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Final Environmental Assessment: Vleesbaai Boat launching site
Charl de Villiers Environmental Consulting cc
FINAL
APPLICATION FOR THE REGISTRATION OF THE
VLEESBAAI BOAT LAUNCHING SITE
VLEES BAY
DEA&DP
Charl de Villiers
Boat being retrieved at Noordstrand launching
Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc
INAL ENVIRONMENTAL ASSESSMENT
APPLICATION FOR THE REGISTRATION OF THE
BOAT LAUNCHING SITE AT NOORDSTRAND,
VLEES BAY, WESTERN CAPE
DEA&DP Ref: E16/2/4 VLEES BAY HOLIDAY RESORT
8 May 2010
Prepared by
Charl de Villiers Environmental Consulting cc
on behalf of
Mr Hannes van Jaarsveldt
Vleesbaai Bootklub
PO Box 307
PAARL
7620
Boat being retrieved at Noordstrand launching site, Vleesbaai December 2009
1
APPLICATION FOR THE REGISTRATION OF THE
NOORDSTRAND,
site, Vleesbaai December 2009
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
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This environmental assessment has been undertaken in terms of Reg 7(4)(ii) of the ‘Off-
road Vehicle (ORV) Regulations’, amended by GN R.1426 of 7 December 2004, which
stipulate that a licence for boat launching sites shall only be issued if the applicant – in this
instance the Vleesbaai Bootklub – complies with the requirements of section 24(4) of the
National Environmental Management Act 107 of 1998 as amended, i.e. the provision
relating to the investigation, assessment and communication of the potential impact of
the activities associated with boat launching at the site.
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TABLE OF CONTENTS
1 EXECUTIVE SUMMARY (Unrevised)
16 – 11
2 MINIMUM PROCEDURES FOR THE INVESTIGATION, ASSESSMENT AND
COMMUNICATION OF THE POTENTIAL CONSEQUENCES OR IMPACTS OF
ACTIVITIES ON THE ENVIRONMENT
12 - 15
2.1 Co-ordination and co-operation between organs of state
2.2 Factors that must be taken into account by decision-makers
2.3 Description of the receiving environment (Ch 7)
2.4 Impact assessment and evaluation of significance of impacts (Ch 8)
2.5 Public participation
2.6 Alternatives (Ch 4)
2.7 Mitigation (Ch 8)
2.8 Heritage resources (Chapters 5, 7 and 8)
2.9 Reporting gaps in knowledge and uncertainty (Ch 8)
2.10 Monitoring and management of residual impacts (Ch 9)
2.11 Consideration of maps of environmental attributes and
information(Chapters 5, 6 and 7)
2.12 Adherence to the requirements of other environmental management
Acts (Ch 5)
2.13 Appeals
3 OVERVIEW OF THE ACTIVITY AND THE LOCAL CONTEXT 16 – 18
4 ALTERNATIVES 19 – 24
4.1 Alternative 1: The preferred option
4.2 Alternative 2: Construction of a slipway at Die Hoek.
4.3 Alternative 3: The ‘no-go’ option
4.4 Alternative 4: Launching boats at the Mossel Bay harbour or
Gouritsmond
4.5 Summary
5 REGULATORY REQUIREMENTS RELATING TO THE VLEESBAAI
(NOORDSTRAND) BOAT LAUNCHING SITE
25 – 28
6 THE ‘DUTY OF CARE’, THE NATIONAL ENVIRONMENTAL MANAGEMENT
PRINCIPLES, THE DRAFT WESTERN CAPE RURAL LAND-USE PLANNING
AND MANAGEMENT GUIDELINES and CAPENATURE’S REQUIREMENTS
WITH RESPECT TO BIODIVERSITY IN DEVELOPMENT APPLICATIONS
29 – 32
6.1 The Duty of Care
6.2 Protection of Coastal Public Property
6.3 The National Environmental Management Principles
6.4 The Draft Western Cape Rural Land-use Planning and Management
Guidelines
6.5 CapeNature’s requirement with respect to biodiversity in development
applications
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7 THE RECEIVING ENVIRONMENT 33 – 47
7.1 Location
7.2 Topography
7.3 Climate
7.4 Ecosystems
7.4.1 Critical Biodiversity Areas
7.4.2 Sandy beaches and dune systems
7.4.3 The Noordkloof Strandveld valley bottom wetland
7.4.4 The rocky inter-tidal zone and inshore waters at Die
Hoek
7.5 The archaeological context: Shell middens
7.6 The social context: Bathing and other recreational activities
7.6.1 Recreational activities and outdoor pursuits
7.6.2 Access to the beach at Noordstrand, Vleesbaai
7.6.3 Municipal services and representation of homeowners
7.6.4 The Vleesbaai Bootklub
8 IDENTIFICATION, ASSESSMENT AND EVALUATION OF IMPACTS ARISING
FROM ORV USE OF THE VLEESBAAI (NOORDSTRAND) BOAT LAUNCHING
SITE
48 – 66
8.1 Evaluation method
8.2. Vulnerabilities of the natural environment w.r.t. ORV use
8.2.1 A note on impact frequency, scale, resilience of sandy
beach ecosystems and impact reversibility
8.3 Potential damage by ORVs to the Noordkloof and Noordstrand sandy
beach and dune ecosystems and coastal processes
8.3.1 Implications of scale-related factors, type of disturbance
and ecological resilience to impact evaluation
8.3.2 Discussion
8.3.3 Measures for impact avoidance and mitigation
8.4 Potential damage by ORVs to the Noordkloof Strandveld valley
bottom wetland
8.4.1 Discussion
8.4.2 Measures for impact avoidance and mitigation
8.5 Potential degradation of the Noordstrand-Noordkloof sediment
corridor and embedded Strandveld valley bottom wetland, i.e.
Critical Biodiversity Areas
8.5.1 Measures for impact avoidance and mitigation
8.6 Potential impacts of a slipway on the rocky inter-tidal zone at Die
Hoek
8.6.1 Measures for impact avoidance and mitigation
8.7 Vulnerability of shell middens to ORVs
8.7.1 Measures for impact avoidance and mitigation
8.8 Vulnerability of bathers and other users of the Vleesbaai boat
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launching site
8.8.1 Measures for impact avoidance and mitigation
8.9 Potential financial costs and the question of ‘reasonableness’ and
‘feasibility’
8.10 Comparative assessment of the significance of all four alternatives
8.10.1 Alternative 1 – The status quo and preferred option
8.10.2 Alternative 2 – Construction of a slipway and access road
at Die Hoek
8.10.3 Alternative 3 – The ‘no go’ option
8.10.4 Alternative 4 – Launching boats at Gouritsmond or Mossel
Bay
9 PUBLIC PARTICIPATION 67 - 85
9.1 The legal basis for public participation
9.2 The Western Cape guideline on public participation
9.3 Potential interested and affected parties who were notified of the
application
9.3.1 The informal phase of public participation
9.3.2 The formal phase of public participation
9.4 Actions to notify potential interested and affected parties
9.5 Proof of notice and record of registration of I&APs
9.6 Registered interested and affected parties
9.7 Comments and responses report
9.8 Key issues raised by interested and affected parties
9.9 Copies of comment received from interested and affected parties
10 CONCLUSION AND RECOMMENDATIONS 86 - 88
10.1 Conclusions: The preferred option
10.2 Recommendations
10.3 Draft environmental management programme (EMP) for the
Noordstrand launching site
11 REFERENCES 89 - 91
12 APPENDICES 1-7
1. Rulesof the Vleesbaai Bootklub
2. VAB Bpk permission to boat club o use access route via VAB property
3. Quote for construction of slipway at Die Hoek
4. Pre-application correspondence with Dept Env Affairs and Development Planning
5. Draft EMF for the Vleesbaai boat launching site
6. Konsep- omgewingsbestuursplan vir die Vleesbaai bootlanseringsplek
7. ORV application form and checklist
8. Comment by interested and affected parties (5 Feb 2010-25 March 2010)
9. Second round of comment by I&APs (14 Apr 2010-7 May 2010)
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1. EXECUTIVE SUMMARY
NOTE: The executive summary has not been updated since it was first distributed in
December 2009. This is because the conclusions of the environmental assessment have
not changed since then. The executive summary therefore remains an accurate reflection
of the findings of the environmental assessment and its recommendations. Changes to
the draft Environmental Management Plan are detailed in Chapter 9, ‘The public
participation process’, and the amended EMPs are contained in Appendix 5 (the original
English version) and Appendix 6 (the Afrikaans translation).
1.1 BACKGROUND
The Vleesbaai Bootklub (‘the boat club’) has initiated a process to have a boat launching site
at Noordstrand, Vleesbaai, licensed in terms of the Off-road Vehicle (ORV) Regulations.1
Vleesbaai is a coastal holiday settlement about 24 km south-west of Mossel Bay in the
Western Cape (see Figure 1, p 2).
The ORV regulations require that an environmental assessment be undertaken in terms of
section 24(4) of NEMA, and that an environmental management plan (EMP) must be
submitted with the application.
This information document summarises the initial findings of the draft environmental
assessment that is being undertaken for the boat club in fulfilment of its legal obligations. It
also spells out how interested and affected parties can participate in the environmental
assessment process.
1.2 THE ENVIRONMENTAL ASSESSMENT PROCESS
Section 24(4) of NEMA specifies the minimum requirements for investigating, assessing and
communicating the potential impact of activities such as those associated with a boat
launching site.
The Western Cape Department of Environmental Affairs and Development Planning has
instructed the boat club to investigate the environmental impacts of the Noordstrand
launching site, as well as the ‘no go’ option, and at least one other alternatives. The
additional alternatives are:
− Constructing a concrete slipway at Die Hoek, Vleesbaai; and
− Making use of existing slipways at Gouritsmond or Mossel Bay.
1 See Sections 2 to 9 of the Draft Environmental Assessment for references.
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Alternatives must be both feasible and reasonable – from the perspective of the applicant,
as well as in terms of both biophysical and social impacts.
None of the activities conducted by the boat club require authorisation in terms of the
NEMA environmental impact assessment (EIA) regulations.
The environmental assessment process is being conducted by an independent
environmental consultancy, Charl de Villiers Environmental Consulting cc (contact details
provided in Section 7, ‘The Way Forward’).
The section on ‘The way forward’ summarises the public participation process and explains
how you can become involved in this process.
1.3 THE ACTIVITY
The activity entails launching boats from an open beach at Noordstrand, Vleesbaai, on the
southern Cape coast.
The launch site, which entails no fixed infrastructure such as a slipway, jetty or breakwater,
is located at about 34°17’02.99” South 21°54’42.98” East (see Figs. 1 and 2). Only members
Fig 1: The boat launching site in its regional context
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of the Vleesbaai Boat Club have permission to drive across private land to the beach at
Noordstrand. The site has been used to launch boats since the early 1970s. The site is used
most frequently during the summer holidays, when three to five boats may be launched a
day. Vehicles get to the beach via a tarred ramp into a shallow sandy valley, Noordkloof,
which opens into Noordstrand.
1.4 THE ENVIRONMENT
The launching site and the access route through Noordkloof are located within the littoral
active zone, i.e. that naturally dynamic part of the coastal environment that is characterised
by the exchange of sand between the sea and the coast, and biodiversity that is adapted to
these unstable conditions. See Figure 2.
The biodiversity of the littoral active zone is highly resilient to natural disturbances caused
by wave action and wind, and seasonal cycles of erosion, transport and deposition of sand.
Sandy beach and dune ecosystems are, however, particularly vulnerable to developments or
activities that interfere with the natural dynamics of the littoral active zone. Dunes are very
sensitive to trampling and destabilised drift sand can become a major nuisance if the natural
vegetation cover is disturbed.
Fig. 2: The Vleesbaai boat launching site
The littoral active zone comprises the in-shore region, the area between the low and high
water marks, the open beach and sand dunes at varying stages of development. Some of the
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dunes, such as the steeply-incised foredunes in front of the built-up area at Vleesbaai-
Noord, are relatively vegetated and stable. Dunes in Noordkloof, which forms a natural sand
corridor, are generally less well developed, mobile and exposed to storm surges that can
rapidly change the local dune topography. The dunes at Vleesbaai fall within a ‘Least
Threatened’ vegetation type classified as Cape Seashore Vegetation.
About 120 m inland of the high water mark, the shifting sands of Noordkloof are replaced by
a shallow Strandveld valley bottom wetland, most of which is located on the neighbouring
farm. The tarred ramp into Noordkloof skirts this wetland. Noordkloof and the adjacent
coastal zone are defined as a Critical Biodiversity Area due to the presence of the wetland
and the potential occurrence of an ‘Endangered’ vegetation type, Groot Brak Dune
Strandveld in the vicinity. Critical Biodiversity Areas represent the least amount of land that
is required to meet thresholds for conserving biodiversity pattern (such as species, habitats
and vegetation types) and ecological processes, and need to be managed accordingly.
The environmental assessment has approached the Noordstrand-Noordkloof area as a single
ecosystem, which is dominated by the features and processes of the littoral active zone but
which also includes part of a Strandveld valley bottom wetland at its landward margin.
The only animal species of concern that is known to frequent the area is the African Black
Oystercatcher, classified as ‘Near-threatened’ by the 2009 IUCN Red Data List. This species
does not nest in the vicinity of the launching site, although oystercatchers regularly forage
on the rocks either side of Noordstrand. Southern right whales, a ‘Species of least concern’,
often frequent Vleesbaai in the winter months to calve and mate.
There is a shell midden about 15 m north of the access route through Noordkloof. The
midden is located in a raised depression and therefore not considered to be at risk from
driving. Noordstrand is also used for other seaside activities, particularly bathing, surfing,
walking and games.
1.5 IMPACT ASSESSMENT
The environmental assessment investigated four alternatives. Only two of these would have
a predicted impact on the environment as the result of boat launching in the littoral active
zone. These are the preferred option – maintaining Noordstrand as a launching site – or
building a slipway at Die Hoek, about 800 m to the south. The latter site did have a slipway
which has since been destroyed by the action of the sea.
The ‘no go’ and Mossel Bay and Gouritsmond alternatives would have no negative
environmental consequences, but would be most inconvenient from the perspective of the
Vleesbaai Bootklub as both of the alternative launching sites entailed roundtrips of at least
50 km by road to get to the respective slipways. Retaining Noordkloof and Noordstrand as
the access route and launching site respectively is likely to have some environmental impact,
but with minimal long-term effect due to the small area of disturbance (≤ 0.4 ha or about
33% of the Noordkloof-Noordstrand interface), the limited duration of driving in the littoral
active zone, and the natural dynamism and resilience of the receiving environment. In
contrast, a slipway at Die Hoek, besides the direct financial costs of such a project and its
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hazards to boating due to its rocky environs, would have a long-term negative effect on the
coastal environment.
Overall, the draft environmental assessment has found that there is no evident
environmental justification for relinquishing the existing Noordstrand launching site at
Vleesbaai, and that all the other alternatives cannot be viewed as either feasible or
reasonable by the Vleesbaai boat club.
1.6 IMPACT MITIGATION AND THE DRAFT ENVIRONMENTAL MANAGEMENT PLAN
The statutory environmental ‘Duty of Care’ requires that degradation of the environment
must be avoided, and where degradation or pollution cannot be reasonably prevented, it
must be minimised and rectified.
In the case of the existing boat launching site at Vleesbaai, a number of measures have been
proposed to avoid, and insofar as this is not reasonably possible, to mitigate the effects of
driving in the littoral active zone. Remedial actions are not deemed necessary due to the
limited magnitude and duration of impacts on the coastal environment, and the ability of
the affected system to absorb the short-lived effects of driving through Noordkloof to
Noordstrand. These mitigatory measures and a monitoring protocol are contained in a draft
environmental management plan for the Noordstrand, Vleesbaai, boat launching site.
Table 1 summarises the significance of impacts arising from all four alternatives, without and
with mitigation.
Table 1: Summary of draft impact evaluation [(+) = positive, (-) + negative; negative impacts
shaded]
Alternative 1
Noordkloof &
Noordstrand
Alternative 2
Die Hoek
Alternative 3
‘No-go’ option
Alternative 4
Mossel Bay or
Gouritsmond
Vulnerable
feature No Mit. With Mit. No Mit. With Mit. No Mit.
With
Mit. No Mit. With Mit.
Coastal
processes
LOW (-)
Probable
LOW (-)
Possible NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL
Valley bottom
wetland
LOW (-)
Unlikely
NEUTRAL
Unlikely NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL
CBAs HIGH (-)
Possible
V. LOW (-)
High.
prob.
NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL
Shell middens HIGH (-)
Possible
NEUTRAL
Unlikely NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL
Bathers, etc HIGH (-)
Unlikely
NEUTRAL
Unlikely NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL
Rocky inter-tidal
zone NEUTRAL NEUTRAL
MEDIUM
(-)
Probable
MEDIUM
(-)
Probable
NEUTRAL NEUTRAL NEUTRAL NEUTRAL
Feasibility &
reasonableness
HIGH (+)
Definite
HIGH (+)
Definite
HIGH (-)
Definite
HIGH (-)
Definite
HIGH (-)
Definite
HIGH (-)
Definite
HIGH (-)
Definite
HIGH (-)
Definite
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1.7 THE WAY FORWARD
The public participation process is being approached in two phases:
− An informal opportunity (the ‘informal Vleesbaai phase’) for residents at Vleesbaai
to be informed of the environmental process during the summer holidays
(December-January, 2009); and
− A formal public participation process (‘the formal public phase’) that conforms to
legal requirements, and which is planned to commence in January or February,
2009.
The informal Vleesbaai phase
Copies of this information document and the draft EMP were e-mailed to Vleesbaai Dienste
in December for distribution to the associations and companies representing homeowners
at Vleesbaai, namely: Keerom Bpk; Hoekbaai Huiseienaarsvereniging; Visbaai Bpk; Driehoek
Huiseienaarsvereniging; Vleesbaai Aandeleblok Bpk; and the Karmosyn Homeowners’
Association.
The recipients of the documents have been given an opportunity to familiarise themselves
with the application and the draft EMP so as to ensure the factual accuracy of these
documents. Any factual corrections must please be submitted to Charl de Villiers
Environmental Consulting cc by 8 January, 2010, if possible (see contact details on page 6).
The formal phase of public participation
All the above mentioned associations will be notified of the formal public participation
process once it commences in January or February 2010, when they will have an
opportunity to register as interested and affected parties and to formally submit comment
on the potential environmental impacts of the licence application.
NAVRAE EN KONTAK-BESONDERHEDE
Navrae i.v.m die Vleesbaai Bootklub se lisensie-aansoek ingevolge die ‘ORV’-regulasies en
die meegaande omgewingsimpakstudie, asook enige feitelike regstellings, moet asseblief
aan die volgende instansie gerig word:
Charl de Villiers Environmental Consulting cc
Bradwellweg 14
VREDEHOEK
8001
e-pos [email protected]
faks 086 553 9256
tel 021 461-2477
sel 083 785 0776
Korreksies moet asb, waar moontlik, teen Vrydag 8 Januarie 2010 ingedien word.
Afgesien van hierdie inligtingstuk, sal u vereniging ook in Januarie of Februarie 2010
formeel uitgenooi word om by die wetlik-voorgeskrewe openbare deelname-proses as
belanghebbende en geaffekteerde party te registreer.
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2. MINIMUM PROCEDURES FOR THE INVESTIGATION, ASSESSMENT
AND COMMUNICATION OF THE POTENTIAL CONSEQUENCES OR
IMPACTS OF ACTIVITIES ON THE ENVIRONMENT
The Vleesbaai Bootklub (hereafter ‘the boat club’) has applied to the Western Cape
Department of Environmental Affairs and Development Planning (DEA&DP) for the licensing
of the Noordstrand launching site at Vleesbaai in the southern Cape in terms of the ORV
regulations. The potential environmental consequences or impacts of boat launching and
related activities at Noordstrand need to be investigated and reported to DEA&DP in terms
of section 24(4) of the National Environmental Management Act 107 of 1998 (hereafter
‘NEMA’) as amended.
In summary, section 24(4) of NEMA stipulates minimum requirements for environmental
assessments that relate to authorities and the environmental assessment process
respectively.
Figure 1: Location
The minimum requirements with respect to organs of state are paraphrased below.
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2.1 Co-ordination and co-operation between organs of state
There must be co-ordination and co-operation between organs of state where an activity
may fall under the jurisdiction of more than one organ of state.
2.2 Factors that must be taken into account by decision-makers
Any decision by an organ of state must take into account:
−−−− The findings and recommendations flowing from an environmental assessment;
−−−− The general objectives of integrated environmental management as provided for in
Chapter 5 of NEMA
−−−− The national environmental management principles (section 2, NEMA).
Environmental assessments, in turn, must as a minimum address the following
(corresponding chapters in this document in brackets):
2.3 Description of the receiving environment (Ch 7)
An application must contain a description of the environment likely to be significantly
affected by the proposed activity.
