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Freshwater Consulting cc 5 April 2019 Adrian Sillito Sillito Environmental Consulting By email: [email protected] Dear Adrian WETLAND SCAN AND IMPACT ASSESSMENT FOR PROPOSED ASTRON SERVICE STATION DEVELOPMENT ON ERF 614232, MUIZENBERG (CITY OF CAPE TOWN) Background and terms of reference Sillito Environmental Consultants (SEC) is currently facilitating the environmental assessment process for the proposed development of a fuel service station by Astron on Erf 164232, Muizenberg, City of Cape Town. The site, which is currently vacant, is approximately 0.5 ha in extent. It is located alongside the M5 freeway (Prince George Drive), immediately to the north of St Georges Street, approximately half a kilometre north of "Sunrise Circle" at the intersection of the M5 and the R310 (Baden Powell Drive) (see Locality Map in Figure 1). Figure 1: Locality Map for proposed Astron site (Erf 614232, Muizenberg) Freshwater Consulting cc trading as “The Freshwater Consulting Group” (FCG) Members: JL Ewart-Smith, CD Snaddon Reg. No. 2007/064216/23 Unit F6, Prime Park Mocke Road Road Diep River 7880 Cell: 072 377 7006 E-mail: [email protected]

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Page 1: Freshwater Consulting cc · 2020-06-22 · Freshwater Consulting cc 5 April 2019 Adrian Sillito Sillito Environmental Consulting By email: adrian@environmentalconsultants.co.za Dear

Freshwater Consulting cc

5 April 2019

Adrian SillitoSillito Environmental ConsultingBy email: [email protected]

Dear Adrian

WETLAND SCAN AND IMPACT ASSESSMENT FOR PROPOSED ASTRON SERVICESTATION DEVELOPMENT ON ERF 614232, MUIZENBERG (CITY OF CAPE TOWN)

Background and terms of reference

Sillito Environmental Consultants (SEC) is currently facilitating the environmental assessmentprocess for the proposed development of a fuel service station by Astron on Erf 164232,Muizenberg, City of Cape Town. The site, which is currently vacant, is approximately 0.5 ha inextent. It is located alongside the M5 freeway (Prince George Drive), immediately to the north of StGeorges Street, approximately half a kilometre north of "Sunrise Circle" at the intersection of theM5 and the R310 (Baden Powell Drive) (see Locality Map in Figure 1).

Figure 1: Locality Map for proposed Astron site (Erf 614232, Muizenberg)

Freshwater Consulting cc trading as “The Freshwater Consulting Group” (FCG)Members: JL Ewart-Smith, CD Snaddon

Reg. No. 2007/064216/23

Unit F6, Prime ParkMocke Road RoadDiep River 7880

Cell: 072 377 7006E-mail: [email protected]

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SEC appointed the Freshwater Consulting cc to provide freshwater ecological input into theenvironmental assessment, particularly in relation to wetlands. The terms of reference for thespecialist input requested from the Freshwater Consulting cc were as follows:• Conduct a site visit;• Scan the site and surrounding areas to determine whether any wetlands or other freshwater

ecosystems are present on or adjacent to the subject property;• Provide an assessment of the potential impacts of the proposed development on wetlands, if

any are identified to be present on or adjacent to the site; and • Recommend mitigation measures to minimise the potentially negative impacts on wetlands and

other freshwater ecosystems that could result from the proposed development.

Approach taken to the study

The approach taken to meeting the above-mentioned terms of reference was as follows: • Background information and existing documentation relating to the site and the proposed

development was reviewed.• Relevant existing maps, aerial photos and biodiversity conservation plans for the study area

were examined. These included the maps of the 2011 National Freshwater Ecosystem PriorityAreas (NFEPA) project1 and the most recent GIS layers available for the City of Cape Town'sWetlands Map and accompanying Biodiversity Network2.

• A desktop-based map was compiled of potential “watercourses” (i.e. rivers, wetlands, openwaterbodies) located on and adjacent to the proposed development site, using GIS.

