trunk Road (TR) 85 Section 1 between the R27 and MR238 The upgrading of TR85 would inter alia entail the development of the Port Road interchange at the TR85OP7645 (Port Road) Intersection OP7654 would be upgraded to a Main Road The proposed new eastern access road would provide an additional access point to the SBIDZ from this access route while at the same time providing access to the proposed new Afrisam cement plant that is to be developed on Erf 1139 to the west of OP7645 The proposed south-north access road would provide an additional access point to the existing Duferco steel processing plant located to the north-west of Erf 1139 The proposed project would comprise the following project components (1) Development of an eastern access road The proposed eastern access road would be located between OP7645 and the eastern entrance into the Saldanha Bay IDZ The road would be a two-lane asphalt surfaced road with surfaced shoulders The subsurface layer would consist of gravel and cement stabilized layers that would be raised above the
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
SLR Consulting (South Africa) (Pty) Ltd Page vi
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
natural ground level to reduce cutting into the natural calcrete The typical road cross section would be 126 m consisting of a 37 m lane in each direction with a 2 m surfaced shoulder and a 06 m unsurfaced road edge on each side Provision would be made for a turning lane to the right at the Afrisam entrance where the road cross section would increase to 16 m to accommodate the 34 m wide additional turning lane Three drainage culverts would be constructed to avoid ponding of water next to the proposed road at km 005km km 083 and km 110 The road would be located in a 326 m wide road reserve with a view to future road dualling by the addition of a second carriageway to the north of the initial alignment when necessary due to increased traffic volumes The construction of an intersection at the eastern end of the new access road would require the widening of OP7645 The existing road width of 116 m would be increased at the intersection to 155 m in order to accommodate a 34 m wide right turning lane (2) Development of a south-north access road The proposed south-north access road would extend approximately 630 m along the eastern boundary of the SBIDZ from its (the SBIDZrsquos) eastern entrance up to the Duferco steel processing plant The road would have a similar asphalt surface and similar pavement structure to the proposed eastern access road A sidewalk would be constructed on the one side of the road and a concrete lined side drain on the other The typical road cross section would be approximately 12 m consisting of a 4 m lane in each direction with a 15 m sidewalk on the one side and a 24 m concrete lined side drain on the other The road would typically be located in a 30 m wide road reserve except at the southern end where the reserve would be 54 m wide to provide for the intersection at the SBIDZ eastern entrance 4 AFFECTED ENVIRONMENT The access roads would be located on the remainder of Erf 1139 on the coastal plain approximately 13 km from the shoreline north of the Saldanha Bay Port and 4 km north-east of the town of Saldanha The property comprises open land which has historically been used for agriculture (cultivation and grazing) but is now zoned for industrial use It is surrounded by roads and industrial plants The proposed eastern access road would traverse the property from east to west crossing a limestone ridge which is located midway along the route and extends for approximately 250 m westwards The ridge is a few metres higher in elevation than the surrounding lower-lying areas which are approximately 20 m above mean sea level The proposed north-east access road would traverse flat terrain along the western boundary of the property adjacent to the SBIDZ The two vegetation types originally present on the site are Saldanha Limestone Strandveld and Saldanha Flats Strandveld The former is classified as Least Threatened and the latter as Vulnerable in terms of Section 52 of NEMBA However the threat status of Saldanha Flats Strandveld has been updated to Endangered in a 2014 CapeNature status update document1 and it is thus assessed as such The vegetation and habitat on the low-lying areas of the proposed access road routes (originally Saldanha Limestone Strandveld and Saldanha Flats Strandveld) is highly degraded as a result of cultivation and overgrazing The botanical sensitivity is regarded as very low apart from the presence of some geophytes The Saldanha Limestone Strandveld vegetation and habitat located on the low limestone ridge is mostly intact and harbours endemic species This vegetation is thus regarded as of high botanical sensitivity There are no watercourses or aquatic ecosystems on site
1 Pence Genevieve QK (2014) Western Cape Biodiversity Framework 2014 Status Update Critical Biodiversity Areas of the
Western Cape Unpublished CapeNature project report Cape Town South Africa
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
SLR Consulting (South Africa) (Pty) Ltd Page vii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