2.4 Impact assessment and evaluation of significance of impacts (Ch 8)
There must be an investigation of:
−−−− The potential environmental consequences for, or impacts on, of the activity; and
−−−− The significance of those potential consequences or impacts.
2.5 Public participation (Ch 9)
The public participation process was conducted between 5 February 2010 and 19 February
2010. The conduct of the process and a record of comments received and the responses
thereto are reflected in Chapter 9. All notices and correspondence relating to the public
participation process are contained in Appendix 8. Amendments to the main body of the
report that were introduced on the basis of public comment or the availability of new
information are underlined.
2.6 Alternatives (Ch 4)
All applications for an environmental authorisation must include, where applicable:
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−−−− Investigation of the potential consequences or impacts of alternatives to the activity
on the environment; and
−−−− Assessment of the significance of those potential consequences or impacts,
including the option of not implementing the activity.
2.7 Mitigation (Ch 8)
Measures must be investigated to mitigate adverse consequences or impacts to the
minimum.
2.8 Heritage resources (Chapters 5, 7 and 8)
Potential impacts on heritage resources (the ‘national estate’ in terms of section 3(2) of the
National Heritage Resources Act 25 of 1999) must be investigated, assessed and evaluated.
2.9 Reporting gaps in knowledge and uncertainty (Ch 8)
Gaps in knowledge, the adequacy of predictive methods and underlying assumptions and
uncertainties arising from the compilation of information must be reported.
2.10 Monitoring and management of residual impacts (Ch 10 and Apps 5 and 6)
Arrangements for monitoring and managing environmental consequences and impacts must
be investigated and formulated, as must the effectiveness of such arrangements.
2.11 Consideration of maps of environmental attributes and information (Chapters 5, 6
and 7)
Applications must consider information and maps that specify the attributes of the
environment in particular geographic areas where such information and maps have been
complied by either the national Minister of Water and Environmental affairs or a provincial
MEC.
2.12 Adherence to the requirements of other environmental management Acts (Ch 5)
Environmental assessments must also adhere to the requirements prescribed in other
environmental management Acts that may be relevant to the listed or specified activity in
question. It is the understanding of the boat club that this provision, section 24(4)(b)(vii),
does not apply to its application for the licensing of the Vleesbaai boat launching site as the
latter does not entail a ‘listed’ or ‘specified’ activity as defined by NEMA. See section 5
(‘Regulatory requirements’) below.
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2.13 Appeals
In terms of section 43(1) of NEMA, any affected person may appeal to the Minister against a
decision taken by any person acting under a power delegated by the Minister under Act of
107 of 1998.
Figure 2: Vleesbaai – Local features
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3. OVERVIEW OF THE ACTIVITY AND THE LOCAL CONTEXT
The activity entails launching small craft such as ski boats, sailing dinghies and ‘rubber ducks’
from the open beach at Noordstrand, Vleesbaai (approximate location 34°17’02.99” South
21°54’42.98” East). Vleesbaai is a coastal holiday node constituting about 300 dwellings at
the south-western extremity of Vlees Bay, about 30 km by road from Mossel Bay. The sandy
Noordstrand beach at Vleesbaai has been used for launching boats for about 35 years. It is
also a popular bathing beach.
Boats are towed
to the beach by
off-road vehicles.
Launching usually
takes place at low
tide, from the
open beach. A
section of the
access route
crosses a strip of
privately-owned
land (Vleesch Baai
Strand 266),
which is located in
the littoral active
zone.2 The latter
property is owned
by Vleesbaai
Aandeleblok Bpk, a
body representing
shareholders in the neighbouring coastal settlement that is colloquially known as Vleesbaai-
Noord. Only members of the Vleesbaai Bootklub may drive through Noordkloof to the
launching site (cf. Appendix 2, ‘ VAB Bpk permission to boat club to use access route via VAB
property’). The northern, undeveloped part Vleesch Baai Strand 266 is a conservancy).
Measured from the access gate on Mullerlaan, Vleesbaai-Noord (34° 17’05.48” South, 21°
54’ 38.63” East), to the approximate water’s edge, the distance traversed by vehicle in the
littoral active zone is about 140-150 m. The potential area that may be adversely impacted
by the physical effects of driving through Noordkloof to the beach amounts, at most, to
about 1.2 ha. Boat launching activities, including driving to and from the launch site, parking
2 The ‘littoral active zone’ refers to that portion of the coastal environment that is dominated by
beaches and foredunes, and where sand is moved naturally by wind, water or gravity. Frontal dunes
form part of this sediment exchange system (Tinley 1985; Council for the Environment, 1991)
Figure 3: The Noordstrand boat launching site
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vehicles and trailers on the back beach, and manoeuvring vehicles and trailers in the vicinity
of the launch site, use an area not exceeding 0,4 ha or about 33% of the Noordkloof-
Noordstrand interface.3
A tarred ramp, 40-50 m in length, from Mullerlaan to the base of Noordkloof represents the
only fixed infrastructure associated with the boat launching site. The base of the ramp is
about 90 m from the HWM. Vehicles only access the beach during daylight hours.
Only members of
the Vleesbaai
Bootklub are
allowed to use the
launching site, and
vehicular access to
Noordkloof and the
beach is controlled
by a gate that is
kept locked when
not in use by
members of the
boat club.
Membership of the
boat club is limited
to 30 individuals
(section 3, ‘Vleesbaai
Aandelblok (VAB)
Booklubreëls’;
Appendix 1).
Use of the beach launching site peaks over the summer holidays (mid-December to mid-
January), when there may be three to four launchings a day. The number and frequency of
launchings is strongly dictated by environmental factors such as the tide, sea state, wind and
weather. The intensity of such use decreases significantly outside the festive season. It takes
about 20 to 30 minutes to launch a boat. Vehicles are either removed from the beach after
boats have been launched, or left parked against the foredunes flanking the northern aspect
of Noordstrand (cf. Figure 3). Vehicles must be parked out of sight to the rest of Vleesbaai.
There is rarely more than one vehicle parked in such a manner at any time. The boat club
limits the number of vehicles that may be parked on the back beach at any one time to five.
3 Measurements calculated using ‘GoogleEarth’ http://earth.google.com and ‘Google Planimeter’
http://www.acme.com/planimeter/
Figure 4: ORV traversing Noordkloof with boat from launching site
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 18
Members of the boat club must subscribe to a set of rules enforced by Vleesbaai
Aandeleblok Bpk (see Appendix 1).
For reasons of safety, access and limited environmental impact, the boat club views
Noordstrand as the most optimal site for launching boats at Vleesbaai and the latter site has
therefore been selected as the preferred option in the treatment of alternatives in Section 4.
Figure 5: The preferred alternative in its local context
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 19
4. ALTERNATIVES
One of the central principles of environmental management is that it must seek the best
practicable option, i.e. the option that provides the most benefit or causes the least damage
to the environment as a whole, at a cost acceptable to society, in the long term as well as
the short term.4 The primary mechanism for doing so is through the identification and
examination of alternatives that provide a basis for choice among options available to the
decision-maker (Preston et al., 1996, p 755).
In terms of the DEA&DP guideline on alternatives (2007), the term means “different means
of meeting the general requirements of the activity” and can include location, activity,
design or layout, technological and operational alternatives. The DEA&DP guideline
emphasises that alternatives must be ‘feasible’ and ‘reasonable’, and the such ‘feasibility’ or
‘reasonableness’ must be weighed up against:
− The general purpose, requirements and need of the activity;
− How the activity impacts on the affected environment; and
− How the activity impacts on the affected human community.
The New Oxford English Dictionary (Pearsall (ed), 1998) defines ‘feasible’ as meaning
“possible to do easily or conveniently” and ‘reasonable’ as, variously, “fair and sensible...
based on good sense.... as much as it is appropriate or fair”, etc.
The Vleesbaai boat club has been instructed to assess at least one other alternative besides
the preferred and ‘no-development’ options (DEADP, 23 November 2009). A fourth
(location) alternative is also assessed, viz., abandoning the Noordstrand launch site in favour
of the Gouritsmond or Mossel Bay slipways.
4.6 Alternative 1: The preferred option
For the Vleesbaai Bootklub, its primary activity of choice and reason for its existence is
partaking in fishing and water sports, as safely as possible, with minimal environmental
impact, in boats launched at Noordstrand, in the waters directly off Vleesbaai in the
southern Cape. This activity has been taking place in the latter location since at least the
early 1970s, and with the formal approval of the owners of the land via which the launching
site is accessed, since 1983 (Appendix 2).
The reasons given by the boat club for its preference for Noordstrand as a launching site are:
4 Cf. sections 1(1)(iii) and 2(4)(b) of the National Environmental Management Act 107 of
1998 as amended.
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− The coastline from Fransmanshoek (to the east) to Die Hoek at Vleesbaai is rocky and
entirely unsuitable for the purposes of boat launching (Figure 2).
− There were two concrete
slipways at Die Hoek (one
sanctioned, the other not;
Dr Martin Pauw, pers
comm), about 800 m
south of the Noordstrand
beach, but this has been
out of action for many
years due storm damage.
(Figures 7 & 8). This site, if
it were to be redeveloped
into a slipway and access
point, is viewed as being
unacceptably hazardous due
to its seaward approaches
being too narrow to allow
vessels sufficient room to manoeuvre freely, its rocky coastline and bottom conditions
alternating with congestion by sand, and shallow waters. These factors particularly
apply to the safe launching of yachts, which have a very narrow margin of error in such
hazardous conditions. The Die Hoek site is, however, selected as a second alternative to
Noordstrand (the existing boat launching site) due to its historical use as a slipway and
close proximity to Vleesbaai (see below,’ Alternative 2’).
− From Die Hoek to Noordstrand, the shoreline constitutes virtually unbroken rocks and is
therefore not suitable for boat launching.
− The Noordstrand beach is defined by rocky areas directly to its north and south. The
sandy portion of the beach is about 150 m wide, but in practice less frontage is
available (and used) for launching boats at any time. This is chiefly due to changes in the
sandy bottom brought about by the shifting location and configuration of in-shore
sandbanks and channels.
− North of Noordstrand, the shore is again dominated by more rocky wave-cut platforms
and sea conditions become increasingly rough as one starts losing the sheltering effect
of the Fransmanshoek Peninsula against south-westerly swells.
Figure 6: Retrieval of ski boat, Noordstrand (Dec 2009)
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 21
4.7 Alternative 2: Construction of a slipway at Die Hoek.
The second alternative refers to one of two former slipways at Die Hoek (see Figures 2 and
6), a rocky inlet about 800 m to the south of Noordstrand (34°17’27.94”S, 21°54’52.06”E).
This alternative would entail rebuilding the slipway and the access road, which would have
to negotiate a ±1:3 gradient down to inter-tidal zone. The parking lot above this site is about
180 m2
in extent.
The beach here consists of loose cobbles in places overlain with aelionite or a similar
sedimentary deposit. The seaward approaches are shallow, rocky and periodically clogged
with sand. A line of rocks defines the immediate western shoulder of the Die Hoek site
(Figures 7 & 8).
Figure 7: Die Hoek – location
According to local accounts, there were two slipways at Die Hoek (Dr M Pauw, pers comm).
One was apparently built in the 1960s, below Gallie Mayer Avenue (i.e. the approximate
location of Alternative 2). A second slipway was apparently built without permission. It
mainly served the needs of kayakers and inflatables.
Both slipways have been largely destroyed by the action of the sea. The boat club views De
Hoek as particularly unsuited for launching sailboats as vessels leaving and approaching the
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Charl de Villiers Environmental Consulting cc 22
slipway have to negotiate an opening in the rocks that is less than 25 m wide. Owing to the
bottom conditions, it may be necessary to excavate a channel to accommodate vessels with
a deeper draught or fixed keels.
It is estimated that it would cost about R360 000 [corrected amount] to build a reinforced
concrete slipway of 80 to 100 m2 in extent at Die Hoek (see Appendix 3). This amount
excludes engineering consulting fees, a geotechnical/hydrographical survey of the seaward
approaches to Die Hoek, and costs of excavating a channel. It also does not take into account
the transaction costs arising from the EIA that would need to be undertaken before such an
activity could be allowed to proceed.
Figure 8: Die Hoek – topography
Access to the former slipway site is partly blocked by a wooden boardwalk that runs parallel
to the shoreline. Die Hoek is not regularly used by bathers, and there is therefore limited
likelihood for conflict between boating and bathing. The area is apparently popular with
snorkelers.
Die Hoek represents the only local launching site (albeit an abandoned and hazardous one),
apart from Noordstrand, that can be accessed directly from Vleesbaai and without having to
travel longitudinally along the beach.
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Charl de Villiers Environmental Consulting cc 23
4.8 Alternative 3: The ‘no-go’ option
The ‘no-go’ option provides a basis from which to conduct an informed, comparative
assessment of the respective environmental costs and benefits of different ways of meeting
a particular land-use objective or development outcome.
This alternative would satisfy the mandatory requirement that the ‘no go’ option be
assessed. 5 If implemented, it would entail the cessation of an activity – launching of boats
from an open beach – that has been conducted in the same place, in the same manner, and
to the same effect for more than three decades.
In the case of this application, Goebbelskloof and its associated landforms, vegetation and
ecological processes present a useful local example of the state that Noordkloof and
Noordstrand may return to were they to be closed to vehicles and people (see Figure 9).
Goebbelskloof, although more exposed to on-shore winds and generally more high energy
sea conditions than the Noordkloof-Noordstrand boat launching site, also serves a potential
benchmark for comparing the impacts of limited driving on a sandy beach environment to
one where no driving takes place. Goebbelskloof is about one kilometre north of
Noordstrand.
Figure 9: Effects of trampling on frontal dunes, Goebbelskloof & Vleesbaai-Noord
5 Section 24(4)(b)(i), NEMA
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Charl de Villiers Environmental Consulting cc 24
4.9 Alternative 4: Launching boats at the Mossel Bay harbour or Gouritsmond
This is another location alternative that would see boat-owners at Vleesbaai driving to the
Mossel Bay harbour, about 30 km away, or Gouritsmond, roughly 23 km by road, to launch
their vessels from slipways at the respective launch sites (see Figure 1).
The effect of these alternatives on the environment would be the same as the ‘no go’ option
(Alternative 3), as they would entail the cessation of all boat launching activities and driving
in the littoral active zone in Noordkloof and the Noordstrand beach at Vleesbaai.
Both these alternatives are possible. It is questionable, however, if they would be either
feasible or reasonable from the boat club’s perspective, and the general purpose of its
primary activity as spelled out above.
In terms of the safety criterion, the Mossel Bay harbour would certainly be viewed an
acceptable option, although a busy working harbour would not provide a safe environment
for non-motorised sailboats. Use of the Gouritsmond slipway would entail few evident
hazards if boating was restricted to the river upstream from the mouth. Skippers wishing to
go to sea would have to negotiate the river mouth which can be dangerous due to strong
currents, unpredictable waves and migrating sand bars.
Hauling boats to Mossel Bay or Gouritsmond by road would be highly inconvenient for
members of the Vleesbaai boat club, who would incur additional fuel costs and would be
obliged to negotiate busy, high season traffic which holds its own safety risks.
There would probably also be additional costs, over and above fuel and vehicle wear-and-
tear, in the form of launching fees or permits at the two slipways in question.
4.10 Summary
The Vleesbaai Bootklub has elected not to investigate any alternatives other than those
outlined above. This is primarily because no other alternative – type of activity, design,
process, scheduling, layout, etc – is applicable to the activity of safely launching and
retrieving small craft from the only open beach at Vleesbaai. Location alternatives have
therefore predominated, with the addition of a process-type alternative in the case of
Alternative 2, which would entail rebuilding a slipway and new access road and, potentially,
excavation of the seabed.
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 25
5. REGULATORY REQUIREMENTS RELATING TO THE VLEESBAAI
(NOORDSTRAND) BOAT LAUNCHING SITE
The following laws or regulations potentially apply to the application by the Vleesbaai
Bootklub for the licensing of the boat launching site at Noordstrand, Vleesbaai, viz:
− The ‘Off-road Vehicle' (ORV) Regulations6 published in terms of the National
Environmental Management Act 107 of 1998 as most recently amended by Act 62 of
2008 (NEMA);
− The environmental impact assessment regulations7 published in terms of NEMA;
− The Sea-shore Act 21 of 1935 (section 3: ‘Letting of sea-shores and the sea’);
− The National Environmental Management: Integrated Coastal Management Act 24 of
2008 (section 65: leasing land in ‘coastal public property’)8;
− The Marine Traffic Regulations9 published in terms of section 14 of the Marine Traffic
Act 2 of 1981;
− The National Heritage Resources Act 25 of 1999.
5.1 The ORV Regulations
The ‘Off-road Vehicle' (ORV) Regulations10
published in terms of the National Environmental
Management Act 107 of 1998 generally prohibit the use of vehicles in the coastal zone11
unless the use is:
− Permissible (without a permit) in terms of Reg 4;
− Authorised in terms of Reg 6 (permit); or
− Permitted in terms of Reg 7 (boat launching site licence).12
In the case of Vleesbaai, persons wishing to drive on private property within the coastal zone
(e.g. Vleesch Baai Strand 266) do not require a permit if they have permission to do so from
the owner or lawful occupier of the land (Reg 4). It would, however, be unlawful to drive on
such land without a permit issued in terms of Reg 6 if the necessary permission has not be
been given by the owner or lawful occupier of the property in question. Access to the boat
6 GN R. 1426 of 7 December 2007
7 GN R. 385, GN R. 386 & GN R. 387 of 21 April 2006
8 ‘Coastal public property’ consists inter alia of coastal waters, land submerged beneath coastal
waters, the seashore and any admiralty reserve owned by the state. 9 GN R. 194 of 1 February 1985
10 GN R. 1426 of 7 December 2007
11 The ‘coastal zone’ means the area adjacent to the sea characterised by coastal landforms, and
includes beaches, dunes, estuaries, coastal lakes, coastal wetlands, land submerged by the waters of
the sea, or of any estuary, coastal lake or coastal wetland, boat launching sites, proclaimed harbours
and recreational use areas. 12
Cf. DEAT (2004) Guidelines on the implementation of regulations pertaining to the control of
vehicles in the coastal zone. Department of Environmental Affairs and Tourism, Pretoria.
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Charl de Villiers Environmental Consulting cc 26
launching site via Vleesch Baai Strand 266 is currently limited to members of the Vleesbaai
Bootklub, who, by virtue of their membership of the boat club, have the permission of the
owners of this land, Vleesbaai Aandeblok Bpk, to drive there.
Any vehicle may be used within a licensed boat launching site (Reg 7), provided that the
vehicle is used for the purpose of launching a vessel. It is important to note that even though
a launching site may be licensed in terms of Reg 7, those using it for launching vessels will
also need a permit for using a vehicle in the coastal zone (Reg 6).
Applications for permits in terms of the ORV Regulations must be directed to:
The Sub-Directorate: Coastal Planning and Environmental Protection
Branch: Marine and Coastal Management
Department of Environmental Affairs and Tourism
Telephone: 021 - 402 3023
Fax: 021 - 402 3009
Address: Private Bag X2, Roggebaai, 8012
Web Site: www.environment.gov.za
In order to ensure that its activities are legally compliant, the Vleesbaai Boat Club has
applied to the Western Cape Department of Environmental Affairs and Development
Planning (DEA&DP) for the Noordstrand (‘Vlees Bay Holiday Resort’) beach to be licensed as
a boat launching site in terms of the ORV regulations. In this instance, the licence application
entails the following components:
− Compliance with the general objectives of integrated environmental management as
prescribed under the ‘Environmental Authorisation’ provisions of section 24 of the
National Environmental Management Act 107 of 1998 as most recently amended by Act
62 of 2008 (this includes the consideration of alternatives, including the ‘no-go’ option,
and a public participation process); and
− Submission of a draft environmental management plan (EMP) that would give
operational effect to the ‘Duty of Care’ insofar as this would apply to the launching of
boats from an open beach on the Southern Cape coastline.
5.2 The NEMA EIA Regulations
The Vleesbaai boat-launching site does not trigger any listed activities identified in terms of
GN R. 386 or GN R. 387 i.e. (activities that requiring authorisation in terms of section 24 of
NEMA). This has been confirmed by the DEA&DP (see paragraph 5 of the letter from
DEA&DP, dated 23 November 2009; Appendix 4).