• A site visit was undertaken on 20 February 2019 to verify whether any wetlands or other"watercourses" are present on or adjacent to the proposed development site. The presence ofwetlands was determined by following standard field-based procedures for the identification ofwetlands (after DWAF 2005)3, which are based on the observation of landscape setting,landform, vegetation and soil moisture characteristics (using a soil auger to check the soil forsigns of permanent or periodic saturation at selected points). The definition of “wetland”adopted for this investigation was that of the National Water Act (Act No. 36 of 1998), wherebya wetland is defined as “land which is transitional between terrestrial and aquatic systems,where the water table is usually at, or near the surface, or the land is periodically covered withshallow water and which land in normal circumstances supports, or would support, vegetationadapted to life in saturated soil.”

• A ground-truthed map of the “watercourses” confirmed to be present on and adjacent to theproposed development site was compiled by updating the preliminary desktop-based map,using GIS, based on the findings of the site visit.

• Potentially applicable legislation was reviewed to ascertain whether any regulatoryrequirements relating to “watercourses” are likely to be applicable.

• The Present Ecological State (PES) of wetlands identified to be present was determined usingthe WET-Health "Level 1" assessment method4, which involves an assessment of theecological state of the hydrology, geomorphology and vegetation of a wetland against theperceived natural reference state.

• The conservation importance of wetlands identified to be present was determined using a listof criteria developed by the Freshwater Consulting cc (see Table 1)5.

• The significance of potential impacts on wetlands that could result from the proposeddevelopment was evaluated, using the criteria outlined in DEA&DP’s Guideline for Biodiversity

1 Obtained from SANBI's Biodiversity GIS website - http://bgis.sanbi.org/2 Obtained from the City's Open Data Portal - https://web1.capetown.gov.za/web1/opendataportal/Default3 Department of Water Affairs and Forestry [DWAF] (2005). A Practical Field Procedure for Identification and Delineationof Wetlands and Riparian Areas. Department of Water Affairs and Forestry, Pretoria.4 Macfarlane D, Kotze D, Ellery W, Walters D, Koopman V, Goodman P and Goge C (2008). WET-Health: A techniquefor rapidly assessing wetland health. WRC Report No. TT 340/08. Water Research Commission, Pretoria.5 After: Ewart-Smith JL and Ratcliffe SG (2002). Assessment of the Potential Impacts of the Proposed N1 / N2 WinelandsToll Highway Project on Aquatic Ecosystems. Specialist EIA Report to Crowther Campbell & Associates, on behalf of theNational Roads Agency.

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Specialist Studies6 and a protocol developed by the Freshwater Consulting cc for rating thesignificance of impacts on freshwater ecosystems (see Appendix 1).

• Recommendations were formulated for minimising the potential impacts on wetlands and other"watercourses" that could result from the proposed development.

• The current letter-report was compiled to summarise our findings relating to wetlands.

Table 1: Criteria used to assign low, moderate or high conservation importance to potentially affected freshwaterecosystems (note that the highest category applicable to any freshwater ecosystem, based on any one criteria, is theone accorded the ecosystem as a whole) [modified from Ewart-Smith & Ractliffe (2002)]

Low importance:

• does not provide ecologically or functionally significant aquatic habitat because of extremely small size or relatively high degree of degradation; and/or

• of extremely limited importance as a corridor between systems that are themselves of low conservation importance.

Moderate importance:

• provides ecologically significant aquatic habitat (e.g. locally important aquatic ecosystem habitat types); and/or • fulfils some functional roles within the catchment; and/or • acts as a corridor for fauna and/or flora between other aquatic ecosystems or ecologically important habitat types; and/or • supports (or is likely to support) fauna or flora that are characteristic of the region and/or provides habitat to indigenous

flora and fauna; and/or • is a degraded but threatened habitat type; and/or • is degraded but has high potential for rehabilitation; and/or • has been identified as a Freshwater Ecosystem Priority Area (FEPA) in terms of the National Freshwater Ecosystem

Priority Areas (NFEPA) project or as an aquatic Critical Biodiversity Area (CBA) in terms of a regional biodiversity conservation plan, but is in relatively poor present ecological condition; and/or

• has been identified as an aquatic Critical Ecosystem Support Area (CESA) in terms of a regional biodiversity conservation plan; and/or

• functions as a buffer area between terrestrial systems and more ecologically important aquatic ecosystems; and/or • is upstream of aquatic ecosystems that are of high conservation importance.