5 ENVIRONMENTAL IMPACT STATEMENT A summary of the potential impact of the proposed project is provided in Table 1 The proposed new access roads which would improve access to industrial sites in the SBIDZ and its immediate surrounds would form part of a larger road network upgrade and development project undertaken in the area in support of the SIP5 Saldanha-Northern Cape Development Corridor project As such the proposed project would contribute to economic growth and development in the area resulting in an impact of LOW (positive) significance Table 1 Impacts during the construction phase (all impacts are negative unless stated otherwise)
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation Loss of vegetation and habitat ndash low-lying areas
Low VERY LOW
Loss of vegetation and habitat ndash limestone ridge
High MEDIUM
Socio-economic Aspects Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust noise and visual Low VERY LOW Cultural-historical Aspects Archaeology and Heritage NO IMPACT Palaeontology High HIGH (POSITIVE) Table 82 Impacts during the operational phase
Impact Significance without mitigation
Significance with mitigation
Geographical and Physical Aspects NO IMPACT Biological Aspects Vegetation NO IMPACT Socio-economic Aspects Contribution to economic growth and development Low (Positive) LOW (POSITIVE)
Cultural-historical aspects NO IMPACT Table 83 Impacts associated with the No-Go Option
Impact Significance without mitigation
Significance with mitigation
Transport infrastructure Low LOW The proposed mitigation measures would reduce the impacts on biological aspects to a VERY LOW to MEDIUM significance The loss of an area of mostly intact Saldanha Limestone Strandveld of high botanical sensitivity located on the limestone ridge as a result of the development of the eastern access road would be contained to a MEDIUM significance impact after mitigation A crucial aspect of the mitigation was already implemented at the design phase namely amending the horizontal alignment of the road to coincide with an existing footpath along the limestone ridge in order to minimise this potential impact (refer to Section E(c) in this regard) The botanical specialist concluded that the overall impacts would be within acceptable limits if adequate mitigation is applied and indicated that the proposed road is supported from a botanical perspective The only other negative impacts of the proposed project relate to noise dust and visual impacts associated with construction phase activities These have been rated as of VERY LOW significance after mitigation The No-Go Option would mean that there would be no development of new access roads to the SBIDZ and thus no provision for the road network to support the expected industrial development projects and
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
SLR Consulting (South Africa) (Pty) Ltd Page viii
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
economic development potential related to SIP5 The No-Go Option is not considered to be a sustainable or desirable option and would result in an impact of LOW significance All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially environmentally and economically acceptable 6 RECOMMENDATIONS It is recommended that the following mitigation measures be implemented if an Environmental Authorisation is issued for the proposed project Vegetation bull Restrict construction activities to the construction zone bull Demarcate as a No-go area the remnant of Saldanha Flats Strandveld south of the easternnorth-
south access roads intersection and prohibit any movement of construction vehicles and workers in these areas
bull Demarcate the vegetation north and south of the construction zone on the limestone ridge as No-go areas and prohibit any movement of construction vehicles and workers in these areas
bull Locate lift and relocate the geophytes occurring on the footprint of the road to a designated safe receptor area particularly Boophone haemanthoides and Brunsvigia orientalis
bull Relocate any Aloe perfoliata that falls within the proposed road reserve area to a safe site on the limestone ridge outside of the development footprint
bull Undertake a revegetation programme to re-instate vegetation on the limestone ridge in the road reserve adjacent to the new eastern access road
bull Retain and mulch all vegetation removed on the limestone ridge and use the mulched material for rehabilitation post-construction
Employment bull Local BEE services and providers and local labour from the local community should be employed as
far as possible bull The appointed contractor must comply with the Proponentrsquos labour and procurement specifications bull Ensure appropriate training is provided where required Compliance with environmental specifications listed in the Construction EMP bull The proposed project must comply with the environmental specifications listed in the Construction
EMP Where appropriate the proposed mitigation measures have been incorporated in the Construction EMP Key mitigation includes o Site demarcation o No-go areas o Palaeontological monitoring at cuttings and o Rehabilitation of disturbed areas
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
SLR Consulting (South Africa) (Pty) Ltd Page ix
SLR Ref 7201908300005 Report No 1
Proposed new access roads to the Saldanha Bay IDZ BAR and EMPR March 2017
Figure 1 Locality map (Google Earth image) of the proposed access roads layout (red lines) and project site (purple outline)
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
AfriSam is a Level 4 B-BBEE contributor To view AfriSams legal disclaimer please go to httpwwwafrisamcomlegaldisclaimer
----- Forwarded by Gavin VenterSSCZAFAfriSam on 25042017 1014 -----