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Charl de Villiers Environmental Consulting cc 27
5.3 The Sea-shore Act
Section 3 of the Sea-shore Act provides for the letting of any portion of the sea-shore13
and
the sea by the State President. Such letting must be in the interest of the general public, or
must not seriously affect the general public’s enjoyment of the sea-shore and the sea. In the
circumstances, it would appear that the use of an open beach for periodic launching of
recreational vessels does not constitute any of the ‘purposes’14
for which the sea-shore may
be let. Such ‘purposes’ chiefly relate to construction or erection of structures on the sea-
shore. It is consequently the understanding of the Vleesbaai Bootklub that, provided it is not
contemplating any of the ‘purposes’ stipulated in section 3 of Act 21 of 1935, it is not
required to enter a lease agreement with the State for the launching of boats from the open
beach at Noordstrand, Vleesbaai.
5.4 The NEM: Integrated Coastal Management Act
Any person wishing to occupy any part of, or a site on, or construct or erect a building, road,
barrier or structure on or in Coastal Public Property may only do so in terms of a coastal
lease awarded by the Minister of Water and Environmental Affairs.15
It is the understanding
of the Vleesbaai Bootklub that section 65 of the NEM: Integrated Coastal Management Act is
not yet in force (cf. paragraph 1 of letter of 23 March 2 from the Acting Deputy-director:
Coastal Planning and Environmental Protection (Appendix 8, ‘Comment by interested and
affected parties’) and that this provision therefore does not apply to the activities of the
boat club. It is the view of the boat club that, due to the nature of its intermittent and non-
invasive utilisation of the beach and littoral active zone at Noordstrand and Noordkloof,
Vleesbaai, its activities would in any event not entail any of the actions contemplated by
section 65 of Act 24 of 2008 and therefore would not be required to enter a coastal lease
with the Department of Water and Environmental Affairs, were these provisions to be in
force.
5.5 The Marine Traffic Regulations
The Marine Traffic Regulations inter alia exempt small vessels engaged in sporting or
recreational activities from section 4(1) of the Marine Traffic Act 2 of 1981, which stipulates
that the Master of any ship “shall not, except as prescribed by regulation, cause it to enter
or leave internal waters other than a harbour or a fishing harbour”. Insofar as potential
pollution of the sea is concerned, Act 2 of 1981 provides that it is an offence to sink or dump
any vessel, wreck or hulk except with the permission of the South African Maritime Safety
13
The ‘sea-shore’ means the water and the land between the low-water mark and the high-water
mark. 14
Sub-section 3(a) to (o) of Act 21of 1935. 15
Section 65(1), Act 24 of 2008.
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Charl de Villiers Environmental Consulting cc 28
Authority.16
Neither the Marine Traffic Regulations nor the empowering Act would seem to
place a specific, direct onus on the Vleesbaai Bootklub and its activities.
5.6 The National Heritage Resources Act 25 of 1999
Section 24(4)(b)(iii) of NEMA requires that environmental assessments must investigate,
assess and evaluate the impact of any proposed listed or specified activity on any national
heritage estate referred to in section 3(2) of the National Heritage Resources Act. The
national heritage estate ranges from structures with cultural significances and archaeological
and paleontological sites to graves and objectives of scientific and technological interest.
Section 38 of Act 25 of 1999, in turn, specifies the circumstances under which the
responsible heritage resources authority (in this instance, Heritage Western Cape) must be
notified of proposed developments in terms of a series of specified categories.17
Sub-section 38(2)(a) specifies that if there is reason to believe that heritage resources will be
affected by such development, the responsible heritage authority must within 14 days of
having being notified of the proposed development notify the project proponent to
undertake a heritage impact assessment. Regulations published by the provincial heritage
agency, Heritage Western Cape, inter alia specific the circumstances and procedures under
which a permit must be obtained in terms of sections 27, 29 and 34 of Act 25 of 1999.18
Given that the activities associated with boat launching at Noordstrand, Vleesbaai, do not
impact on the national estate as defined by section 3(2) of Act 25 of 1999, or constitute any
of the categories of development specified in section 38 of the Act, and that such activities
will not result in the destruction or any form of damage or disturbance to heritage
resources, it is the understanding of the Vleesbaai Bootklub that:
− (a) Heritage Western Cape does not need to be notified of the licensing application in
terms of the ORV regulations; and
− (b) The boat club’s activities do not require a permit in terms of the Western Cape
heritage regulations.
16
Section 6, Act 2 of 1981. 17
Cf. sub-sections 38(1)(a) to (2): (a) the construction of a road, wall, powerline, pipeline, canal or
other similar form of linear development or barrier exceeding 300 m in length; (b) the construction of
a bridge or similar structure exceeding 50 m in length; (c) any development or other activity which will
change the character of a site— (i) exceeding 5 000 m2 in extent; or (ii) involving three or more
existing erven or subdivisions thereof; or (iii) involving three or more erven or divisions thereof which
have been consolidated within the past five years; or (iv) the costs of which will exceed a sum set in
terms of regulations by SAHRA or a provincial heritage resources authority; (d) the re-zoning of a site
exceeding 10 000 m2 in extent; or (e) any other category of development provided for in regulations
by SAHRA or a provincial heritage resources authority... 18
Provincial Notice 336 of 25 October 2002
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6. THE ‘DUTY OF CARE’, THE NATIONAL ENVIRONMENTAL
MANAGEMENT PRINCIPLES, THE DRAFT WESTERN CAPE RURAL
LAND-USE PLANNING AND MANAGEMENT GUIDELINES and
CAPENATURE’S REQUIREMENTS WITH RESPECT TO BIODIVERSITY
IN DEVELOPMENT APPLICATIONS
This section summarises ‘high-level’ legal and policy considerations that would contribute to
informing an official decision with respect to the boat club’s application for the licensing of
the Vleesbaai boat launching site at Noordstrand.
6.1 The Duty of Care
Chapter 7 of the National Environmental Management Act 107 of 1998 prescribes a general
‘duty of care’ and requirement to remediate environmental damage. Section 28(1) of NEMA
states:
Every person who causes, has caused or may cause significant pollution or
degradation of the environment must take reasonable measures to prevent such
pollution or degradation from occurring, continuing or recurring, or, insofar as such
harm to the environment is authorised by law or cannot reasonably be avoided or
stopped, to minimise and rectify such pollution or degradation of the
environment....
The EMP for the boat launching site would be drafted with the specific goal of giving effect
to the Vleesbaai boat club’s obligations in terms of the ‘Duty of Care’, which is also present
in the National Environmental Management: Integrated Coastal Management Act 24 of
2008.19
6.2 Protection of Coastal Public Property
The National Environmental Management: Integrated Coastal Management Act 24 of 2008,
in turn, confirms the State’s role as the public trustee of all ‘coastal public property’ (CPP),20
which must be used and conserved in the interests of the whole community and protected
for present and future generations. Act 24 of 2008 also established a ‘coastal protection
zone’ (CPZ).21
The CPZ is established for enabling the use of land that is adjacent to CPP or
that plays a significant role in a coastal ecosystem to be managed, regulated or restricted in
19 Section 58, Act 24 of 2008 20
Cf. section 7 of Act 24 of 2008 for the definition of ‘coastal public property’, which includes the
seashore below the HWM. 21
Cf. sections 16 and 17 of Act 24 of 2008 for the definition of the ‘coastal protection zone’ and its
purpose.
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terms of predominantly ecological considerations and potential risks to people, property and
economic activities that may arise from dynamic coastal processes. Act 24 of 2008
establishes the right of reasonable access to CPP provided it does not cause an adverse
effect.22
6.3 The National Environmental Management Principles
Chapter 1 of NEMA (the National Environmental Management Principles) lays down
principles23
that apply the actions of all organs of state that may significantly affect the
environment. These principles serve as guidelines by reference to which any organ of state
must exercise any function when taking any decision in terms of any statutory provision
concerning the protection of the environment.24
The National Environmental Management
Principles therefore apply to the Vleesbaai Bootklub’s application for the licensing of
Vleesbaai (Noordstrand) boat launching site.
The National Environmental Management Principles place people and their needs at the
forefront of environmental management, and require that development must be socially,
environmentally and economically sustainable.25
They also endorse the participation of all
interested and affected parties in environmental governance.26
The principles that would
have particular relevance to decisions relating to driving and boat launching the littoral
active zone of the Southern Cape coast are those that require that environmental
management must (in paraphrased format):
− Avoid, minimise or remedy disturbance of ecosystems and loss of biodiversity;
− Avoid degradation of the environment;
− Avoid jeopardising ecosystem integrity;
− Pursue the best practicable environmental option by means of integrated
environmental management; and
− Pay specific attention to management and planning procedures pertaining to sensitive,
vulnerable, highly dynamic or stressed ecosystems.27
6.4 The Draft Western Cape Rural Land-use Planning and Management Guidelines
The draft Western Cape Rural Land-use Planning and Management Guidelines (DEA&DP
2009a)28
are based on the Western Cape Provincial Spatial Development Framework, an
approved section 4(6) structure plan in terms of the Land-use Planning Ordinance 15 of
1985. They aim to:
22
Section 13, Act 24 of 2008. 23
Section 2, Act 107 of 1998 as amended 24
Section 2(1)c), Act 107 of 1998 as amended 25
Section 2(2), Act 107 of 1998 as amended 26
Section 2(4)(f), Act 107 of 1998 as amended 27
Cf. sub-sections 2(4)(a)(i), (ii), (vi); (b); and (r) 28 http://www.capegateway.gov.za/other/2009/9/wcpsdf_rural_guidelines_may_09_draft_3.pdf
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− Promote sustainable development in appropriate rural locations throughout the
Western Cape;
− Safeguard the functionality of the province’s life-supporting ecosystem services;
− Maintain the integrity, authenticity and accessibility of the province’s significant
farming, ecological, cultural and scenic rural landscapes and natural resources;
− Assist Western Cape municipalities to plan and manage their rural areas more
effectively; and
− Provide clarity to the province’s social partners on what kind of development is
appropriate beyond the urban edge, suitable locations where it could take place, and
the desirable form and scale of such development.
These guidelines delineate Spatial Planning Categories (SPCs) in terms of, among others, the
biodiversity categories that are used by CapeNature’s Critical Biodiversity Area maps29 for
Western Cape municipalities (Pence, 2008; Te Roller and Vromans, 2009). Such SPCs indicate
the type of land use that should be accommodated in the SPC and where these land use
should take place. CBA maps, in turn, provide desired management objectives for the
various mapped biodiversity categories that underpin SPCs.
In the case of the Vleesbaai boat launching site, the following CBAs and SPCs apply:
CBA category Desired conservation
management objective
SPC Appropriate activities
Aquatic CBA
- Maintain natural land.
- Rehabilitate degraded
areas to natural or
near-natural state.
- Manage against further
degradation
Core 1
- ‘No go’ for development. Should
remain undisturbed by human
impact.
- Conservation management to be
encouraged.
- Subject to stringent controls, these
biodiversity-compatible, low impact
land uses may be accommodated:
o Non-consumptive low impact
eco-tourism
o Harvesting of natural resources
o No further loss of natural
habitat
o No large-scale ecotourism
developments
o Encourage land consolidation &
discourage sub-division.
Terrestrial CBA
29
Cf. http://bgis.sanbi.org
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The CBAs and SPCs are particularly relevant to evaluation of the significance of potential
impacts on biodiversity and ecosystems (see Section 6).
6.5 CapeNature’s requirement with respect to biodiversity in development
applications
The Western Cape Nature Conservation Board Act 15 of 1998 designates CapeNature as the
statutory custodian of biodiversity in the Western Cape.
The organisation requires that a biodiversity assessment must be undertaken if a
development may result in the loss of habitat or ecological functioning in any of the
following situations, or if there is any doubt about the biodiversity value of an area
(CapeNature 2008):
− Rivers, wetlands, groundwater-dependent communities and estuaries;
− Critical Biodiversity Areas and Ecological Support Areas;
− Viable or connected Critically Endangered and Endangered ecosystems;
− Any area identified by a systematic conservation plan as important for biodiversity
conservation;
− Any special habitat with unique signature of species;
− Any habitat with rare, threatened or range-restricted plant or animal species;
− Natural habitat in ecological corridors or along vegetation boundaries, including frontal
dune systems; or
− Mountain Catchment Areas.
CapeNature recommends that CBA maps be used as the primary biodiversity informant in
the province. Although the CBA maps represent the best available information, they need to
be ground-truthed and do not replace the need for a specialist assessment (Ralston et al.,
2009). Ground-truthing is also needed to identify potential errors in land cover mapping.
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7. THE RECEIVING ENVIRONMENT
Impact assessment and environmental management need to be undertaken at a scale that is
appropriate to the issues being addressed. In order to determine the appropriate scale of an
EA, it is therefore necessary to understand the distinctive dynamics and sensitivities of the
receiving environment, how it may respond to human pressures, to what spatial extent, for
how long, and to what effect.
This study focuses on the area that is most immediately impacted by the infrequent use of
ORVs in a small, ca. 0.4 ha portion, of the littoral active zone at Vleesbaai in the southern
Cape. The receiving environment is described with the objective of identifying potentially
significant impacts in relation to key sensitivities or vulnerabilities of the affected
ecosystems, their resilience to the effects of ORVs, and the social context.
Chapter 7 summarises the main features of the receiving environment. Chapter 8 considers
the potential environmental consequences or effects of the use of ORVs at the Vleesbaai
boat launching site, and evaluates the significance of these potential consequences or
impacts. It also presents mitigatory measures that would be fed into an operational EMP.
7.1 Location
The Noordstrand launching site at Vleesbaai is located at approximately 34°17’02.99”S,
21°54’42.98”E, in the south-western corner of the coastal landform known as Vlees Bay on
the southern Cape coast (see Figures 1, 2 & 5).30
Mossel Bay, about 23 km to the north-east,
is the closest major settlement. Vleesbaai lies on South Africa’s Indian Ocean coastline.
7.2 Topography
The ‘half-heart’ Vlees Bay (Tinley, 1985) is defined by rocky headlands at Cape St Blaize to
the north-east and the Fransmanshoek Peninsula and Vleespunt to the east, connected by a
concave coastline of about 32 km in length. The Langeberg range, part of the Cape Fold Belt,
lie about 35 km inland in a roughly latitudinal orientation. The mouth of the Gouritz River,
which forms part of a major regional catchment and drainage system, is located about 7 km
(geographic) to the west of Vleesbaai (Figure 1).
The coastline is dominated by sandy shores interspersed by wave-cut platforms that are
generally inundated at high tide. Major stretches of the rocky inter-tidal zone are
periodically smothered by massive deposits of sand that can remain in place for several
years at a time. The defining headlands are made up of quartzitic sandstones of the
Nardouw Formation in the Table Mountain Group. Conglomerates associated with the Enon
Formation are exposed in a fault at Die Hoek, Vleesbaai (Rust, 1998; Malan et al., 1994).
30 1:50 000 topocadastral sheet GOURITSMOND 3421 BD, Chief-Director Surveys and Mapping
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A raised scarp about 40 m above mean sea level (MSL) defines the boundary between the
littoral active zone and adjacent coastal plateau, which is incised by pronounced drainage
lines such as at Danabaai and the Blinderivier, Goebbelskloof and Noordkloof valleys. These
are highly seasonal and ephemeral freshwater systems which are seldom open to the sea.
Once-extensive dune fields are a dominant feature of this coastline, and include the
spectacular Kanon dunes that form a northwards-trending headland bypass system, over the
Fransmanshoek Peninsula, into the adjacent Vleesbaai (Figure 2). The sandy parts of the bay
are rimmed by primary and foredunes which, geomorphically, form part of the littoral active
zone. Sands in the Strandveld Formation predominate on this coastline, which in recent
years has experienced considerable erosion at the Vleesbaai settlement.
Natural sediment dynamics and processes – at a local as well as a regional scale – have
undoubtedly been degraded as a result of extensive infestation of once-mobile dune fields
by the woody rooikrans shrub Acacia cyclops and the construction of roads and property
development that act as physical barriers to the natural migration of sand.
7.3 Climate
Vleesbaai is situated in a region of spring-dominant, bimodal rainfall (Stone et al., 1998).
Mean annual rainfall is 417 mm, peaking in September and April (Cape St Blaize). The dry
season extends from November to March. The mean annual temperature is 17,9°C with an
annual range of 7,1°C. Westerly winds occur throughout the year, the main seasonal
difference being the higher frequency of easterlies in spring and summer. The wind is
predominantly westerly to north-westerly in winter. Desiccating katabatic winds occur under
pre-frontal, anticyclonic conditions from autumn until spring when temperatures can rise up
to 10°C an hour, creating a major fire risk.
There are anecdotal accounts of torrential rain accompanied by flooding and severe erosion
of dunes in the back beach area in Noordkloof, which is also subject to periodic inundation
by sea water that may extend up to 150 m inland from the high water mark (HWM) (Figure
16). The physical effects of pedestrian trampling in sand dunes and impacts of driving on
unconsolidated dry sand are probably most pronounced during the summer holiday season
due an influx of visitors that coincides with high temperatures, low rainfall and strong south-
easterly winds (Figures 4 & 9).
7.4 Ecosystems
The Noordkloof-Noordstrand area is characterised by a number of distinctive, inter-related
landforms and habitats in which features and processes associated with the sandy littoral
active zone are predominant, namely:
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− An open, sandy beach (Noordstrand) spanned by a rocky inter-tidal zone of wave cut
platforms at its northern and southern extremities;
− The drier back beach area, above the high water mark, that grades into Noordkloof and
its combination of unconsolidated sand and embryo and hummock dunes, and
foredunes north and south of the beach; and
− The seaward aspect of a Strandveld valley bottom wetland that potentially forms an
interface with the western, inland portion of the Noordkloof sand flats and mobile
dunes.
These landforms, systems and habitat types (Figure 10) variously fall within the ‘Coastal
Ecosystems’ and ‘Freshwater Ecosystems’ categories defined by the Fynbos Forum
Ecosystem Guidelines for Environmental Assessment in the Western Cape (De Villiers et al.,
2005).31
Figure 10: Habitats of the Noordkloof-Noordstrand ecosystem
The ecosystems are:
− Sandy beaches and dune systems
− Strandveld, dune thicket and dune fynbos
− Wetlands (although not treated as estuarine, this system is at least partly under the
influence of coastal processes and environmental conditions).
31
Downloadable at http://bgis.sanbi.org
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Each of the local manifestations of the aforementioned ecosystems is presented below in
relation to its potential sensitivities to activities associated with the launching of boats at
Noordstrand. From an ecosystem perspective, most of the area in question lies in a natural
sediment movement corridor that extends landwards from the seashore, interfacing with a
highly seasonal Strandveld valley bottom wetland below the Mullerlaan access route.
Noordkloof and the Noordstrand boat launching site are therefore treated as an ecotone
between wetland and sandy beach/littoral ecosystems, in which the latter is overwhelmingly
dominant (Figures 5, 10 & 11).
The rocky inter-tidal zone and inshore area at Die Hoek are also presented as components of
the coastal environment that potentially would be vulnerable to impacts associated with
Alternative 2 (Figures 7 & 8).
Figure 11: Environmental features, Noordkloof-Noordstrand interface
7.4.1 Critical Biodiversity Areas
Virtually the entire extent of Noordkloof, its coastal margin, and the littoral active zone
extending to Boggomsbaai to the north are depicted as a Terrestrial Critical Biodiversity Area
(CBA) on the CBA Map for the Mossel Bay Municipality (Figure 12) (CapeNature, 2008). The
Noordkloof wetland is depicted as an Aquatic CBA on the same map. The land cover for
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Noordkloof directly either side of the western boundary fence is designated as ‘mixed’ by
the Mossel Bay CBA Map.
CBA Maps are derived from systematic conservation planning methods (Margules and
Pressey, 2000; Pence, 2008) and identify the most efficient network of sites that are
required to ensure the continued persistence of:
− Biodiversity pattern (e.g. species, habitats, vegetation types and ecosystems);
− The ecological processes and disturbance regimes by which this biodiversity pattern is
maintained (e.g. seasonal migration of sunbirds or fire in fynbos); and
− The services nature provides to society, such as supplying water, pollination in support
of fruit production, and providing protection against floods.
CBA Maps depict spatially-explicit biodiversity categories that are linked to desired
management objectives. The categories indicate the importance that is attached to a site
owing to its contribution to meeting biodiversity objectives, and therefore serves as an
explicit indication of a site’s contextual significance. The desired management objectives, in
turn, provide the test for determining the appropriateness of a proposed development –
development that is consistent with a site’s desired management objectives would be
appropriate, whereas development that is not consistent with these objectives would
probably not be appropriate, and an alternative should be explored.
This background to CBA maps will inform the evaluation, in Chapter 8, of impacts associated
the use of ORVs in the Noordkloof-Noordstrand area of Vleesbaai.
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Figure 12: Critical Biodiversity Areas, Vleesbaai and environs
7.4.2 Sandy beaches and dune systems
The area that is colloquially known as Noordstrand is an example of a sandy beach
ecosystem associated with the half-heart bays of the southern Cape coastline (see Figures 1,
3 & 9).