High importance:

• supports a high diversity of indigenous plant / animal species; and/or • supports, or is likely to support, red data species; and/or; • supports relatively undisturbed aquatic communities; and/or• forms an integral part of the habitat mosaic within a landscape; and/or • is representative of a regionally threatened / restricted habitat type; and/or • has been identified as a FEPA in terms of the NFEPA project or as an aquatic CBA in terms of a regional biodiversity

conservation plan, and is in fair to good present ecological condition; and/or• has a high functional importance (e.g. nutrient filtration; flood attenuation) in the catchment; and/or • is of a significant size (and therefore provides significant aquatic habitat, albeit degraded or of low diversity).

Contextual setting of the site

The proposed site is situated in a mostly built-up urban residential part of the Cape Flats, within theSouthern Suburbs of the City of Cape Town, and presumably falls within the existing Urban Edge.The M5 freeway is located along the western edge of the site and a smaller tar road (St GeorgesStreet) runs along the southern edge of the site, with residential development on the other side ofboth these roads. Residential developments abut the site to the north and the east. As such, thesite is currently an isolated patch of vacant land surrounded by roads and residential housing.

The site is located in a generally flat, low-lying landscape forming part of the Cape Flats. As istypical of the natural morphology of the Cape Flats, some low-lying sand dunes and depressional

6 Brownlie S (2005). Guideline for Involving Biodiversity Specialists in EIA Processes: Edition 1. CSIR Report No. ENV-S-C 2005 053 C. Department of Environmental Affairs & Development Planning, Provincial Government of the WesternCape.

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areas ("dune slacks") occur on the site. The most prominent depression is situated near the middleof the site.

According to the relevant 1:250 000 scale geology map from the Council for Geoscience (3418Cape Town), the study area is dominated by calcareous dune sands of the Witzand Formation,with limestone and calcrete of the Langebaan Formation occurring in places. The most-recentnational vegetation map of South Africa7 indicates that the natural vegetation type on the site andin the surrounding areas is Cape Flats Dune Strandveld. This vegetation type is categorised asEndangered in the National List of Threatened Ecosystems published in terms of the NationalEnvironmental Management: Biodiversity Act (Act No. 10 of 2004)8.

Although there is a reasonably good coverage of naturally-occurring indigenous vegetation on thesite9 (e.g. see photo in Figure 2), a recent botanical assessment by the NCC EnvironmentalServices rated the overall indigenous plant density and diversity as quite low, which can be betterwitnessed in summer when many of the annual and exotic grasses have died back leaving largepatches of exposed sand and a more scattered vegetation façade10. Furthermore, no Red Datalisted plant species were encountered during the botanical survey, with the likelihood of anyoccurring that were not encountered rated to be slim, and invasive alien vegetation was found tobe present on the site (comprising of a sporadic scattering of Acacia cyclops, rooikrans, and non-listed annual exotic grass species such as Bromus diandrus and Avena fatua). The present-daycondition of the vegetation on the site has also been negatively affected by a plant "search-and-rescue" operation that was conducted by the Nature Conservation Corporation in 2009, as acompensatory mitigation measure for the anticipated construction of a fuel service station on thesite that had been approved at the time (this approval subsequently lapsed before thecommencement of construction activities, but the search-and-rescue operation had already beenundertaken). During the plant search-and-rescue operation, 5 bulbs of Albuca cooperi, 460 cormsof Chasmanthe aethiopica, 175 clumps of Scirpoides nodosus (Ficinia nodosa), and 121 tubers ofZantedeschia aethiopica were removed from the site11.

There are a number foot-paths cutting through the site, which have no vegetation and comprisebare sand. In addition, immediately adjacent to the surrounding residential developments, therehas been substantial infilling of the site along the northern and eastern edges (see photos inFigure 3). The outer edges of the site along the southern and, especially, western edges have, onthe other hand, been transformed through regular mowing, being driven on by vehicles, dumping,and presumably also by sporadic excavation activities associated with the laying of and/or repair ofunderground cables and pipes along these road edges (e.g. see photos in Figure 4). According tothe botanical assessment by NCC Environmental Services10, the vegetation associated with thecentral part of the site, although from a distance initially appearing to be fairly natural, has beenand is undergoing change in plant structure and species composition, and can be classed as"Modified to Transformed" in terms of its present ecological condition, owing primarily to thedominant structuring species still being present but with the species dominance having beensignificantly altered. The vegetation associated with the edges of the site was classed as"Replaced – Managed", on the other hand, because the dominant structuring species of the nativevegetation community have been removed from these areas and the regeneration of the nativevegetation community has been lost or suppressed by intensive land management.