MainDocument
Mandy Kulaltmkulaslrconsultingcomgt
1503 0826 GMT
Basics
DocumentTypeSubject PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE (DEAampDP REF NO
16331F417301117) NOTIFICATION OF REGISTRATION AS AN IampAP AND AVAILABILITY OF DBAR FOR REVIEWAND COMMENT
Category P 01-5 Property P 03-3 EIA Studies P 04-3 Legal Contract Aspects - Inc Servitude Registration etc P 08-9 - CorrespondenceIDZ
AssociatedEventAssociatedSubteam(s)
Reviewers (optional)
Review By Date ltNo due dategt Status Open To change the status click the Edit Document button
Reviewers ltno reviewersgt
Dear Sirs Madams We write to inform you about the availability of the Basic Assessment Report (BAR) for the above-mentioned proposed project for a 30-day
review and comment period from 10 March to 10 April 2017 (including one additional day to cover the intervening publicholiday on 21 March 2017) The following documentation regarding this matter is attached for you information
A notification letter andA copy of the Executive Summary of the BAR
A full copy of the Environmental Authorisation is available for download at the following link httpslrconsultingcomzaslr-documentsproposed-new-access-roads-to-the-idz Please feel free to contact us with any enquiries Best regards Mandy KulaTechnical AssistantSLR Consulting
SLR Consulting (Cape Town office)Unit 39 Roeland Square
Cnr Roeland Street and Drury Lane Cape Town 8001 South Africa
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Confidentiality Notice and Disclaimer
This communication and any attachment(s) contains information which is confidential and may also be legally privileged It is intended for the exclusive use of therecipient(s) to whom it is addressed If you are not the intended recipient any disclosure copying distribution or any action taken or omitted to be taken in reliance onit is prohibited and may be unlawful If you have received this communication in error please email us by return mail and then delete the email from your systemtogether with any copies of it Please note that you are not permitted to print copy disclose or use part or all of the content in any way
Emails and any information transmitted thereunder may be intercepted corrupted or delayed As a result SLR does not accept any responsibility for any errors oromissions howsoever caused and SLR accepts no responsibility for changes made to this email or any attachment after transmission from SLR Whilst all reasonableendeavours are taken by SLR to screen all emails for known viruses SLR cannot guarantee that any transmission will be virus free
Any views or opinions are solely those of the author and do not necessarily represent those of SLR Management Ltd or any of its subsidiaries unless specificallystated
SLR Consulting (South Africa) (Proprietary) Limited and SLR Consulting (Africa) (Proprietary) Limited are both subsidiaries of SLR Management LtdRegistered Office Unit 7 Fourways Manor Office Park Cnr Roos and Macbeth Street Fourways 2191 Gauteng South Africa
Disclaimer
The information contained in this communication from the sender is confidential It is intended solely for use by the recipient andothers authorized to receive it If you are not the recipient you are hereby notified that any disclosure copying distribution or takingaction in relation of the contents of this information is strictly prohibited and may be unlawful
This email has been scanned for viruses and malware and automatically archived by Mimecast SA (Pty) Ltd an innovator inSoftware as a Service (SaaS) for business Mimecast Unified Email Management trade (UEM) offers email continuity securityarchiving and compliance with all current legislation To find out more contact Mimecast itevomcid
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Appendices cover pagespdf
APPENDIX B
Database_7 March17pdf
2 col (Organisation) amp Name sort Org
Site Notice Rev 0 (16 Jan 2017) - finalpdf
SLR CONTACT DETAILS
TEL (021) 461 11189 FAX (021) 461 1120
EMAIL edevilliersslrconsultingcom
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Database_5June17pdf
2 col (Organisation) amp Name sort Org
Advert - new access roads (March 2017)pdf
BASIC ASSESSMENT FOR PROPOSED NEW ACCESS ROADS TO THE SALDANHA BAY INDUSTRIAL DEVELOPMENT ZONE
NOTICE NO SEMC03AR 022017 DEAampDP REF NO 16331F417301117
Application for Environmental Authorisation (EA) to undertake the following activities
The proposed project triggers Listed Activities in terms of the EIA Regulations 2014 promulgated in terms of NEMA namely Government Notices (GN) R983 (Listing Notice 1) Activity 24 and R985 (Listing Notice 3) Activities 12 and 18 A Basic Assessment is required in order to apply for EA
Opportunity to participate In accordance with the EIA Regulations (GN R982) you andor your organisation are hereby invited to register as an Interested and Affected Party (IampAP) and comment on the Basic Assessment Report (BAR) for the proposed project The BAR has been made available for a 30-day comment period from 10 March to 10 April 2017 (including an additional day to cover the intervening public holiday) Please contact SLR (at the contact details below) should you wish to register as an IampAP Any comment should be submitted by no later than 10 April 2017
Draft BAR Comments and Response Report - Rev1 8 June 2017pdf
METHOD AND DATE
SUBMITTED BY
AUTHORITY COMMENTS AND ISSUES
A
COMMENTS FROM WEST COAST DISTRICT MUNICIPALITY
1
Draft BAR Comments and Response Report - Rev1 8 June 2017 last editpdf