Its ~150 m seaward frontage is broadly defined by rocky shorelines to the north and south,
and extends about 50 m inland to a line that roughly corresponds with the base of the
foredunes fronting Vleesbaai-Noord and the seashore to the north (Figures 9 & 11). The
bathing beach covers an area of about 0.4-0.5 ha. The natural ocean wave climate, free
exchange of mobile sands between frontal dunes and the beach, and seasonal cycles of
deposition and erosion are the major drivers of this ecosystem (Clark and De Villiers, 2005).
Wrack such as marine algae and terrestrial plant material washed into the sea by floods
represents an important imported food source for organisms in the littoral active zone.
Seashore fauna and avifauna commonly associated with the area under tidal influence and
sand movement include Plough snails Bullia spp. (a scavenger), Whitefronted Plover
Charadrius marginatus (a shorebird), African Black Oystercatcher Haematopus moquini (a
shorebird) and Kelp Gulls Larus domicanus (a scavenger that feeds on the beach and in open
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water). Sand mussels Donax serra, an important prey species in sandy beach ecosystems,
represent an example of sub-surface macrofauna. Ghost crab Ocypode spp. burrows are
occasionally found in the back beach area, near the HWM. Microscopic interstitial fauna
would occur in the saturated sediments of the inter-tidal zone.
The African Black Oystercatcher is the only Red Data Book species known to occur locally at
Vleesbaai. It has ‘Near-threatened’ status according to the IUCN’s 2009 Red List of
Threatened Species.32
The nearest observed nesting site is on the Fransmanshoek Peninsula,
on a rock-bounded sandy beach about 1,5 km across the bay from Noordstrand. The African
Black Oystercatcher is not considered to be at risk from the use of ORVs at Noordstrand.
Local threats to this species, especially while foraging on rocks at low tide, would potentially
include dogs or, in the longer-term, over-harvesting of bait organisms by humans.
The back beach, i.e. the area immediately inland of the high spring tide drift line (cf. Lubke
and McLachlan, 1998), is characterised by unconsolidated, mobile sands that feed and grade
into the primary and foredune systems (Figures 11 & 15).
The drier sands of the back beach are mostly devoid of plant growth, except for hardy wind,
desiccation and salt-tolerant species such as the ‘seepampoen’ Arctotheca populifolia which
can contribute to dune formation (Figure 15). The terrestrial vegetation here is classified as
Cape Seashore Vegetation, a Least-Threatened ecosystem that is associated with beaches,
coastal dunes, dune slacks and coastal cliffs (Mucina et al., 2006, pp 685 & 686). It comprises
open grassy, herbaceous and, to some extent, dwarf-shrubby (including succulent)
vegetation often dominated by single pioneer species. It occurs on young coastal sandy
sediments (Strandveld Formation) exposed to reworking by relentless winds and frequent
sea storms. Cape Seashore Vegetation has a biodiversity target of 20%. Almost 50% of this
vegetation type is represented in statutory protected areas.
The foredunes fronting Vleesbaai-Noord exceed 2 m in height and have been subject to
considerable erosion over recent years as is evidenced by their cliff-like structure. Anecdotal
accounts (Prof Martin Pauw pers. comm) suggest that the dune face may have retreated by
as much as 15 m since c. 2007. These erosional processes have resulted in breakages to
cement storm water pipes laid in the foredunes, the destruction of a sewage pipe and
potential under-cutting of at least one seafront property. The dunes closest to the
Noordstrand bathing area undergo considerable trampling and localised destabilisation by
beachgoers in the annual high season, December to January (Figure 9).
Isolated hummock dunes approaching an equivalent height to the foredunes extend
westward into Noordkloof (Figures 4 & 14). Embryo dunes, with small colonies of
‘seepampoen’ A. populifolia, are sometimes evident. These structures are often temporary
32 http://www.iucnredlist.org/apps/redlist/details/144070/0
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in nature as they are susceptible to being destroyed by storm surges that have been
observed to wash up to 150 m into Noordkloof.
The dunes to the rear of the Noordkloof sand flats are heavily infested by rooikrans Acacia
cyclops, which also dominates the inland aspect of the foredunes and coastal scarp north of
Noordkloof (Figures 10 & 11).
7.4.3 The Noordkloof Strandveld valley bottom wetland
A Strandveld valley bottom wetland extends about 25 m into the seaward aspect of
Noordkloof at the property boundary between Vleesch Baai Strand 266 (‘Vleesbaai-Noord’)
and the neighbouring farm Buffelsfontein 250/8.
Job et al. (2008) define valley bottom wetlands as low-lying, gently-sloped areas that receive
water from an upstream channel and/or from adjacent hill slopes, not subject to periodic
over-bank flooding by a river channel. Altogether 19 Strandveld valley bottom wetlands,
collectively covering less than 600 ha, have been mapped in the Riversdale Plain planning
domain by CapeNature’s fine-scale biodiversity planning project. Only 14% of these wetland
types are considered more than 80% intact.
Figure 13: Strandveld valley bottom wetland, from access ramp to Noordkloof
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The wetland in Noordkloof is defined as an ‘Aquatic Critical Biodiversity Area’ by the CBA
map for the Mossel Bay Municipality (Figure 12) (CapeNature, 2008).33
Its buffer is identified
as a seep zone which is mapped as extending below the high water mark. The wetland, in
turn, is depicted as extending to a point roughly in line with the main frontage of the
foredunes (cf. Figure 11).
The major extent of the wetland is confined to the adjacent farm, and appears to be in a
highly degraded condition. A spring in the lower end of the wetland has been encased in a
cement structure, the sides of the kloof are infested with rooikrans, the base of the valley is
grazed and trampled by cattle, and natural vegetation at the base of this depression has
been replaced by kweek grasses.
The stretch of wetland between the fence and the access ramp to Noordkloof appears to be
in a more natural condition than the corresponding area of wetland on the farm side of the
fence (Figures 13 & 14). The area has, however, occasionally been used for dumping of
building rubble and other waste, which besides being illegal, has contributed to the
degradation of the Noordkloof wetland.
Whether the seaward aspect of the wetland, which is separated from the shoreline by more
than 100 m of shifting sands and dunes, represents estuarine properties is not viewed as
relevant to this environmental assessment. When the site was visited in October 2009, there
was a small (~1,5 m2) stand of glasswort Sarcicornia meyeriana close to where the fence
runs through the wetland in Noordkloof (Figure 14). The presence of this species, which is
adapted to saline conditions (as can be expected after inundation by sea water under storm
and high tide conditions) suggest salt marsh habitat. The plants were green, indicating a
predominance of fresh rather than salt water (when they turn red). Windblown sand directly
east of the latter vegetation supported two dune pioneer species, Tetragonia spp. and A.
populifolia, which supports the contention that the study area represents a constant
interplay between sandy beach and valley bottom wetland processes, in which the former
predominate.
The tarred ramp into Noordkloof from Mullerlaan skirts the seaward edge of the wetland,
and forms an artificial, fixed barrier that may result in changes to the hydrology of the
wetland. This obstacle probably has less of an impact under irregular high flow conditions
that may follow torrential downpours over the Noordkloof catchment. Vehicles accessing
Noordkloof and the Noordstrand beach do not have a direct impact on the wetland,
although they would traverse the mapped buffer area that incorporates part of the
Noordkloof sediment corridor (Figures 4, 11 & 13).
33 http://bgis.sanbi.org
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Figure 14: Habitats in the sandy beach-wetland ecotone, Noordkloof
The Strandveld aspect of the Noordkloof wetland refers to the vegetation type that is
mapped as potentially occurring in the area, i.e. Groot Brak Dune Strandveld, an
‘Endangered’ ecosystem (Rebelo et al., 2006, pp 206 & 207). The potential presence of Groot
Brak Dune Strandveld probably explains the ‘Terrestrial CBA’ status that is assigned to the
coast between Gouritsmond and Dana Bay by the CBA Map for the Mossel Bay Municipality.
The Sub-tropical Thicket Ecosystem Plan (Pierce et al., 2003) also depicts a coastal ecological
corridor that has been selected for conservation planning purposes along this coastline.
Groot Brak Dune Strandveld occurs on flats, undulating landscapes (stabilised dunes) and
steep coastal slopes (Rebelo et al., 2006). High bird and animal densities are important for
maintaining pollination and seed dispersal in dune thicket (such as Groot Brak Dune
Strandveld) and the maintenance of habitat connectivity is therefore an important
management objective (Helme, 2005, pp 32-37). Because dune slack wetlands contribute to
the overall diversity of this ecosystem, drainage is another important ‘driver’ of ecosystem
functioning.
Given that the access route to the boat launching site runs through an area of
unconsolidated beach sand and shifting dunes, it is unlikely that this area provides habitat
that would support Groot Brak Dune Strandveld unless artificially stabilised and deliberately
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managed to this end. Pockets of this vegetation type do seem, however, to occur just west
of the tarred access ramp, on the stable, north-facing slopes adjacent to and inland of the
fence line that bisects Noordkloof ( i.e. well away from the area subject to the license
application) (Figure 13).
There is no evidence of Groot Brak Dune Strandveld occurring in the area impacted by ORVs
travelling to and from the Noordstrand launching site.
7.4.4 The rocky inter-tidal zone and inshore waters at Die Hoek
The National Spatial Biodiversity Assessment identifies coastal development as the single
greatest threat to the supra-tidal (inshore) zone of the Southern Cape coastline (Lombard et
al., 2004).
Slow-moving or sessile invertebrates are used to categorise animal and plant communities in
the rocky inter-tidal one, which is only habitable by species that are adapted to varying
degrees of exposure to immersion, desiccation and a high energy wave environment (Lubke,
1998). Rocky coastlines and reefs can provide habitat for over-exploited fish species such as
Roman Chrysoblephus laticeps and Dageraad Chrysoblephus cristiceps, both of which are
listed as having ‘orange’ status in terms of WWF-SA’S ‘South African Sustainable Seafood
Initiative’.34
The rocky inter-tidal zone at Die Hoek comprises three major zones defined by the following
indicator species (after Lubke, 1998, pp 174 & 175):
The Inter-tidal Zone The Sub-tidal Zone
Littorina zone
(periwinkles)
Balanoid Zone
(barnacles & mussels)
Cochlear Zone
(limpets)
Infratidal zone
(red-bait and
seaweeds) Upper Lower
Between Mean HW
Spring Tides & Mean
HW Neap tides
Between Mean HW
Neap Tides & Mean
LW Neap tides
Between Mean LW
Neap tides
Between Mean LW
Spring Tide
A slipway at De Hoek would probably extend across the tidal gradient from the Littorina into
the Infratidal zones. It would have an estimated direct ‘footprint’ of 80 to 100 m2, but this
does not take into account construction-related impacts which would probably affect a
wider area, or the impacts associated with excavating an approach channel.
34
http://www.wwfsassi.co.za/?m=1
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7.5 The archaeological context: Shell middens
There are numerous shell middens in the dune and coastal scarp environments of the
broader Vleesbaai area.
They form part of a cultural and historical
heritage that reflects human use of South
Africa’s coastal resources for more than 100
000 years, and the conservation of this
heritage is underscored as vitally important
by the White Paper for Sustainable Coastal
Development (CMPP, 1999).
Webley and Hall (1998) note that open shell
middens represent the most common Later
Stone Age (≤30 000 years before present)
sites along the southern and eastern Cape
coasts. The majority are located within 300 m
from the HWM, but middens have been
found up to as 5 km from the coast. LSA
middens generally consist of shellfish remains
(reflecting the coastal habitat types – sandy
or rocky shores – that provided the food
species). Other archaeological material
potentially includes marine and terrestrial
mammal remains, stone artefacts, bone
tools and sometimes pottery.
In Noordkloof, the nearest observable midden occurs in a raised, east-west trending,
depression in the dunes some 15 m to the NNW of the access route to the launching site.
The midden, which appears to consist of a thin layer of shattered shell remains (the species
is not known), is not threatened by vehicles using Noordkloof to gain access to the launching
site (Figures 11 & 15).
An extensive midden occurs about 700 m to the north in a longitudinal dune slack just south
of the mouth of Goebbelskloof, but the area has become virtually impenetrable due to the
spread of rooikrans. Stone tools, blackened shell deposits, ostrich shell beads and pottery
shards used to be visible in depressions and benches in the calcareous dune scarp north of
Noordkloof but this feature, too, is no longer accessible due to infestation by rooikrans.
Figure 15: Exposed shell midden,
October 2009. By December, three
months later, the area was covered by
drift sand and the midden was no
longer visible.
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7.6 The social context: Bathing and other recreational activities
The first bungalows at Vleesbaai-Noord were built in the late 1950s, and Noordstrand has
been used for launching boats since about 1970.
Vleesbaai is primarily a holiday settlement, with no established commerce or industry
besides a single shop (TV3, 2005). The surrounding land uses are virtually exclusively
agricultural. The nearest settlement is Boggomsbaai, about 2 km up the coast to the north.
There are about 300 houses at Vleesbaai, representing about 60% of the developable land in
the settlement.
The scenic, relatively undeveloped coastal environment with its distinctive landforms,
sheltered waters and occurrence of charismatic marine mammals such as dolphins and
Southern Right Whales Eubalaena australis, contribute to Vleesbaai’s reputation as an
exceptional holiday destination.
7.6.1 Recreational activities and outdoor pursuits
The beach and inshore waters form the focus of outdoor recreational activity at Vleesbaai,
and the resident population peaks during the summer festive season (mid-December to mid-
January) (cf. Frontispiece & Figure 6). Visitor numbers drop significantly during the rest of
the year.
Water sports revolve around swimming, surfing and kayaking. Off-shore boating activities,
i.e. beyond the surf line, include fishing from ski-boats, yachting, and trips in inflatables
(‘rubber ducks’). There is limited use of ‘jet skis’ at Vleesbaai, a form of conveyance that has
been banned in certain areas owing to its unpopularity with the public. Sunbathing, games,
snorkelling (in rocky sections of beach), walking and rock and surf angling are popular
activities. There is a privately-run 4x4 trail on the Kanon dunes,35
and the overnight
‘Oystercatcher Trail’ proceeds past Vleesbaai to Gouritsmond.36
Swimming and other water sports are mostly limited to two beaches at Vleesbaai due to the
rocky coastline: Middelstrand and Noordstrand (Figures 5 & 7). Middelstrand, about midway
between Noordstrand and Die Hoek, is the smaller of the two beaches. Both beaches are
freely accessible to the public. The number of users of the Noordstrand beach increases
when Middelstrand is rendered unfit for bathing due to the removal of sand and exposure of
rocks as a result of storms and natural cycles of erosion and deposition in the littoral active
zone.
35
http://www.trailguide.co.za/trailswesterncape.html 36
http://www.oystercatchertrail.co.za/
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Life-savers are on duty at Noordstrand during the high (summer holiday) season, and
members of the Vleesbaai boat club have reputedly assisted with a number of rescues at sea
(Chris Rabie, pers comm.).
7.6.2 Access to the beach at Noordstrand, Vleesbaai
There is limited space for parking in Vleesbaai, most notably during the peak season, and
vehicular access to the VAB property is controlled by an automated boom. There is
unrestricted pedestrian access to Vleesbaai and its constituent properties, including that
owned by VAB. According to a submission by a local interested and affected party (Mr Johan
Lambrechts, 2 March 2010), there is a need for public parking and ablution facilities at
Noordstrand, which is reputedly Vleesbaai’s most popular bathing beach. This issue, and
that of the control of vehicular access to property owned by VAB, appears have given rise to
considerable local polemic. This matter is addressed in more detail in the ‘Comment and
response’ table (Chapter 9).
Workers and their dependents on nearby farms also make use of the beach and inshore
environment at Vleesbaai, variously as a public throughway to the local shop, or for fishing,
bait collection and swimming.
7.6.3 Municipal services and representation of homeowners
Vleesbaai is located within the boundaries of the Mossel Bay Municipality, but services and
infrastructure are controlled by a private utility, Vleesbaai Dienste. 37
Shareholders are
represented on Vleesbaai Dienste by six companies:
− Keerom Bpk.
− Hoekbaai Huiseienaarsvereniging;
− Visbaai Bpk.
− Driehoek Huiseienaarsvereniging
− Vleesbaai Aandeleblok Bpk; and
− The Karmosyn Homeowners’ Association.
Local environmental and conservation interests are represented through the Vleesbaai-
Noord, Fransmanshoek and Boggomsbaai conservancies. Vleesbaai Dienste also has an
environmental committee. The Fransmanshoek Conservancy employs a full-time
conservator.38
37
http://www.vleesbaai.co.za/ 38
http://www.fransmanshoek.co.za/
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7.6.4 The Vleesbaai Bootklub
In April 1983, the Board of Directors of Vleesbaai Aandeleblok Bpk (VAB) granted the
Vleesbaai Bootklub permission to use the Noordkloof access route, via property registered in
the name of VAB, to launch boats from the beach at the northern extremity of the Vleesbaai
village (cf. Appendix 2,’VAB permission to boat club to use access route via VAB property’).
VAB also compiled rules for the boat club that inter alia limit vehicular access to Noordkloof
to members of the boat club, limit the number of boat club members to 30, and prohibit any
additional membership by owners of ‘jet skis’. Membership of the boat club must be
renewed annually
See Appendix 1 for the full set of boat club rules.
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8. IDENTIFICATION, ASSESSMENT AND EVALUATION OF IMPACTS
ARISING FROM ORV USE OF THE VLEESBAAI (NOORDSTRAND)
BOAT LAUNCHING SITE
This section sets out to identify impacts on the natural and social environments that may
arise from the use of ORVs in the study area, to assess the environmental implications of
such impacts, and to evaluate their significance against appropriate criteria.
Each suite of potential impacts is analysed with reference to specialised literature including
the Fynbos Forum Ecosystem Guidelines for Environmental Assessment in the Western Cape
(De Villiers, et al., 2005), an authoritative peer-reviewed account of threats to sandy beach
ecosystems (Defeo et al., 2008, pp 1-12) and A Field guide to the Eastern and Southern Cape
Coasts (Lubke and De Moor (eds), 1998).
This is followed by recommendations with respect to effective mechanisms to alternatively
avoid, minimise or, where appropriate, remedy loss of biodiversity and disturbance to
ecosystems. The treatment of mitigation measures only applies to Alternative 1, the status
quo and preferred option.
The draft Environmental Management Plan for the Vleesbaai boat launching site is informed
by the proposed preventative and mitigatory measures which will take into account the
natural resilience of the affected ecosystems to transient disturbances.
ADDITIONAL IMPACTS RAISED DURING PUBLIC PARTICIPATION
The public participation process (Chapter 9 and Appendix 8) did not raise any additional
issues pertaining to potential biophysical impacts relating to the use of the Vleesbaai
launching site by the Vleesbaai Bootklub.
Concerns were raised about the provision of public parking and ablution facilities within the
property owned by Vleesbaai Aandelblok Bpk at Noordstrand. Such developments, were
they to be initiated, would not be the responsibility of the Vleesbaai Bootklub, do not fall
within the ambit of this application and are therefore not relevant to the subject of this
environmental assessment process: the launching of boats from an open, sandy beach at
Noordstrand, Vleesbaai with the assistance of ORVs.
The question of parking and ablution faciltiies has, however, been comprehensively dealt
with in the ‘Comments and responses report’ (section 9.7) and is also flagged as a key issue
that may need to be addressed in an appropriate forum.
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 49
8.1 Evaluation method
The method employed here was developed by the Ninham Shand Environmental Section,
which is hereby acknowledged as the authors of this approach.
The potential impacts associated with each of the four alternatives will be evaluated in
terms of spatial extent, magnitude and duration (Table 1), which provides a significance
rating for each impact (Table 2). The probability an impact occurring, and the confidence of
that prediction, will be recorded (Tables 3 & 4 respectively).
The SIGNIFICANCE of an impact is derived by taking into account the temporal and spatial
scales and magnitude. The means of arriving at the different significance ratings is explained
in Table 2.
Table 1: Assessment criteria for the evaluation of impacts
CRITERIA CATEGORY
DESCRIPTION
Extent or spatial
influence of impact
National Loss of habitat in a Critical Biodiversity Area
Regional Boggomsbaai-Vleesbaai-Fransmanshoek and wider
Local Directly neighbouring properties
Site specific Noordkloof and Noordstrand
Magnitude of
impact (at the
indicated spatial
scale)
High Natural and/ or social functions and/ or processes are severely & irreplaceably
altered (including irreversible loss of habitat in CBA)
Medium Natural and/ or social functions and/ or processes are notably altered. but reversible
(including reversible loss of habitat in CBA)
Low Natural and/ or social functions and/ or processes are slightly altered.
Very Low Natural and/ or social functions and/ or processes are negligibly altered.
Zero Natural and/ or social functions and/ or processes remain unaltered.