7 Mucina & Rutherford (2006, with 2012 updates). The Vegetation of South Africa, Lesotho and Swaziland. Strelitzia 19.South African National Biodiversity Institute, Pretoria.8 Government Notice No. 1002 of 9 December 2011.9 Indigenous plant species observed on the site included the woody Euclea racemosa, Searsia glauca, S. laevigata var.incana, Lycium ferocissimum and asteraceous plants such as Senecio halimifolius, Osteospermum incanum and O.moniliferum, which dominate, with annual geophytes and smaller flowering species occurring in the pockets of openground between bush clumps. The geophytes Zantedeschia aethiopica and Chasmanthe aethiopica emerge seasonallyfrom the open spaces and bush clumps.10 Altern S (2019). Botanical Assessment. Astron Energy Muizenberg, ERF 164232. Prepared for Sillito EnvironmentalConsulting by NCC Environmental Services, February 2019.11 The Nature Conservation Corporation (2009). Final Report. Completion of Search & Rescue Operation: Erf 164232,Muizenberg. Report prepared for Sillito Environmental Consulting, November 2009.

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Figure 2: Photograph of some of the indigenous vegetation on a more intact portion of the site [taken on 20/02/2019]

Figure 3: Photographs of infilling along the northern (left) and eastern (right) edges of the site [taken on 20/02/2019]

Figure 4: Photographs of the transformed western (left) and southern (right) edges of the site alongside existing roads[taken on 20/02/2019]

The conclusion of the recent botanical assessment by NCC Environmental Services was that,overall, the current state of the vegetation on the site can be described as being "Poor", asecological functionality has been severely compromised or lost, in addition to alteration of thestructure and composition of the vegetation. The site does not form part of the City of Cape Town's

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Biodiversity Network, either as a terrestrial Critical Biodiversity Area (CBA) or Ecological SupportArea (ESA). As such, at least in terms of terrestrial vegetation, the site has not been identified tobe of any biodiversity conservation importance at a regional scale.

Identification of wetlands on and adjacent to the site

In terms of the desktop-based mapping that was completed for the study area, no wetlands weremapped on or nearby the site by the NFEPA project, although NFEPA erroneously identifies thesite as part of a broad area along the coast that was mapped as "Estuaries". The City of CapeTown's Wetlands Map, however, shows a wetland taking up a large portion of the site andextending close to 100 m northwards beyond the site boundary (see map in Figure 5). Thiswetland was classified on a desktop basis as a dune strandveld depression in terms of the type ofaquatic ecosystem12 and was categorised as an Aquatic Critical Ecological Support Area (CESA)through the wetland prioritisation process that was completed by the Freshwater Consulting cc in2009 for the City's Wetlands Map13.

Figure 5: Map of wetlands indicated to be present within 500 m of Erf 614232, Muizenberg, according to the City ofCape Town's desktop-based Wetlands Map (note that the presence of these wetlands has not been verified on theground)

It should be noted that the imagery in the background of the map in Figure 5 is out-dated and thatthe piece of land to the north of the site has already been developed, with that area now beingoccupied by a residential housing estate. When environmental assessment studies were beingconducted for the Scoping phase of the Environmental Authorisation process for the then-proposedhousing development, Dr Liz Day of the Freshwater Consulting cc identified relatively extensivewetland areas on the land to the north of Erf 614232, Muizenberg, as well as a few small patchesof wetland on Erf 614232.

12 After: Ollis DJ, Snaddon CD, Job NM and Mbona N (2013). Classification System for Wetlands and other AquaticEcosystems in South Africa. User Manual: Inland Systems. SANBI Biodiversity Series 22. South African NationalBiodiversity Institute, Pretoria.13 Snaddon K and Day L (2009). Prioritisation of City Wetlands. Report prepared by the Freshwater Consulting Group forthe Department of Environmental Resource Management, City of Cape Town.

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During the fieldwork undertaken by the Freshwater Consulting cc in February 2019 for the currentlyproposed fuel service station development, it was confirmed that there is a small depressionwetland on Erf 614232, but this wetland is a lot less extensive than the area indicated on the City'sWetlands Map. The total extent of the wetland is approximately 85 m2 (0.0085 ha), at most, and itis located near the centre of the site (see map in Figure 6).