Duration of impact
Short Term
0-1 year
Medium Term 1-5 years
Long Term More than 5 years
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 50
Table 2: Definition of significance ratings
SIGNIFICANCE
RATINGS LEVEL OF CRITERIA REQUIRED
High • High magnitude with a national or regional extent and long-term duration.
• High magnitude with either a regional extent and medium term duration or a local extent and long term
duration.
• Medium magnitude with a national or regional extent and long-term duration.
Medium • High magnitude with a local extent and medium term duration.
• High magnitude with a regional extent and short term duration or a site-specific extent and long term
duration.
• High magnitude with either a local extent and short-term duration or a site-specific extent and medium
term duration.
• Medium magnitude with any combination of extent and duration except site specific and short term or
regional and long term.
• Low magnitude with a regional extent and long term duration.
Low • High magnitude with a site-specific extent and short-term duration.
• Medium magnitude with a site-specific extent and short-term duration.
• Low magnitude with any combination of extent and duration except site specific and short term.
• Very low magnitude with a regional extent and long term duration.
Very low • Low magnitude with a site-specific extent and short-term duration.
• Very low magnitude with any combination of extent and duration except regional and long term.
Neutral • Zero magnitude with any combination of extent and duration.
Once the significance of an impact has been determined, the PROBABILITY of this impact
occurring as well as the CONFIDENCE in the assessment of the impact, are estimated using
the rating systems outlined in tables 3 and 4 respectively. It is important to note that the
significance of an impact should always be considered in concert with the probability of that
impact occurring.
Table 3: Definition of probability ratings
PROBABILITY RATINGS CRITERIA
Definite Estimated greater than 95 % chance of the impact occurring.
Highly probable Estimated 80 to 95 % chance of the impact occurring.
Probable Estimated 20 to 80 % chance of the impact occurring.
Possible Estimated 5 to 20 % chance of the impact occurring.
Unlikely Estimated less than 5 % chance of the impact occurring.
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 51
Table 4: Definition of confidence ratings
CONFIDENCE RATINGS CRITERIA
Certain Wealth of information on and sound understanding of the environmental factors
potentially influencing the impact.
Sure Reasonable amount of useful information on and relatively sound understanding of the
environmental factors potentially influencing the impact.
Unsure Limited useful information on and understanding of the environmental factors
potentially influencing this impact.
A summary of the significance of the potential impacts is presented in Table 5.
GAPS IN KNOWLEDGE AND UNCERTAINTY OF PREDICTIVE METHODS AND ASSUMPTIONS
As the investigation, assessment and evaluation of impacts was undertaken by a ‘generalist’
environmental assessment practitioner, and not a biodiversity specialist, conservative
confidence ratings have deliberately been recorded where there may have been any
uncertainty as to the type and effect of impacts. Overall, the type, quality and relevance of
information at the EAP’s disposal are viewed as adequate for the purposes of accurately and
confidently identifying, predicting and analysing the potential consequences of impacts of
the environment in question.
8.2. Vulnerabilities of the natural environment w.r.t. ORV use
The in-shore region, inter-tidal zone, back beach, adjacent dunes and at least the portion of
Noordkloof that lies to the seaward of the fence between the Vleesbaai-Noord property and
the adjacent farm is understood to be a contiguous sediment corridor that needs to be
understood and managed as a functional unit or ecosystem. The Strandveld valley bottom
wetland is treated as a distinct ecosystem that is embedded in the sediment corridor, and is
therefore at least partly subject to its dynamics.
The effects of ORV’s driving to and from the Noordstrand boat launching site via Noordkloof
will be assessed in terms of impacts on:
− Coastal ecological processes (sand exchange, mobility, accretion, erosion and dune
formation);
− The Strandveld valley bottom wetland; and
− The Noordstrand-Noordkloof sediment corridor and embedded Strandveld valley
bottom wetland (i.e. as a single functional unit with Aquatic and Terrestrial CBA status).
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 52
8.2.1 A note on impact frequency, scale, resilience of sandy beach ecosystems
and impact reversibility
Spatial and temporal scale, and the frequency and type of impacts, need to be factored into
estimates of the effect, duration and reversibility of ORV-related disturbances to sandy
coastal ecosystems such those associated with the Vleesbaai boat launching site.
At an ecosystem level, impacts to sandy beaches are viewed as reversible over a period of
five to 10 years if the disturbance was not caused by fixed infrastructure or development
(Clark and De Villiers, 2005). This is understood to constitute a highly conservative estimate
as to recovery periods following transient disturbances. Where dune vegetation has been
destroyed, recovery to the climax phase of the successional process may exceed 10 years.
Defeo et al. (2009, p 3), in turn, state that the effects of recreational activities on sandy
beaches, including ORVs, are “particularly noticeable” at scales ranging from weeks to
months, and from <1 to 10 km. However,
Shorter term impacts (i.e. weeks to months) tend to be pulse disturbances (compared
to ‘press’ or sustained, repeated, long-term pressures – CdeV) and effects are generally
expected to last for shorter time periods, since sandy-beach species are adapted to
severe physical disturbances (e.g. storms)... (Defeo et al., 2009, p 2).
These authors note that notwithstanding uncertainty about higher-order ecological impacts
arising from mortalities of beach invertebrates as a result of ORV driving on beaches, there is
evidence to suggest that such impacts can extend beyond the level of individual organisms.
Owing to the temporally and spatially limited frequency of such impact from ORVs at the
Vleesbaai boat launching site, and the natural dynamism and disturbance regime of the
littoral active zone, higher order or secondary impacts arising from mortalities of beach
invertebrates are not considered to be of ecological significance in the context of this
application.
8.3 Potential damage by ORVs to the Noordkloof and Noordstrand sandy beach and
dune ecosystems and coastal processes
Clark and De Villiers (De Villiers et al., 2005: pp 28-31) identify the major threats to sandy
beach ecosystems and coastal processes as stabilisation of naturally dynamic dune systems
and sediment corridors, fixed infrastructure that impedes longshore drift and inshore
sediment dynamics, and destruction of dune vegetation.
Defeo et al. (2009, p 3), in turn, found that the negative impacts most directly associated
with ORVs in sandy beach ecosystems are:
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 53
− Disturbing the physical attributes and stability of dunes and beaches by deeply rutting
the sand surface and destroying embryonic foredunes in the tyre tracks;
− Destroying dune vegetation, leading to lower diversity and less floral ground cover; and
− Disturbing, injuring or killing beach fauna, including endangered vertebrates such as
turtles and shorebirds.
8.3.1 Implications of scale-related factors, type of disturbance and ecological
resilience to impact evaluation
For the purposes of impact evaluation, i.e. determining the potential significance of impacts
on the environment, the use of ORVs at the Vleesbaai boat launching entails:
− A low-frequency (± one month p.a.) pulse disturbance at a highly localised (<1,5 ha)
scale;
− No impact on dune climax vegetation;
− No permanent interference with coastal processes;
− An activity in an environment naturally subject to severe physical disturbances; and
− An activity in an environment that is naturally resilient to transient pressures.
8.3.2 Discussion
The use of ORVs to haul boats to the water’s edge at Noordstrand does not result in the
artificial stabilisation of mobile sands, or entail erection of any fixed infrastructure. It is
therefore viewed as highly unlikely that coastal sediment processes will be negatively
influenced by ORVs in the littoral active zone.
Potentially fatal species-level impacts must be anticipated in the littoral active zone,
particularly with respect to burrowing fauna. These are understood to be locally abundant
and not at risk from anthropogenic pressures. There is no evidence that any threatened
animal species would be at risk from the use of ORVs to access to the Vleesbaai boat
launching site.
In terms of impacts on terrestrial habitats, there is potential of at least some damage to
dune vegetation and embryo dunes in the base of Noordkloof – specifically dune pioneer
plant species – en route to the launching site.
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 54
Figure 16: Effects of coastal processes on sand flats in Noordkloof sediment corridor
Damage such as rutting of vehicle tracks and destruction of dune pioneer vegetation and
embryo dunes is most likely at the start of the summer vacation when there is increased
vehicle use in the littoral active zone, and the route to the beach is ‘opened’ for the first
time that season.
The risk of damage to indigenous dune vegetation is directly linked to the physical state of
Noordkloof’s substrate, the extent of dune formation in the preceding year, rainfall and the
degree of new plant growth or condition of existing dune vegetation. If the kloof was
recently scoured by storm surges, or flooding from the adjacent catchment, there potentially
would be a reduced likelihood of damage to dunes and dune vegetation by ORVs (Figure 16).
If, however, dune formation and colonisation by plants had not been affected by, for
example, storm surges or destabilisation of sand and environmental desiccation as a result
of strong bergwinds, there would be a corresponding increased risk that driving could
damage dune vegetation. Such damage would probably be limited both in extent and effect
due to the wide natural dispersion of embryo dunes and pioneer plants, the proximity of
source populations of these species, ‘once-off’ limitation of such impacts to vegetation
directly in the route to the beach and launching area, and general avoidance by drivers of all
but the smallest dune mounds (cf. Figure 4).
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 55
8.3.3 Measures for impact avoidance and mitigation
The following measures are proposed to prevent and, where adverse impacts are
unavoidable, reduce potential environmental damage by ORVs in the Noordkloof and
Noordstrand sandy beach and dune ecosystems:
− The number of daily launchings with the assistance of ORVs or other vehicles must be
limited to seven a day.
− No more than five vehicles may be parked above the high water mark in Noordkloof at
any one time.
− At the onset of the peak season, i.e. in early December each year, the boat club must
aim to mark the least environmentally harmful route to Noordstrand by driving a
vehicle so that its tracks (‘spoor’) avoid dunes and dune vegetation (the approximate
line of this route is depicted in Figure 11;
− Members of the boat club must be encouraged to follow the same set of tracks in
Noordkloof and to actively avoid straying from the original route;
− Dunes that may pose an obstacle to the safe hauling of boats to and from the beach
may be dug away by hand (i.e. not by mechanical excavation), but only to the extent
that the direct obstacle is removed – note that the removal of 10m2 or more of
indigenous vegetation or sand within 100 m of the HWM constitutes a listed activity in
terms of the EIA regulations and cannot be undertaken without an environmental
authorisation;
− Avoid depositing sand on dune vegetation, and especially dune pioneer species such as
the ‘seepampoen’ A. populifolia or Tetragonia spp;
− Do not park in the dunes or damage dunes when parking;
− Only four-wheel drive vehicles must be allowed into Noordkloof under dry conditions,
and both axles must be engaged for the duration of the trip off tar;
− Drivers must take standard precautions to avoid getting stuck in sand, including
deflating tyres, using gears in high range, maintaining a steady momentum, not making
tight turns, and not allowing the wheels to spin;
− Keep either the front or rear wheels on drier sand when launching or retrieving boats in
the swash zone; and
− Vehicles must under no circumstances, unless authorised to do so, be allowed beyond
the borders of the lines marked A, B and C in Figure 11.
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 56
8.3.4 Assessment summary: Coastal processes (sand exchange, mobility,
accretion, erosion and dune formation)
Alternative 1
Noordkloof &
Noordstrand
Alternative 2
Die Hoek
Alternative 3
‘No-go’ option
Alternative 4
Mossel Bay or
Gouritsmond
No Mit. With
Mit. No Mit.
With
Mit. No Mit.
With
Mit.
No Mit. With
Mit.
Extent Local Site
specific
No impact No impact No
impact
No
impact
No impact No impact
Magnitude Medium Low No impact No impact No
impact
No
impact
No impact No impact
Duration Medium
term
Short
term
n/a n/a n/a n/a n/a n/a
Significance MEDIUM
(-)
VERY LOW
(-)
NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL
Probability Possible Probable Unlikely Unlikely Unlikely Unlikely Unlikely Unlikely
Confidence Certain Certain Certain Certain
Significance: positive impacts indicated by no shading & (+), negative impacts indicated by shading & (-)
8.4 Potential damage by ORVs to the Noordkloof Strandveld valley bottom wetland
Helme (2005) lists major threats to Strandveld and dune thicket vegetation as resort and
urban development and associated impacts (e.g. trampling, dumping and fires) and
uncontrolled driving by ORVs. Day and Job (2005) identify some of the key threats to
wetlands as direct loss of habitat, drainage, separation from up- and downstream systems,
changes in water quality, insufficient buffering from adjacent developments, alien species
and aesthetic degradation.
8.4.1 Discussion
Of these threats and vulnerabilities, the only issue that may potentially arise from ORV use
in the vicinity of the Noordkloof Strandveld valley bottom wetland would be direct damage
to wetland habitat if vehicles deliberately left the tarred access ramp and turned up the
kloof to the west. The probability of this happening is negligible. ORVs do traverse the
mapped Aquatic CBA buffer, but the latter largely overlaps with habitat in the littoral active
zone and impacts would relate to effects on the latter system rather than the valley bottom
wetland (Figures 4 & 11).
The quality of the wetland on the Vleesbaai-Noord property would, in most respects, be
determined by land use pressures occurring on the adjacent farm which lies upstream from
the study area.
As far as could be reasonably ascertained, no Strandveld vegetation or habitat occurs in the
area used by ORVs at Noordkloof. It therefore follows that use of the Noordkloof-
Noordstrand area by ORVs for the purposes of boat launching has no evident impact on
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 57
Groot Brak Strandveld or the integrity of the Terrestrial Critical Biodiversity Area that is
associated with this Endangered vegetation type.
8.4.2 Measures for impact avoidance and mitigation
The following measure is proposed to prevent and, where adverse impacts are unavoidable,
reduce potential environmental damage to the Noordkloof Strandveld valley bottom
wetland:
− Stay on the tarred ramp when driving to and from Noordkloof.
8.4.3 Assessment summary: Strandveld valley bottom wetland
Alternative 1
Noordkloof &
Noordstrand
Alternative 2
Die Hoek
Alternative 3
‘No-go’ option
Alternative 4
Mossel Bay or
Gouritsmond
No Mit. With
Mit. No Mit.
With
Mit. No Mit.
With
Mit.
No Mit. With
Mit.
Extent National Site
specific
No impact No impact No
impact
No
impact
No impact No impact
Magnitude Medium Zero No impact No impact No
impact
No
impact
No impact No impact
Duration Long term Short n/a n/a n/a n/a n/a n/a
Significance HIGH (-) NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL
Probability Unlikely Unlikely Unlikely Unlikely Unlikely Unlikely Unlikely Unlikely
Confidence Sure Certain Certain Certain
Significance: positive impacts indicated by no shading & (+), negative impacts indicated by shading & (-)
8.5 Potential degradation of the Noordstrand-Noordkloof sediment corridor and
embedded Strandveld valley bottom wetland, i.e. Critical Biodiversity Areas
As noted above, the Noordkloof-Noordstrand sediment corridor and embedded Strandveld
valley bottom wetland are understood to constitute different habitat components of a larger
ecosystem in which the dynamics, processes and habitat types associated with the littoral
active zone predominate.
These elements are also assigned Critical Biodiversity Area status. This means that they
should be managed in pursuit of biodiversity conservation objectives and, if not in a natural
state, restored to a natural or near-natural condition, and managed in support of that end.
Overall, there is no single set of impacts or potential combination of impacts arising from the
use of ORVs in this area that, on the basis of available evidence and analysis, may result in
either the long-term, irreplaceable loss of biodiversity or irreversible disturbance to coastal
ecological processes. This conclusion is supported by the finding that the use of ORVs in the
study area would have a ‘very low negative’ significance in terms of potential impacts on
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 58
the functioning of the littoral active zone and its associated ecosystems. The latter finding
also needs to be interpreted in the light of the high degree of resilience – and adaptation –
of such ecosystems to even “severe” pulse disturbances (Defeo et al., 2008, p. 2). It is
inconceivable that the current levels of ORV activity at Vleesbaai could even closely
approximate the magnitude and extent of disturbances that are associated with natural
processes such as storm surges, flooding and desiccation.
Allied to this, is the conclusion that driving in the vicinity of the Strandveld valley bottom
wetland will have no evident impact on this feature as long as drivers keep to the tarred
access ramp.
8.5.1 Measures for impact avoidance and mitigation
See the preventative and mitigatory measures with respect to impacts on coastal sandy
ecosystems and processes and the Noordkloof Strandveld valley bottom wetland.
8.5.2 Assessment summary: The Noordstrand-Noordkloof sediment corridor
and embedded Strandveld valley bottom wetland (i.e. as a single
functional unit with Aquatic and Terrestrial CBA status)
Alternative 1
Noordkloof &
Noordstrand
Alternative 2
Die Hoek
Alternative 3
‘No-go’ option
Alternative 4
Mossel Bay or
Gouritsmond
No Mit. With
Mit. No Mit.
With
Mit. No Mit.
With
Mit.
No Mit. With
Mit.
Extent National Site
specific
No impact No impact No
impact
No
impact
No impact No impact
Magnitude Medium Very low No impact No impact No
impact
No
impact
No impact No impact
Duration Long term Short n/a n/a n/a n/a n/a n/a
Significance HIGH (-) VERY LOW
(-)
NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL
Probability Possible Highly
probable
Unlikely Unlikely Unlikely Unlikely Unlikely Unlikely
Confidence Sure Certain Certain Certain
Significance: positive impacts indicated by no shading & (+), negative impacts
8.6 Potential impacts of a slipway on the rocky inter-tidal zone at Die Hoek
Negative environmental impacts associated with slipways and their construction could
include:
− Direct destruction of habitat and biota;
− Disruption of local food webs and other ecological processes that underpin marine
ecosystems; and
− Disruption of sediment patterns.
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 59
Changes to patterns of local sediment movement as a result of artificial hardening of the
coastline and physical barriers that interfere with longshore drift are likely to be permanent
and can contribute to accelerated coastal erosion in adjacent sandy beach environments.
Biota killed or displaced by construction will probably be replaced through natural processes
of re-colonisation insofar as the reshaped inter-tidal environment would permit this.
A slipway in Die Hoek may potentially result in friction between local homeowners and boat
owners during the construction phase, and over parking, traffic congestion and noise
associated with the launching and retrieval of boats directly adjacent to an urban area.
8.6.1 Measures for impact avoidance and mitigation
It is surmised that construction phase impacts (e.g. traffic, blasting and concrete batching)
may have a broader but, by implication, temporary affect on the local littoral and social
environments. The long-term effects of a slipway at Die Hoek partly could be mitigated
through measures such as reducing the physical size of the structure and designing it in such
a way that inshore sediment dynamics would not be significantly affected. The feasibility of
such an option would need to be assessed.
8.6.1 Assessment summary: Impacts of a slipway on the rocky inter-tidal zone
at Die Hoek
Alternative 1
Noordkloof &
Noordstrand
Alternative 2
Die Hoek
Alternative 3
‘No-go’ option
Alternative 4
Mossel Bay or
Gouritsmond
No Mit. With
Mit. No Mit.
With
Mit. No Mit.
With
Mit.
No Mit. With
Mit.
Extent Local Local No impact No impact No
impact
No
impact
No impact No impact
Magnitude Medium Medium No impact No impact No
impact
No
impact
No impact No impact
Duration Long-term Long-term n/a n/a n/a n/a n/a n/a
Significance MEDIUM
(-)
MEDIUM
(-)
NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL
Probability Highly
probable
Highly
probable
Unlikely Unlikely Unlikely Unlikely Unlikely Unlikely
Confidence Sure Certain Certain Certain
Significance: positive impacts indicated by no shading & (+), negative impacts
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 60
8.7 Vulnerability of shell middens to ORVs
Archaeological sites are particularly vulnerable to damage and destruction by ORVs.39
Furthermore, archaeological sites such as coastal shell middens are non-renewable and
irreplaceable: once destroyed, they cannot be restored (Webley and Hall, 1998).
At Vleesbaai, there is no evident risk of interaction between ORVs travelling to and from the
local boat launching site at Noordstrand and any shell middens.
In the absence of any foreseen changes to the access route through Noordkloof, or
reconfiguration of semi-stabilised dunes near the boundary with the adjacent farm – i.e. the
location of the closest observed midden to the access route – shell middens are not viewed
as being vulnerable to the use of ORVs at the Vleesbaai boat launching site.
8.7.1 Measures for impact avoidance and mitigation
The following measures are proposed to prevent damage by ORVs to shell middens and
other heritage resources in the Noordkloof-Noordstrand environment:
− Drivers must at all times comply with the instruction relating to driving in the
Noordkloof and Noordstrand sandy beach and dune ecosystems;
− Drivers must under no circumstances deviate west of the line marked A in Figure 11;
− No shell middens or any other heritage resources may be moved, removed,
damaged or otherwise interfered with; and
− Any potential contraventions with respect to the National Heritage Resources Act
must be reported to the boat club and the Directors of Vleesbaai Dienste.
8.7.2 Assessment summary: Shell middens
Alternative 1
Noordkloof &
Noordstrand
Alternative 2
Die Hoek
Alternative 3
‘No-go’ option
Alternative 4
Mossel Bay or
Gouritsmond
No Mit. With
Mit. No Mit.
With
Mit. No Mit.
With
Mit.
No Mit. With
Mit.
Extent National Site
specific
No impact No impact No
impact
No
impact
No impact No impact
Magnitude High Zero No impact No impact No
impact
No
impact
No impact No impact
Duration Long term Short n/a n/a n/a n/a n/a n/a
Significance HIGH (-) NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL
Probability Possible Unlikely Unlikely Unlikely Unlikely Unlikely Unlikely Unlikely
Confidence Certain Certain Certain Certain
39
http://www.unep.org/Geo/gdoutlook/041.asp
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 61
8.8 Vulnerability of bathers and other users of the Vleesbaai boat launching site
The formal management and control of ORVs at the Vleesbaai boat launching site is closely
integrated with the general oversight function of Vleesbaai Aandeblok Bpk, which represents
all shareholders at Vleesbaai-Noord.
Vleesbaai Aandeblok Bpk exercises authority over the boat club through a set of rules that is
binding on boat club members (see Appendix 1), control over access to Noordkloof via the
Mullerlaan gate, and general rules of public and environmental conduct that apply to all
shareholders.
There is a strong likelihood that any dissatisfaction with the conduct of boat club members
would be raised with the Directors of Vleesbaai Aandeblok Bpk, and reported at the entity’s
annual general meeting.
As far as can be reasonably ascertained, no formal complaints of this nature have been
raised with Vleesbaai Aandeblok Bpk, although concern has apparently been expressed
about the perceived nuisance associated the use of ‘jet skis’ at Vleesbaai.
In practice, bathers and other beach users will temporarily move away from the
approaching vehicles and launching site while boats are either launched from trailers on
winched in to place prior to removal from the beach (cf. Frontispiece & Figure 6). Most
launchings are completed within 20 to 30 minutes (Van Jaarsveldt – pers comm).
As far as could be reasonable ascertained, there have been no accidents at the Vleesbaai
boat launching site that have caused physical injury to non-boating members of the public.
It is concluded that boat launching at Noordstrand represents, at worst, a temporary
inconvenience for other users of this beach and, overall, is generally treated as a legitimate,
inoffensive use of this portion of the southern Cape coastline.
8.8.1 Measures for impact avoidance and mitigation
The following measures are proposed to prevent any risk of harm by ORVs to bathing and
other people seeking enjoyment of the Noordstrand beach and environs:
− Drivers must at all times comply with the rules of the Vleesbaai Bootklub (Vleesbaai
Aandeleblok Bpk (VAB): Bootklubreëls);
− All vessels must have an appropriate certificate of seaworthiness;
− Skippers must, where relevant, be able to producer their skippers’ licences;
− ORVs must be parked inland of the upper drift line, at the base of the foredunes to the
NW of the launching site;
− Boat engines may not be switched on out of the water;
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 62
− No fish may be gutted or otherwise cleaned on the beach;
− Skippers and all persons involved with launching and retrieving boats must exercise the
highest degree of caution towards bathers and other members of the public, especially
when vessels are leaving or approaching the launching site;
− Boats must remain outside of the demarcated swimming area, and be well clear of
bathers and other people in the water, except when leaving or approaching the
launching site;
− All boating activities, except those relating to launching or retrieval, must take place to
the seaward of the anchored buoys; and
− Jet skis must proceed to areas that are not off-shore to the built settlement of
Vleesbaai
8.8.2 Assessment summary: Impacts on bathers and other users of the
Vleesbaai boat launching site
Alternative 1
Noordkloof &
Noordstrand
Alternative 2
Die Hoek
Alternative 3
‘No-go’ option
Alternative 4
Mossel Bay or
Gouritsmond
No Mit. With
Mit. No Mit.
With
Mit. No Mit.
With
Mit.
No Mit. With
Mit.
Extent National Site
specific
No impact No impact No
impact
No
impact
No impact No impact
Magnitude High Zero No impact No impact No
impact
No
impact
No impact No impact
Duration Long term Short n/a n/a n/a n/a n/a n/a
Significance HIGH (-) NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL
Probability Unlikely Unlikely Unlikely Unlikely Unlikely Unlikely Unlikely Unlikely
Confidence Sure Certain Certain Certain
8.9 Potential financial costs and the question of ‘reasonableness’ and ‘feasibility’
It is believed that the question of financial affordability of alternatives needs to be taken into
account as this would inter alia address the question of what, from the applicant’s point of
view, would constitute a ‘reasonable’ and ‘feasible’ alternative relative to the general
purpose of the activity. In this instance, the latter entails launching boats from an open
beach at Vleesbaai under the aegis of the Vleesbaai Bootklub.
Detailed cost analyses have not be undertaken other than obtaining one quotation from a
consulting civil engineer on the potential costs of building a concrete slipway at Die Hoek
(Appendix 3). The comparison of direct financial costs associated with the respective
alternatives is straightforward and does not required any level of analysis other than
identifying potential areas of spending, i.e. constructing a new slipway and extra travel
costs.
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 63
Alternative Construction
costs (R)
Extra travel
Costs/launch (R)
1. Noordstrand Nil Nil
2. Die Hoek 360 000 [corrected amount] Nil
2. No-go Nil Nil
3. (a) Mossel Bay ~60 km / (b)
Gouritsmond ~46 km
(11 km/ℓ @ R7.42/ℓ)40
Nil (a) R40.47
(b) R31.02
Construction of a concrete slipway at Die Hoek would require an environmental
authorisation, and probably lease agreements in terms of the Sea-shore Act and National
Environmental Management: Integrated Coastal Management Act. The EIA process (at least
a basic assessment in terms of GN R. 366 of 21 April 2006) would cost in the order of R100
000 to R200 000; an amount approximating the latter figure is almost certain if a marine
biologist or similar specialist were to participate in the investigation. If construction costs are
included, a new slipway would cost at least R400 000. It is unlikely that a sponsor, or
proponent, for such expenditure would be readily forthcoming at Vleesbaai.
For the purposes of evaluating the significance of constraints that the different options may
place on their feasibility, reasonableness and practicability, construction of a slipway at Die
Hoek (Alternative 2), complete cessation of boat launching at Vleesbaai (Alternative 3), and
travel beyond Vleesbaai to launch boats elsewhere (i.e. Alternative 4), are all assigned a
significance value of ‘High negative’, with a probability rating of ’Definite’. This reflects the
views of the Vleesbaai Bootklub.
Retention of the status quo, i.e. Alternative 1, is treated as ‘definitely’ having a ‘High
positive’ significance.
8.10 Comparative assessment of the significance of all four alternatives
Table 5 summarises (a) the significance of impacts of all four alternatives, without and with
mitigation, on the Vleesbaai environment, and (b) the significance of constraints that would
weigh against the alternatives when measured against the criteria of cost, feasibility and
reasonableness.
The probability of the potential impacts occurring is also included.
40
RSA pump price for diesel in coastal areas on 3 Dec 2009, Calculation excludes wear-and-tear, etc
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 64
Table 5: Summary of impact significance of all four alternatives
8.10.1 Alternative 1 – The status quo and preferred option
Alternative 1 entails the continuation of the status quo, i.e. launching boats at Noordstrand,
Vleesbaai, via Noordkloof. The activities associated with Alternative 1 are found – if suitably
– mitigated to hold no threat, or have any negative significance, with respect to the
Noordkloof valley bottom wetland, shell middens, bathers, and the rocky inter-tidal zone.
In a worst case scenario, there may be impacts of ‘high’ negative significance on the locally-
designated Critical Biodiversity Areas if the latter’s’ management objectives were to be
compromised, i.e. if the objectives of maintaining the CBAs in a natural state or, if not
natural, rehabilitation to a natural or near-natural state, were to be subverted. It is
understood that such impacts would be associated with the irreversible degradation of
coastal ecological processes and/or irreplaceable loss of priority biodiversity, coupled with
no attempt to neutralise these threats or to pursue remediation of their effects.
It is the finding of this environmental assessment that the launching of boats and associated
use of ORVs probably do have some impact on coastal ecological processes and the
biodiversity value of the affected CBAs, but that such impacts are transient, of very low
significance and of negligible environmental consequence when measured against the
severity of the natural disturbance regime and resilience of the affected ecosystem. There is
consequently no evident environmental justification for relinquishing Noordstrand as a boat
launching site.
Even without especial mitigatory interventions, i.e. besides those already practised by the
Vleesbaai Bootklub, the use of ORVs for the purposes of launching boats at Noordstrand is
viewed as compatible with the management objectives of the affected CBAs, and the non-
Alternative 1
Noordkloof &
Noordstrand
Alternative 2
Die Hoek
Alternative 3
‘No-go’ option
Alternative 4
Mossel Bay or
Gouritsmond
Vulnerable
feature No Mit.
With
Mit. No Mit.
With
Mit. No Mit.
With
Mit. No Mit.
With
Mit.
Coastal
processes
LOW (-)
Probable
LOW (-)
Possible NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL
Valley bottom
wetland
LOW (-)
Unlikely
NEUTRAL
Unlikely NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL
CBAs HIGH (-)
Possible
V. LOW (-)
High. prob. NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL
Shell middens HIGH (-)
Possible
NEUTRAL
Unlikely NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL
Bathers, etc HIGH (-)
Unlikely
NEUTRAL
Unlikely NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL NEUTRAL
Rocky inter-
tidal zone NEUTRAL NEUTRAL
MEDIUM
(-)
Probable
MEDIUM
(-)
Probable
NEUTRAL NEUTRAL NEUTRAL NEUTRAL
Feasibility &
reasonableness
HIGH (+)
Definite
HIGH (+)
Definite
HIGH (-)
Definite
HIGH (-)
Definite
HIGH (-)
Definite
HIGH (-)
Definite
HIGH (-)
Definite
HIGH (-)
Definite
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 65
consumptive, low impact ecotourism recommended by the draft Western Cape Land-use
Planning and Management Guidelines.
From a boating safety point of view, Noordstrand represents the most suitable launching
site at Vleesbaai.
Overall, Alternative 1 represents the most feasible and reasonable option when weighed
against its largely inconsequential effects on the receiving environment and the general
purpose of the activities and expectations of the Vleesbaai Bootklub.
8.10.2 Alternative 2 – Construction of a slipway and access road at Die Hoek
Alternative 2 would entail building a new slipway at Die Hoek, Vleesbaai. This would incur
considerable financial costs to the boat club. A slipway would also result in the irreversible
destruction of an area of rocky shoreline and would probably have a long-term if relatively
localised impact on coastal sediment patterns and processes. The launching and retrieval of
boats at Die Hoek also would be considerably more hazardous than is the case at
Noordstrand. Die Hoek is, however, a local site that would be more convenient to use than,
for example, launching sites at Gouritsmond or Mossel Bay (Alternative 4).
On environmental grounds, and weighed against the general purpose of the activities and
expectations of the Vleesbaai Bootklub, Alternative 2 emerges as considerably less feasible
and reasonable than the preferred option, i.e. Alternative 1.
8.10.3 Alternative 3 – The ‘no go’ option
Alternative 3 is the ‘no go’ option. This would hold no benefit for the Vleesbaai Bootklub,
and therefore cannot be treated as a feasible or reasonable alternative from the boat club’s
perspective. Although the ‘no go’ option would undoubtedly hold some environmental
advantage, this would be miniscule to the point of insignificance; it would certainly not
justify the cessation of the boat club’s use of Noordkloof and Noordstrand for the purposes
of launching boats at Vleesbaai. In contrast, dune rehabilitation, alien clearance and
restoration of the Noordkloof wetland would be of far greater benefit to the environment
than implementing Alternative 3.
8.10.4 Alternative 4 – Launching boats at Gouritsmond or Mossel Bay
Alternative 4 would entail the Vleesbaai boat club abandoning Vleesbaai as a site for
launching boats into the sea and instead relocating its activities to slipways at Gouritsmond
or Mossel Bay. Like the ‘no go’ option, this holds no defensible environmental advantage or
motivation and, in the case of Gouritsmond, can entail significant safety risks. It would be
neither feasible nor reasonable for the boat club to uproot itself in favour of launching sites
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 66
that entail roundtrips by road of nearly 50 or more kilometres when Noordstrand is less than
150 m from the nearest tarred access point at Vleesbaai.
The next section presents the public participation process that was undertaken in fulfilment
of the requirements of s 24(4)(a)(v) of the National Environmental Management Act 107 of
1998 as amended.
It is followed by the final chapter (10), which records the conclusions and recommendations
of this environmental assessment. Chapter 10 also introduces the outline of the draft
management plan and monitoring protocol for Alternative 1, i.e. the boat launching site at
Noordstrand, Vleesbaai, and its approaches through Noordkloof.
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 67
9. THE PUBLIC PARTICIPATION PROCESS
This chapter records the public participation process that was undertaken in support of the
application which is the subject of this environmental assessment report.
Public participation is a definitive aspect of the integrated environmental management
process. It inter alia serves as a structured opportunity for interested and affected parties to
identify potentially significant environmental impacts and matters of concern that are
germane to an environmental decision and therefor may require further investigation. Public
knowledge and interests can also positively influence a project during the planning and
design phases, thereby pre-emptively addresssing and responding to environmental
concerns through the selection of suitable alternatives.
Section 9.1 outlines the legal basis for public participation in terms of the National
Environemntal Management Act 107 of 1998 and confirms the compliance of this
environmental assessment process with the guidelines and reporting requirements on
public participation processes as stipulated by the DEA&DP Guideline on Public Participation
(DEA&DP, 2009b).
Key aspects covered are (relevant sections cross-referenced in brackets):
− The potential interested and affected parties who were notified of the application (9.3);
− The steps that were taken to notify such potentially interested and affected parties (in
civil society and the state) (9.4);
− Proof that notice boards, advertisements and nofications had been displayed, placed or
given to potentially interested and affected parties (9.5);
− A list of all the persons, organisations and organs of state who were registered as
interested and affected parties (9.6);
− A comments and responses report that summarises the issued that were raised by
intererested and affected parties, the date of receipt, and the response thereto (9.7);
− A summary of issues that were incorporated in the body of the final environmental
assessment report or the environmental management plan (9.8); and
− Copies of all the comments received from interested and affected parties (9.9).
Appendix 8, ‘Public participation I’, contains a complete record of all notifications and
correspondence exchanged in connection with this public participation process for the first,
formal period of consultation, viz. 5 February 2010 to 19 March 2010. Appendix 9 (‘Public
participation II’) records comment by interested and affected parties on this (final) draft of
the environmental assessment report.
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 68
9.1 The legal basis for public participation
Section 1 of the National Environmental Management Act 107 of 1998 defines a 'public
participation process' , in relation to the assessment of the environmental impact of any
application for an environmental authorisation, as “a process by which potential interested
and affected parties are given opportunity to comment on, or raise issues relevant to, the
application”.
The right of the public to informed participation in applications for environmental
authorisation is entrenched in NEMA’s provisions relating to the National Environmental
Management Principles,41
the minimum procedures for environmental assessment,42
and
the objectives of integrated environmental management.43
In terms of the National Environmental Management Principles (cf. 6.3, p 31),
The participation of all interested and affected parties in environmental governance
must be promoted, and all people must have the opportunity to develop the
understanding, skills and capacity necessary for achieving equitable and effective
participation, and participation by vulnerable and disadvantaged persons must be
ensured…44
The minimum procedures for environmental assessment (cf. Ch 2 of this report), stipulate
that an environmental assessment process—
must ensure, with respect to every application for an environmental authorisation
public information and participation procedures which provide all interested and
affected parties, including all organs of state in all spheres of government that may
have jurisdiction over any aspect of the activity, with a reasonable opportunity to
participate in those information and participation procedures…45
The general objectives of integrated environmental management, in turn, include the
requirement to—
ensure adequate and appropriate opportunity for public participation in decisions
that may affect the environment… 46
41
Section 2, Act 107 of 1998 42
Section 24(4), Act 107 of 1998 43
Section 23, Act 107 of 1998 44
Section 2(4)(f), Act 107 of 1998 as amended 45
Section 24(4)(a)(v), Act 107 of 1998 as amended 46
Section 23(2)(d), Act 107 of1998 as amended
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 69
9.2 The Western Cape guideline on public participation
The Western Cape guideline on public particiation in environmental processes (DEA&DP,
2009b) provides guidance on the procedures to be followed when conducting public
participation processes in terms of the NEMA and the EIA regulations.
The guidelines among others reiterates the mandatory nature of public participation,
stipulate when and how to conduct public participation processes, and how to report on
them. The section dealing with reporting on public participation processes (DEA&DP, 2009b,
p 19) addresses the reporting requirements for the prescribed basic assessment and scoping
and EIA procedures, neither of which applies to this application. However, this chapter is
structured according to the reporting format prescribed by the DEA&DP guidelines to ensure
conformity with the provincial standard on public participation.
9.3 Potential interested and affected parties who were notified of the application
The public participation process was conducted in two phases:
− Firstly an informal one to notify Vleesbaai residents and holiday home owners of the
application during the 2009/2010 festive season; and
− Secondly, the formal public participation process which invited comment on the draft
environmental assessment and EMP between 5 February 2010 and 19 March 2010 (i.e.
a period of 42 calendar days). This phase of public participation placed the application
in the broad public realm, i.e. it was aimed at notifying all potential I&APs of the
application, as well as targeting particularly official roleplayers who may have
jurisdiction over some aspect of boat launching and/or the environment in which it
takes place.
− Registered interested and affected parties were subsequently invited to comment on
this (final) draft of the environmental impact report. The second leg of the formal public
participation process took took place between 14 April 2010 and 7 May 2010. All
comment received will be submitted to the DEA&DP appended to this report in an
appendix,
9.3.1 The informal phase of public participation
The informal phase of public participation was aimed at notifying those persons who would
potentially be most interested in this application, and most directly affected by the activities
of the Vleesbaai Boat Club, i.e. that population of local holiday home owners who would
disperse to their permanent residences at the end of the summer school holidays.
It entailed an information document and draft Environmental Management Plan being given
to Vleesbaai Dienste for distribution to all the Vleesbaai homeowner associations, i.e.,
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 70
− Keerom Bpk;
− Hoekbaai Huiseienaarsvereniging;
− Visbaai Bpk;
− Driehoek Huiseienaarsvereniging;
− Vleesbaai Aandeleblok Bpk; and
− The Karmosyn Homeowners’ Association.
The recipients of the documents were invited to report any factual corrections by 8 January,
2010 (none was received) and advised that they would be formally notified of the public
participation process when it commenced in January or February 2010.
9.3.2 The formal phase of public participation
The formal phase of public participation was initiated on 5 February 2010 with the
publication of a notice in ‘Die Burger’ (see Appendix 8). Interested and Affected Parties who
were specifically notified of the application were:
Interested and affected party Contact person/s
The Mossel Bay Municipality Mr Eddie Kruger, Mr Warren Manuel
CapeNature Dr Wietsche Roets
The Sub-Directorate: Coastal Planning and
Environmental Protection of Marine and Coastal
Management , Department of Environmental Affairs
Dr Niel Malan, Ms LM Motaung
The Fransmanshoek Conservancy Mr Wayne Meyer, Mr Ronald Scholtz
The Boggomsbaai Conservancy Mr Fred Orban
Vleesbaai Dienste Dr Martin Pauw/The Secretary
Keerom Bpk Mr Hendrik Schoeman/The Secretary
Hoekbaai Huiseienaarsvereniging Mr Koos du Preez/The Secretary
Visbaai Bpk Mrs Anna Basson/The Secretary
Driehoek Huiseienaarsvereniging Mr Johan Lambrechts/The Secretary
Mr Andre du Plessis/ The Secretary
Vleesbaai Aandeleblok Bpk Dr Martin Pauw/The Secretary
The Karmosyn Homeowners’ Association Mrs Elmarie Snel/The Secretary
9.4 Actions to notify potential interested and affected parties
Five techniques were used to notify potential I&APs of the application:
− Placing a formal notice in a regional newspaper
− Giving key statutory stakeholders bound copies of the draft environmental assessment
− Lodging bound copies of the draft environmental assessment in two public places
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 71
− E-mail notification of directly abutting neighbours and the two local conservancies
− Placing notices in public places at Vleesbaai.
I&APs who so requested were e-mailed either the entire draft report, or the executive
summary and the draft EMP.
The notification process specifically entailed—
− Placing a formal notice, as per the DEA&DP guideline on public participation, in ‘Die
Burger’ of 5 February 2010 (which provided I&APs 42 days’ opportunity, i.e. until 19
March 2010, to comment on the executive summary, draft environmental assessment
and Afrikaans and English translations of the draft environmental management
programme).
− Submitting bound copies of the complete draft environmental assessment and related
documentation with the key statutory stakeholders (viz.The Mossel Bay Municipality,
CapeNature and Marine and Coastal Management’s Sub-directorate: Coastal Planning
and Environmental Protection) on or before 5 February 2010;
− Lodging a bound copy of the draft environmental assessment and all related
documentation with the Mossel Bay Municipal Library and the Vleesbaai Strandwinkel
respectively, on or before 5 February 2010;
− Notifying the Secretary of Vleesbaai Dienste of the application by e-mail on 5 February
2010, and requesting that all the companies at Vleesbaai also be notified of the
application;
− Notifying, by e-mail, the Fransmanshoek and Boggomsbaai conservancies of the
application on 5 February 2010; and
− Placing an A3-sized notice on the Vleesbaai Dienste noticeboard at the Vleesbaai
Strandwinkel, as well as on the locked gate that bars vehicular access to Noordstrand
and the launching site for which the Vleesbaai Boat Club is seeking official recognition.
9.5 Proof of notice and record of registration of I&APs
Appendix 8 contains a full record of the correspondence that was generated by this
application.
The chronology of notifications and reminder to I&APs is as follows:
Date Action Proof
Feb
3-5 Bound copies of reports deposited with Mossel
Bay Municipality, CapeNature, Marine and
Coastal Management
CapeNature – e-mailed
confirmation W Roets, 8 Feb;
MCM – e-mailed confirmation,
Dr D Malan, 22 Feb
3-5 Bound copies of reports deposited with Mossel MB library – telephonic
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 72
Bay Library and Vleesbaai Strandwinkel confirmation, 3 Feb; e-mailed
confirmation, Dr M Pauw 9 Feb
3-5 Notices displayed at Vleesbaai Confirmed in situ, 16 Feb
5 Notice published in ‘Die Burger’ See Appendix 8
5 Notice e-mailed to Fransmanshoek Conservancy See Appendix 8
5 Notice e-mailed to Boggomsbaai Conservancy See Appendix 8
5 Notice e-mailed to Vleesbaai Dienste See Appendix 8
9 Confirmation by Vleesbaai Dienste that notice
distributed to all six local companies
See Appendix 8
13 Reminder e-mailed to all six local companies See Appendix 8
14 Reminder e-mailed to Boggomsbaai Conservancy See Appendix 8
14 Reminder e-mailed to Marine and Coastal
Management
See Appendix 8
15 Vleesbaai Dienste e-mailed notice to companies See Appendix 8
March
17 Reminder e-mailed to Mossel Bay Municipality See Appendix 8
17 Reminder e-mailed to Marine and Coastal
Management
See Appendix 8
9.6 Registered interested and affected parties
The following persons or organisations were registered as interested and affected parties.
Those I&APs that commented on the application are identified, with the date of comment.
Interested and affected
party
Commented
Yes/No
Date of reg-
istration
Date of comment
Mossel Bay Municipality
(initially indicated would not
be commenting)
Yes 17 March First comment: 19
March
Revised comment: 25
March
CapeNature Yes 8 February 11 March
Marine and Coastal
Management
Yes 22 February 23 March
Vleesbaai Dienste No 9 February No comment.
Permission to use
notice boards (29 Jan)
Vleesbaai Aandeleblok Bpk Yes 9 February 15 March
Mr Johan Lambrechts Yes 18 February Initial comments: 17 &
19 February
Revised comment: 2
March
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 73
Mr PC le Roux No 8 February No comment
Fransmanshoek Conservancy Yes 5 February 5 March
Boggomsbaai Conservancy No No response No response
Mr Chris Rabie Yes 5 March 5 March
Mr Marius de Jager No 17 February No comment
Mr Alfrancois Henning No 25 February No comment
9.7 Comments and responses report
The comments and responses report is a summary of the major points raised by I&APs , and
particularly those that potentially could have a material bearing on the decision that is being
sought. A full record of I&AP comment is contained in Appendix 8.
In certain instances, I&AP comment has been addressed in the main body of the report. This
particularly relates to situations where IA&Ps have presented new information, or issues
have been raised that were not identified in the draft environmental assessment. Such
comment is clearly indicated in the comments and responses table.
MOSSEL BAY MUNICIPALITY (Mr Warren Manuel, Environmental Officer)
Comment Response
19 March 2010 Queried if the Strandveld
valley bottom wetland did not need to be
delineated, and if approval should not be
obtained in terms of the National Water Act
36 of 1998. Who would enforce ‘measures
for impact avoidance and mitigation’ w.r.t.
vehicles sticking to the ‘least
environmentally harmful route’? Swimming
area must be demarcated by buoys –
municipality would be held liable in the
event of incidents. Queried if people who did
not belong to the Vleesbaai Bootklub would
be able to launch their boats. Asked how
impacts on CBA could be justified for site
that offered ‘very limited localised service’.
Municipality could not comment until
CapeNature and DWAF had commented on
‘wetland issue’.
In response, it was explained in an e-mail
communication on 19 March 2010 to the
municipality that that there was a negligible
risk of vehicles entering the Strandveld valley
bottom wetland, chiefly because there
would be no reason to do so. The issue of
wetland had been raised because of the high
contextual significance of an aquatic CBA.
Wetland delineation was, however,
unnecessary because there was no evident
interaction between driving in Noordkloof
and the functioning or quality of the
wetland in question. Noordkloof and the
portion of the wetland that intruded into the
VAB property were dominated by the
processes and characteristics of the sandy
littoral active zone, of which the wetland
was a small component not impacted by
driving. Wetland delineation was therefore
not relevant to the decision being sought.
The Mossel Bay Municipality was requested
to reconsider its comment. Referred
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 74
25 March 2010 The Mossel Bay Municipality
indicated it had no objections to the
application provided that applicant adhered
to all recommendations and mitigation
measures included in the Draft EA.
municipality to pp 41-44, 55-57 of draft EA
w.r.t. wetland-related impacts. Advised
municipality that Dr Wietsche Roets of
CapeNature was prepared to discuss issues
raised by the municipality.
It will be recommended to the DEA&DP that
all recommendations and mitigation
measures included in the Draft EA be
reflected in the Record of Decision and that
implementation of the EMP be recorded as
a condition of authorisation.
CAPENATURE (Dr Wietsche Roets)
Comment Response
11 March 2010 Ecological issues have been
adequately dealt with and included in the
proposal. CapeNature has no objection to
application. All recommendations and
mitigation measures in the report have to be
included in the final approval. CapeNature
reserves right to revise comments if any
additional information were to be received.
It will be recommended to the DEA&DP that
all recommendations and mitigation
measures included in the Draft EA be
reflected in the Record of Decision and that
implementation of the EMP be
incorporated as a condition of
authorisation.
SUB-DIRECTORATE: COASTAL PLANNING AND ENVIRONMENTAL PROTECTION, MCM (Ms
LM Motaung)
Comment Response
23 March 2010 (a) Launch site boundaries
need to be indicated by boards to prevent
user conflict and avoid driving outside the
launch site.
(a) The Vleesbaai boat club believes that
there are sufficient measures in place to
prevent user conflict and driving outside the
launch site. In terms of managing the
interaction between boat launching and
bathing (both of which are highly seasonal
activities), the bathing beach at Noordstrand
is monitored by lifesavers during the peak
season, the swimming area is marked by
flags, and the rules of the Vleesbaai boat
club also place strict guidelines on boat
launching. Given the absence of any known
history of user conflict over launchings from
the beach, the limited number of daily
launchings in the high season (3-4 daily), and
effectiveness of existing controls over
vehicle use in the coastal zone at
Noordstrand, Vleesbaai, additional control
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 75
(b) Launch site needs demarcated parking
area to avoid vehicles parking in dunes.
(c) EA must address issue of public use of
beach during launching.
(d) EA must indicate number of boats that
can be launched daily, and number of
vehicles that can be parked at launch site per
day.
(e) Vehicle access points to launch site must
be marked.
measures are not deemed necessary. Also,
Fig. 1 of the draft EMP (p 4) clearly indicates
boundaries beyond which vehicles must not
be allowed.
(b) Vehicles do not park in the dunes, and a
demarcated parking lot is neither feasible
nor environmentally desirable due to
unstable substrate and the adverse
ecological impacts that would result from
hard development in the littoral active zone,
which is a naturally dynamic ecosystem. In
order to pre-empt any environmetnal risk
arising from parking. The EMP has been
amended to clearly prohibit parking in
dunes, or damaging dunes when parking
(paragraph ‘e’, section 7.2.1).
(c) The rules of the Vleesbaai Boat Club (App
1 of the draft EA) and section 7.2.3 of the
EMP directly address impact avoidance and
mitigation of launching w.r.t. people using
Noordstrand.
(d) The EMP has been amended to state
that:
- “No more than five vehicles may be
parked at any time at Noordstrand”
(paragraph ‘f’, 7.2.1; p 11); and
- “No more than seven boats may be
launched with the assistance of ORVs or
any other vehicle from Noordstrand
daily” (paragraph ‘g’, 7.2.1; the
understanding being that ‘launching’
refers to the use of ORVs to tow boats to
or from the water’s edge, but does not
refer to boats are that launched without
the assistance of ORVs or any other
vehicle).
(e) The only point where Noordkloof and the
launching site can be accessed is a locked
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 76
(f) It must be indicated how launching was
going to be controlled as there was no
‘control gate’.
(g) Any coastal development should take
into account impacts of coastal processes on
activity, and cumulative effects of impact.
(h) Ownership of launch site must be
clarified, i.e. is it a leased area or private
property?
gate from Mullerlaan, to which only
members of the boat club have keys (see p
18, Ch 3 of the draft EA re access). The draft
EMP addresses the delineation of the access
route through Noordkloof at section 7.2.1
(‘Impact avoidance and mitigation with
respect to the Noordstrand-Noordkloof
sediment corridor and embedded Strandveld
valley bottom wetland, i.e. Critical
Biodiversity Area’).
(f) There is a gate by means of which access
to the launching site is effectively controlled
(see above).
(g) The effects of coastal processes and
potential cumulative impacts are
comprehsensively dealt with in the draft EA
and EMP (cf. Ch 7, ‘The ‘Receiving
Environment’ , and particularly pp 51-57 for
the ecological implications of limited driving
in sandy beach ecosystems) – note
CapeNature’s comment that ecological
aspects had been adequately dealt with).
(h) The access route to the launch site, i.e.
the route through Noordkloof, is privately
owned by Vleesbaai Aandeblok Bpk (cf. p 17
of the draft EA), whereas the beach below
the HWM is state-owned public property
(which is dealt with in Ch 5, ‘Regulatory
requirements’ and Ch 6, which inter alia
addresses the question of coastal public
property). The inland aspect of the launch is
therefore privately owned, and the areas
located below the HWM is coastal public
property controlled by the state.
VLEESBAAI AANDELEBLOK BPK (Dr CM Pauw)
Comment Response
15 March 2010 Vleesbaai Aandeleblok Bpk
(VAB) has no objection to the application,
which confirms a long-standing arrangement
The draft EMP for the Vleesbaai-Noord boat
launching site incorporates all relevant
aspects of the ‘VAB Bootklubreëls’ that
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 77
and agreement between VAB and the
Vleesbaai Bootklub regarding access (to the
launching site) over VAB’s property. As far as
VAB is concerned, (the boat club) can
continue to use the access route provided
that existing arrangements and agreed rules
remain applicable.
address the environmental aspects of boat
launching from the beach in question. No
changes are proposed to existing
arrangements and agreements between VAB
and the Vleesbaai Bootklub.
MR JOHAN LAMBRECHTS, resident of Driehoek, Vleesbaai
Comment Response
Mr Lambrechts engaged directly with the
EAP undertaking this environmental process
on four occasions, viz: 17 February 2010; 18
February 2010; 19 February 2010; and 2
March 2010.
In his e-mail of 17 February 2010, Mr
Lambrechts stated that his remarks to
Messrs Danie Gildenhuys and Koos du Preez
(Vleesbaai residents) in an earlier e-mail on
17 Feburay 2010 to the latter gentlemen
constituted his comment on the boat club
application. Mr Lambrechts stated in the
latter correspondence that Vleesbaai
Aandeblok was “very autocratic” in its views
with respect to public parking and ablution
facilities at Tarka beach, i.e. Noordstrand. He
also referred to a discrepancy between
“recommending approval of one application
at the primary bathing beach” while
“simultaneously ignoring and setting aside
long-standing requests, over many years, for
public public and public ablution facilities
(for the same beach)”. In another e-mail,
sent to nine recipients (but not the EAP) on
16 February 2010, Mr Lambrechts queried
why the boat club’s application could not be
linked to the provision of public parking and
ablution facilities at Tarka (Noordstrand)
beach. This would mean that a fundamental
need (“’n kardinale behoefte”) of the
broader Vleesbaai community would be met,
and not just the objectives of the boat club.
Mr Lambrechts’s e-mail of 17 February 2010
Correspondence was exchanged with Mr
Lambrechts three times: twice on 18
February 2010, and once on 19 February
2010.
An e-mail was sent to Mr Lambrechts on 18
February 2010 in reponse to his e-mail to
the EAP the previous day. In the responding
e-mail of 18 February, Mr Lambrechts was
requested to clearly distinguish his
comments from that of other persons. It was
also emphasised that the application by the
Vleesbaai Bootklub related exclusively to the
licensing of the Noordstrand boat launching
site in terms of the ORV regulations, and that
there was absolutely no intention on the
part of the boat club to apply for any other
activity. It was explained to Mr Lambrechts
that it was up to the appropriate body to
apply for environmental authorisation for
public facilities such as showers and toilets,
and parking, in the coastal zone, were this to
be contemplated. There were no factual
grounds, and specifically environmental
ones, for arguing that the boat club’s
activities warranted any additional facilties.
It was put to Mr Lambrechts that issues
pertaining to public facilities and parking at
Tarka (Noordstrand) should be addressed at
a planning level, and once clarity had been
obtained on these questions, an application
in terms of the NEMA EIA regulations could
be considered.
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 78
to the EAP included at least two others from
other individuals in its attached ‘string’.
Neither of the latter (both sent on 17
February 2010) had copied their comments
to the EAP.
On 18 February 2010, Mr Lambrechts copied
an e-mail to the EAP which was addressed to
altogether 14 recipients. Issues were raised
relating to previous correspondence
between Mr Lambrechts and others with
respect to Vleesbaai Dienste and its alleged
treatment of the public ablution and parking
matter. Mr Lambrechts also repeated the
assertion that the activities of the boat club,
under the aegis of VAB as the owners of the
“much discussed” private land, could not
claim precedence over the lack of public
parking and ablution facilities at Tarka
(Noordstrand) beach. He queried whether
towing vehicles would be parked on the
beach once boats had been launched, or if
they would have to be moved back on to the
streets owned by VAB. These issues, and that
of capping the number of vehicles that were
allowed to park at Tarka (Noordstrand)
beach, should be addressed in tandem with
the boat club’s application.
On 19 February 2010, Mr Lambrechts
thanked the EAP for his feedback, and said
he would make a comprehensive submission
to the EA process. He repeated his claims
that VAB was set on preventing public
ablution and parking facilities being
developed at Tarka (Noordstrand) beach.
Mr Lambrechts submitted a letter reflecting
his comment on the application on 2 March
2010. In the light of previous correspond-
ence with Mr Lambrechts, requesting that he
formalise his comment in order to avoid
An e-mail was sent to Mr Lambrechts on 18
February 2010, confirming that these
comments would be recorded in the final
environmental assessment.
An e-mail was sent to Mr Lambrechts on 19
February 2010, confirming the latter’s
registration as an interested and affected
party, and that comment was awaited from
him.
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 79
confusion and misinterpretation, the letter
of 2 March 2010 is understood to constitute
Mr Lambrechts’s formal, consolidated
comment on the application, substituting his
earlier comment, which is viewed as a
subsidiary preface to the formal submisison
recorded here.
Mr Lambrechts raised the following issues:
(a) All previous approvals or rights
pertaining to the Tarka (Noordstrand) boat
launching site had lapsed and the
application is therefore a new one.
(b) Reference was made to the boat
launching site but there was no mention
that this was also the main bathing beach.
(a) This is the first time that the
Vleesbaai Bootklub has applied for
authorisation of the Noordstrand launching
site in terms of the ORV regulations and s
24(4) of the National Environmental
Management Act 107 of 1998 as amended.
However, as acknowledged by the Dept of
Environmental Affairs and Development
Planning (cf. letter dated 23 Nov 2009,
Appendix 4 of the draft environmental
assessment), the Noordstrand boat
launching site has been in operation for
decades. The boat club’s rights with respect
to use of VAB’s propert to obtain access to
the launching site remain unchanged.
(b) Noordstrand’s use a bathing beach is
extensively described in section 7.6.1 of the
draft environmental assessment
(‘Recreational activities and outdoor
pursuits’). The draft environmental
assessment also assessed the potential
impacts of boat launching on bathers and
other users of the Vleesbaai boat launching
site (cf. section 8.8 of the draft
environmental assessment, ‘Vulnerability of
bathers and other users of the Vleesbaai
boat launchng site’). The ’Overview of the
Activity and the Local Context’ (Ch 3 of the
final environmental assessment) has been
amended to explicitly reflect that the
Noordstrand launching site is also an
important bathing amenity.
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 80
(c) There was no reference to the
number of existing or proposed members
of the boat club, which does not exist
legally.
(d) Mention has been made of 25
members of the boat club who have
permits, whereas their have reputedly been
35 ‘applications’, and impacts on the main
bathing beach could therefore not be
brushed aside on the basis of a limited
number of launchings.
(e) There is no provision for local
parking of ORVs or trailers, and numerous
requests for parking and public toilet
facilities have been swept from the table by
VAB.
(c) The number of members of the
Vleesbaai Bootklub is restricted to 30
members (cf. paragraph 3 of the ‘VAB
Bootklubreëls’, Appendix 1 of the draft
environmental assessment). Ch 3 of the
final environmental assesment has been
amended to dispel any ambiguity on this
question. The Vleesbaai Bootklub operates
as a financially independent entity under
the aegis of VAB.
(d) There are about three to four
launchings a day during peak season (cf p
18 of the draft environmental assessment).
As noted above, the boat club’s rules
require that it limits its number of
members to 30.
(e) These are separate issues. ORVs and
trailers are either removed from the beach
after launchings or parked against the base
of the foredunes flanking the northern
aspect of Noordstrand (cf. p 18 of the draft
environmental assessment). Limited use
(i.e. a maximum of five vehicles at a time)
of the back beach for boating-related
parking is deemed to be environmentally
justifiable: driving-related impacts on dune
ecosystems and coastal processes were
found to be of very low, short-term,
negative significance (cf. section 8.3, pp 51-
55, and 56 and 57 of the draft
environmental assessment). Questions
relating to the provision of public parking
and ablution facilities at Noordstrand need
to be addressed through an appropriate
planning process (cf. EAP’s response to Mr
Lambrechts on 18 February 2010). It would
be inapproporiate to harness these issues
to the boat club’s application which is
strictly limited in scope and intention (and
by regulation) to the licensing provisions of
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 81
(f) Tarka (Noordstrand) is the only
beach at Vleesbaai that can be used by
bathers, whose rights have priority over
those of the boat club.
(g) The statement that the application is
being made with the approval of Vleesbaai
Dienste and VAB is curious as ownership of
the coastal zone vests with the Republic of
South Africa.
(h) Where are vehicles to be parked
after boats have been launched – in streets
owned by VAB or in public parking areas
elsewhere in Vleesbaai, excluding VAB
which does not have such parking?
the ORV regulations.
(f) There is no evidence to suggest, on
the basis of this environmental assessment
process, that the use of Noordstrand as a
launching site for boats either claims any
form of precedence over the rights of any
other users of the coastal zone, or has any
but the slightest impact on public
enjoyment of the beach (cf. section 8.8, pp
59-61 of the draft environmental
assessment, ‘ Vulnerability of bathers and
other users of the Vleesbaai boat launching
site’). Also see response at 3(c) above.
(g) It is not clear what this comment
refers to, and where such an alleged
“statement” is recorded in the draft
environmental assessment, which deals
comprehensively with the question of land
ownership and land-use regulation in the
coastal zone (cf. Ch 5 of the draft
environmental assessment, ‘Regulatory
requirements relating to the Vleesbaai
(Noordstrand) boat launching site’, and Ch
6, which deals with legislation and policy
relating to planning and development in
the coastal zone).
(h) As noted above at (b), vehicles (that,
per definition, only have access to the
beach by virtue of the owner’s membership
of the boat club) are either temporarily
parked on the back beach between
launching and retrieving boats, or removed
from the beach altogether. Vehicles parked
above the high-water mark would be on
private property and, provided their
impacts are controlled in terms of the
measures proposed by this environmental
assessment and the draft environmental
management plan, this has been found to
be an environmentally acceptable practice,
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 82
(i) If it’s the latter case, the rights of
the public are being further constrained
due to the absence of parking at the main
beach and access control by VAB by means
of booms.
(j) The application by the Vleesbaai
Boat Club must be set aside by the Dept of
and one that is condoned by the owners of
the property in question, VAB. Parking or
the lack of it has not been raised as an issue
by any other users of the launching site,
and neither has parking in the back beach
area been identified as an unacceptable
practice by any authorities or social users of
the Noordstrand beach. Expecting vehicles
to leave the beach after every launching
would effectively double the suite of
impacts, and their effect on the receiving
environment, that have been the subject of
this environmental assesssment and its
findings. For these reasons alone, an
increase in the amount of vehicular traffic
above currently, environmentally-tolerable
levels, is both unnecessary and undesirable.
(i) The finding of the draft
environmental assessment is that the
launching of boats from Noordstrand, via
land owned by VAB, has a negligible impact
on the rights of other, non-boating, users of
the coastal zone at Vleesbaai. The issue of
providing public parking and ablution
facilities on privately-owned land, i.e. the
property owned by VAB, or elsewhere, is
emphatically not the subject of this
application, is not understood to be such by
the competent authority, and needs to be
addressed through an appropriate planning
process. Any such planning would have to
be informed by precisely the same coastal
planning principles and ecological
considerations raised in this environmental
assessment with respect to development in
the littoral active zone and the
Noordstrand-Noordkloof sediment corridor
and embedded Strandveld valley bottom
wetland (a CBA).
(j) This environmental assessment has
focused exclusively on potential impacts
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 83
Environmental Affairs and Development
Planning, and all launching must instead
take place at Gouritsmond, if VAB does not
give positive consideration to the provision
of public parking at Tarka (Noordstrand).
and issues relating to the application by the
Vleesbaai Bootklub for the Noordstrand
launching site to be licensed in terms of the
ORV regulations – a state of affairs that has
been confirmed, in writing, by the Western
Cape Department of Environmental Affairs
and Development Planning. If public
parking, or the lack of it, is viewed as an
issue affecting public enjoyment of the
coastal zone, this needs to be addressed on
the basis of a proper and environmentally
justifiable planning process, initiated by
the owners of the land in question,
Vleesbaai Aandeblok Beperk, in
consultation with relevant stakeholders.
That is not the responsibility of the
Vleesbaai Bootklub. It would be
inappropriate and capricious for a decision
subject to a clearly defined regulatory
process to be held ransom to another
process that is not being contemplated, has
not been required by any authority, has not
been agreed to by the affected landowner,
and the need for which has not been
conclusively established. The chapter
dealing with the receiving environment
(Ch 7 of the environmental assessment)
has, however, for the sake of
completeness, been amended to reflect
the issues of public parking and ablution
facilities at Noordstrand – even though
these matters have no substantial or
procedural bearing on this environmental
assessment process, or the decision that it
must inform.
THE FRANSMANSHOEK CONSERVANCY (Roland Scholtz, Senior Conservation Ranger)
Comment Response
5 March 2010 Only members of the
Vleesbaai Ski-Boat Club must be allowed to
launch at the Vleesbaai Slipway. Is there
sufficient parking for slipway users during
season time (December-January); where will
they leave their vehicles while at sea?
Only members of the Vleesbaai Bootklub
have permission to drive across VAB’s land
to the launching site, which means that the
launching site can only be used by members
of the boat club. The launching site is an
open, sandy beach; there is no slipway. The
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 84
issue of parking has been dealt with at
length above. In short, a limited number of
vehicles (no more than five) could be parked
on the back beach at any time; the number
is probably less in practice. Alternatively,
vehicles are removed from the beach – most
likely when a boat is going to used over an
extended period. This usually applies to
kayaks, yachts and ‘rubber ducks’ as ski-
boats are usually not left on the beach when
not in use.
MR CHRIS RABIE, Vleesbaai
Comment Response
5 March 2010 It is crucial for sea rescue
purposes to have a boat launching site at
Vleesbaai. I am aware of 12 incidents in the
past 30 years in which local boats carried our
rescues. Although the NSRI has a station at
Mossel Bay, this would be too far for a
rescue boat to arrive on time at Vleesbaai.
Vehicles and boats have never caused
damage to the beach at Vleesbaai. The only
damage has been caused by rain and run-off
from the land. Vleesbaai’s residents support
the boat club’s application for permission to
launch boats at Noordstrand.
The contribution of locally launched vessels
to sea rescue is noted and has been added
to section 7.6.1 of the report. The stated
desirability of retaining a boat launching site
at Noordstrand is therefore noted. The
interaction of ORVs with the Noordstrand-
Noordkloof environment is extensively dealt
with in the draft environmental assessment,
which to a large extent concurs – but not
entirely – with the statement that the main
causes of disturbance to this ecosystem are
natural. Support for the application is also
noted.
9.8 Key issues raised by interested and affected parties
There are several issues raised by interested and affected parties that either related to
requests for factual clarity (e.g. daily vehicle use of the launching site) or hinted at potential
points of conflict that, even though of tangential relevance to this application, could prove
to be problematic if not dealt with constructively and with the appropriate degree of
sensitivity.
These key are as follows (bracketed references denote where an issue was dealt with in the
comments and responses table):
− Requests for public parking and ablution facilities at Noordstrand, Vleesbaai, and,
linked to this, a demand that the boat club’s licensing application be refused if
Vleesbaai Aandeleblok Bpk did not agree to provide public parking at Noordstrand
(see 3(b), 5(e), 5(h), 5(i), 5(j), and 6);
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 85
− Limiting the number of boats that could be launched daily (see 3(d) and 5(d));
− Limiting the number of vehicles that could be parked at the launch site daily (see
3(d)); and
− Potential friction between boat launching and other activities at Noordstrand, such
as bathing (see 3(c), 5(b) and 5(f)).
These issues are dealt with comprehensively in the ‘Comments and responses’ table.
The provision of public parking and ablution facilities at Noordstrand for bathers and other
user residing beyond the boundaries of the VAB property appeared to be the most
contentious issue. The interested and affected party who raised this said the application
should be refused if Vleesbaai Aandeleblok Bpk, whose land borders on Noordstrand and
provides the only vehicular access route to the launching site, did not agree to provide
public parking at Noordstrand (see comments by Mr Johan Lambrechts, 5(a)-(j)).
Owing to the seriousness of this matter, the response thereto in the comments table
(recorded at 5(j)) is repeated in full here:
“This environmental assessment has focused exclusively on potential impacts and issues
relating to the application by the Vleesbaai Bootklub for the Noordstrand launching site to
be licensed in terms of the ORV regulations – a state of affairs that has been confirmed, in
writing, by the Western Cape Department of Environmental Affairs and Development
Planning. If public parking, or the lack of it, is viewed as an issue affecting public enjoyment
of the coastal zone, this needs to be addressed on the basis of a proper and environmentally
justifiable planning process, initiated by the owners of the land in question, Vleesbaai
Aandeblok Beperk, in consultation with relevant stakeholders. That is not the responsibility
of the Vleesbaai Bootklub. It would be inappropriate and capricious for a decision subject to
a clearly defined regulatory process to be held ransom to another process that is not being
contemplated, has not been required by any authority, has not been agreed to by the
affected landowner, and the need for which has not been conclusively established. The
chapter dealing with the receiving environment (Ch 7 of the environmental assessment) has,
however, for the sake of completeness, been amended to reflect the issues of public parking
and ablution facilities at Noordstrand – even though these matters have no substantial or
procedural bearing on this environmental assessment process, or the decision that it must
inform…”
9.9 Copies of comment received from interested and affected parties
Only written comment was received. A full record of this correspondence, i.e. comments
received on or after 5 February 2010 when the public participation process formally
commenced, is contained in Appendix 8.
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 86
10. CONCLUSIONS AND RECOMMENDATIONS
This section summarises the conclusions of the draft environmental assessment, and offers
recommendations with respect to the implementation and management of the preferred
option, were it to be approved.
10.1 Conclusions: The preferred option
From the foregoing it is concluded that Alternative 1 (i.e. retention of Noordstrand as the
launching site at Vleesbaai) represents the best practicable environmental option because:
− Its impacts can be effectively mitigated and have a limited environmental cost
that is well within the limits of acceptable change for the affected biophysical
and social contexts; and
− It represents the most feasible and reasonable alternative with respect to
meeting the general purpose, requirements and needs of the activities conducted
by the Vleesbaai Bootklub since the early 1970s.
10.2 Recommendations
It is therefore recommended that:
− The Noordstrand beach and Noordkloof access route be retained as a site for
launching boats at Vleesbaai; and
− All recommendations and mitigation measures included in the environmental
assessment be reflected in the Record of Decision; and
− Implementation of the appended environmental management programme be
recorded as a condition of authorisation.
10.3 Draft EMP for the Noordstrand launching site
The treatment of impact management and monitoring is approached from the point of
view that (a) it is difficult to completely exclude human activities from sensitive coastal
areas, but (b) that human interactions with coastal environments can be managed so as to
ensure the long-term persistence and integrity of these dynamic and potentially
threatened systems while meeting people’s needs (CMPP, 1999; Defeo et al., 2008). It is
also accepted that areas of relatively natural, unaffected beach – such as characterise
much of the Vlees Bay littoral active zone over its 32 km sweep – can be interspersed with
areas where recreational activities can be permitted, including launching of boats.
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 87
The DEA&DP Guideline for Environmental Management Plans (Lochner, 2005) guides the
preparation and implementation of effective EMPs. Chapter 3 of the EMP guideline deals
with the preparation and implementation of the EMP.
The following elements should be addressed in the preparation of an EMP:
− An overview of the proposed activity and the local context;
− A summary of impacts associated with the proposed activity;
− The project proponent’s environmental management policies and commitments;
− Institutional arrangements: Roles and responsibilities;
− Legal requirements;
− Implementation programme; and
− Cost estimate and financial resources.
Implementation of an EMP should, in turn, provide for:
− Training and environmental awareness;
− Documentation and record-keeping;
− Reporting procedures;
− Stakeholder engagement;
− Auditing;
− Responding to non-compliance;
− Transfer of EMP requirements to other implementers; and
− Management review and revision of the EMP.
There is no standard format for EMPs, and the format and level of detail for an EMP needs
to fit the circumstances for which it is to be developed (Lochner, 2005, p. 12). In this
instance, the EMP is approached with the understanding that the environmental effects of
the activity in question are well-understood, can be effectively mitigated, and therefore hold
little long-term environmental risk.
The DEA&DP has identified issues that must be addressed in the EMP for the Vleesbaai boat-
launching site (cf. letter dated 12 October 2009, Appendix 4). Not all of these apply to
circumstances at Vleesbaai, however. The issue thus identified are:
− The maximum number of vessels that the site is able to accommodate (limited to the
parking facilities available for vehicles);
− Measures to mitigation erosion of the slipway and maintenance of facilities;
− Measures to be implemented should and fuel leakages occur;
− Emergency measures to be implemented;
− Security measures to be implemented;
− Issues relating to poaching-related activities;
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 88
− Measures taken to ensure compliance by vehicle users with general fishing permit
conditions and the provision of the Marine Living Resources Act 18 of 1998;
− Property and reliable monitoring of impacts on the environment;
− Measures to minimise impacts associated with vehicle use in the boat launching site,
including measures to control vehicle access to the boat launching site;
− Measures to be implemented during the ‘peak’ holiday season; and
− Possible conflict between user groups.
A revised draft EMP is included in Appendix 5.
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 89
11. REFERENCES
CapeNature (2008) CapeNature’s requirements and recommendations with respect to
applications for environmental, mining, agriculture, water, and planning-related
authorisations. CapeNature: Scientific Services, Jonkershoek.
Clark B and de Villiers C (2005) Sandy beaches and dune systems, in De Villiers et al. Fynbos
Forum Ecosystem Guidelines for Environmental Assessment in the Western Cape.
Fynbos Forum and Botanical Society of South Africa, Kirstenbosch.
Coastal Management Policy Programme (CMPP) (1999) Draft White Paper for Sustainable
Coastal Development in South Africa. Department of Environmental Affairs and
Tourism, Pretoria.
Council for the Environment (1991) A policy for coastal zone management in the Republic of
South Africa: Part 2 – Guidelines for Coastal Land-use. Council for the Environment,
Pretoria.
Day L and Job N (2005) Freshwater Ecosystems: Wetlands, in De Villiers et al. Fynbos Forum
Ecosystem Guidelines for Environmental Assessment in the Western Cape. Fynbos
Forum and Botanical Society of South Africa, Kirstenbosch.
De Villiers CC, Brownlie S, Clark B, Day EG, Driver A, Euston-Brown DIW, Helme NA, Holmes
PM, Job N, Rebelo AB (2005) Fynbos Forum Ecosystem Guidelines for Environmental
Assessment in the Western Cape. Fynbos Forum and Botanical Society of South Africa,
Kirstenbosch.
Defeo O, McLachlan A, Schoeman DS, Schlacher TA, Dugan J, Jones A, Lastra M and Scapini F
(2009) Threats to sandy beach ecosystems: A review. Estuarine, Coastal and Shelf
Science 81, 1-12.
Department of Environmental Affairs and Development Planning (DEA&DP) (2007) Guideline
on alternatives, in NEMA environmental impact assessment regulations guideline and
information document series. DEADP, Cape Town.
Department of Environmental Affairs and Development Planning (DEA&DP) (2009a) Western
Cape PSDF: Rural Land-use Planning and Management Guidelines. DEA&DP, Cape
Town.
Department of Environmental Affairs and Development Planning (DEA&DP) (2009b)
Guideline on public participation: NEMA EIA Regulations Guideline and Information
Document Series. DEA&DP, Cape Town.
Fuggle RF and Rabie MA (eds) (1996) Environmental Management in South Africa. Juta & Co,
Kenwyn.
Helme N (2005) Strandveld, Dune Thicket and Dune Fynbos, in De Villiers et al. Fynbos Forum
Ecosystem Guidelines for Environmental Assessment in the Western Cape. Fynbos
Forum and Botanical Society of South Africa, Kirstenbosch.
Job N, Snaddon K, Day L, Nel J and Smith-Adao L (2008) C.A.P.E. Fine-scale Planning Project:
Aquatic ecosystems of the Riversdale coastal plain planning domain. The Freshwater
Consulting Group, Cape Town, and CSIR, Stellenbosch.
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 90
Lochner P (2005) Guideline for Environmental Management Plans. CSIR Report No ENV-S-C-
2005-053 H. Republic of South Africa, Provincial Government of the Western Cape,
Department of Environmental Affairs & Development Planning, Cape Town.
Lombard AT, Strauss T, Harris J, Sink K, Attwood C and Hutchings L (2004) South African
National Spatial Biodiversity Assessment 2004: Technical Report. Volume 4: Marine
Component, South African National Biodiversity Institute, Pretoria.
Lubke R (1998) Marine ecology, in Lubke and De Moor (eds) Field Guide to the Eastern and
Southern Cape Coasts. University of Cape Town Press, Rondebosch
Lubke R and De Moor I (1998) Field Guide to the Eastern and Southern Cape Coasts.
University of Cape Town Press, Rondebosch.
Lubke RA and McLachlan A (1998) Sandy beach ecology, in Lubke and De Moor (eds) Field
Guide to the Eastern and Southern Cape Coasts. University of Cape Town Press,
Rondebosch.
Malan JA, Viljoen JHA, Siegfried HP and Wickens H de V (1994) Die geologie van die gebied
Riversdale: Toeligting tot Riversdale Blad 3420, Skaal 1:250 000. Raad vir
Geowetenskap, Geologiese Opname van Suid-Afrika. Government Printer, Pretoria.
Margules CR and Pressey RL (2000) Systematic conservation planning, Nature 405, 243-253.
Mucina L and Rutherford MC (eds) (2006) The vegetation of South Africa, Lesotho and
Swaziland. Strelitzia 19, South African National Biodiversity Institute, Pretoria.
Mucina L, Adams JB, Knevel IC, Rutherford MC, Powrie LW, Bolton JJ, van der Merwe JH,
Anderson RJ, Bornman T, le Roux A and Janssen JAM (2006) Coastal vegetation of
South Africa, in Mucina and Rutherford (eds) Vegetation of South Africa, Lesotho and
Swaziland. Strelitzia 19, South African National Biodiversity Institute, Pretoria.
Pearsall J (ed) (1998) The New Oxford Dictionary of English. Oxford University Press, Oxford.
Pence GQK (2008) C.A.P.E. Fine-Scale Systematic Conservation Planning Assessment:
Technical Report. Produced for CapeNature as part of the GEF-funded C.A.P.E. Fine-
Scale Biodiversity Planning Project. Cape Town, South Africa.
Pierce, SM (2003) The STEP Mapbook, part of the STEP Handbook: Integrating the natural
environment into land use decisions at the municipal level: towards sustainable
development. Terrestrial Ecology Research Unit Report No. 47. University of Port
Elizabeth, South Africa
Preston GR, Robins N and Fuggle RF (1996) Integrated Environmental Management, in
Fuggle and Rabie (eds) Environmental Management in South Africa. Juta & Co,
Kenwyn.
Ralston S, de Villiers C, Manuel J, te Roller K and Pence G (2009) Where are we going? Fine
Scale Systematic Conservation Plans and their Contribution to Environmental
Assessment. In IAIAsa 2009 National Conference Proceedings, 23-26 August 2009,
Wilderness.
Rebelo AG, Boucher C, Helme N, Mucina L and Rutherford MC (2006) Fynbos biome, in
Mucina and Rutherford (eds) Vegetation of South Africa, Lesotho and Swaziland.
Strelitzia 19, South African National Biodiversity Institute, Pretoria.
Rust IC (1998) Geology and geomorphology, in Lubke and De Moor (Eds) Field Guide to
the Eastern and Southern Cape Coasts. University of Cape Town Press, Rondebosch.
Final Environmental Assessment: Vleesbaai Boat launching site – May 2010
Charl de Villiers Environmental Consulting cc 91
Stone AW, Weaver A v B and West WO (1998) Climate and Weather, in Lubke and De
Moor (Eds) Field Guide to the Eastern and Southern Cape Coasts. University of Cape
Town Press, Rondebosch.
Taylor, Van Rensburg and Van der Spuy (2005) Mossel Bay Municipality: Spatial
Development Framework – Final Draft Volume 1: Proposals. TV3, Stellenbosch.
Te Roller KS and Vromans DC (2009) The Biodiversity Sector Plan for the Hessequa and
Mossel Bay Municipalities. Supporting land-use planning and decision making in
Critical Biodiversity Areas and Ecological Support Areas for sustainable development.
Produced by CapeNature as part of the C.A.P.E. Fine-scale Biodiversity Planning
Project. Kirstenbosch
Tinley KL (1985) Coastal dunes of South Africa, South African national Scientific Programmes
Report No 109. CSIR, Pretoria.
Webley L and Hall S (1998) Archaeology and early history, in Lubke and De Moor (Eds) Field
Guide to the Eastern and Southern Cape Coasts. University of Cape Town Press,
Rondebosch.
ends
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APPENDIX 1
RULES OF THE VLEESBAAI BOOTKLUB
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APPENDIX 2
VLEESBAAI AANDELEBLOK BPK (VAB) – PERMISSION TO VLEESBAAI
BOOTKLUB TO USE AN ACCESS ROUTE VIA VAB’S PROPERTY
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APPENDIX 3
QUOTE FOR CONSTRUCTION OF SLIPWAY AT DIE HOEK
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APPENDIX 4
CORRESPONDENCE WITH THE DEPARTMENT OF ENVIRONMENTAL
AFFAIRS AND DEVELOPMENT PLANNING
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APPENDIX 5
DRAFT ENVIRONMENTAL MANAGEMENT PLAN FOR THE VLEESBAAI
BOAT LAUNCHING SITE, NOORDSTRAND, VLEES BAY
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APPENDIX 6
KONSEP-OMGEWINGSBESTUURSPLAN VIR DIE BOOTLANSERINGSPLEK
TE NOORDSTRAND, VLEESBAAI
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APPENDIX 7
ORV APPLICATION FORM AND CHECKLIST IN TERMS OF
REGULATION 7 AND 9 OF THE REGULATIONS: CONTROL OF
VEHICLES IN THE COASTAL ZONE (“ORV REGULATIONS”)
(GOVERNMENT NOTICE NO. 1399 OF 21 DECEMBER 2001), AS
AMENDED, IN TERMS OF THE NATIONAL ENVIRONMENTAL
MANAGEMENT ACT, 1998 (ACT NO. 107 OF 1998) (“NEMA”)
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APPENDIX 8
PUBLIC PARTICIPATION PROCESS I
5 FEBRUARY 2010 – 19 MARCH 2010
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APPENDIX 9
PUBLIC PARTICIPATION PROCESS II
14 APRIL 2010 – 7 MAY 2010