Figure 6: Map of wetlands and other habitats confirmed to be present on Erf 614232, Muizenberg, during a site visit bythe Freshwater Consulting cc in February 2019 (note that the background imagery is out-dated and that the area to thenorth of the site now consists of a completed residential estate development)

The main wetland plant indicator species identified within the wetland area (see photo in Figure 7)were the sedge Ficinia nodosa (restricted to one or two isolated clumps) and the low-growing restioIschyrolepis eleocharis. Other plant species noted within the wetland included Stenotaphrumsecundatum (Buffalo grass), Passerina paleacea and Zantedeschia aethiopica (Arum lilies), whileSenecio halimifolius and the alien invasive Acacia cyclops (rooikrans) were observed around theouter edges of the depressional area. Generally, the coverage of vegetation within the wetland wasquite sparse and a very low diversity of species was observed. There were foot-paths traversingthe wetland, and there was evidence of trampling (even off the foot-paths) as well as somedumping and littering within the wetland.

At the time of the site visit by the Freshwater Consulting cc (in February 2019), the fine sandy soilswithin the depression wetland were very dry and it was difficult to capture soil samples using anauger. This is, however, to be expected for seasonally or intermittently saturated wetlands on theCape Flats, which typically have dessicated sandy soils during the dry summer months. It ispresumed that the main source of water for the wetland, besides direct rainfall and localised runoff,would be the rising water table associated with the underlying Cape Flats Aquifer during the wetseason (typically May to August in non-drought years).

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Figure 7: Photograph of the depression wetland on Erf 614232, Muizenberg [taken on 20/02/2019]

Legislative implications

In terms of the amended EIA Regulations of the National Environmental Management Act (Act No.107 of 1998) (NEMA), as published in 2017, the following activities in Listing Notice 1 areidentified, amongst others, as activities that may not commence without an environmentalauthorisation from the competent authority:

• Activity 12:

The development of ... (ii) infrastructure or structures with a physical footprint of 100 squaremetres or more; (a) within a watercourse;(b) in front of a development setback; or(c) if no development setback exists, within 32 metres of a watercourse, measured from theedge of a watercourse; -excluding-...(dd) where such development occurs within an urban area;...(ee) where such development occurs within existing roads, road reserves or railway linereserves; ...

• Activity 19:

The infilling or depositing of any material of more than 10 cubic metres into, or the dredging,excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock of more than 10cubic metres from a watercourse;but excluding where such infilling, depositing, dredging, excavation, removal or moving-(a) will occur behind a development setback;...

This implies that, if Erf 614232 is located within the Urban Edge (which it presumably is), thenEnvironmental Authorisation would only be required in terms of Activity 12 of Listing Notice 1 of theNEMA EIA Regulations if any infrastructure or structures with a physical footprint 100 squaremetres or more were to be constructed within the wetland identified on the site. EnvironmentalAuthorisation would also be required in terms of Activity 19 of Listing Notice 1 if more than 10 cubicmetres of material was to be placed into or removed from the wetland identified on the site.

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In terms of Sections 21 (c) and (i) of the National Water Act (Act No. 36 of 1998), activities thatmodify the bed, banks or characteristics of a watercourse, or which impede or divert the flow ofwater in a watercourse, normally require a Water Use Licence from the Department of Water &Sanitation (DWS). Section 39 of the NWA, however, offers relief from having to apply for a WaterUse Licence for Section 21(c) and (i) “water uses”, in the form of a General Authorisation (GA). Interms of the revised GA for Section 21 (c) and (i) water uses14, to avoid a full Water Use LicenseApplication, it must be demonstrated that proposed activities within the “regulated area of awatercourse” (including a 500 m radius from the delineated boundary of any wetland or pan) wouldbe of low risk to the resource quality of the watercourse through the completion of a “Risk Matrix”by a suitably qualified professional registered with SACNASP. The applicant must also verify thatadequate provision has been made for the management, rehabilitation and monitoring of theaffected watercourses, amongst other provisions. If Section 21(c) or (i) activities are to beundertaken, which fall within the ambit of the relevant GA, a Water Use Authorisation process stillneeds to be followed with the regional office of DWS or the relevant Catchment ManagementAgency and the water use must still be registered.

In the case of the proposed development, construction activities will definitely be taking placewithin 500 m of wetlands. As such, a Water Use Authorisation process would need to be initiated,through the Western Cape regional office of DWS, for Section 21(c) and (i) water use activities interms of the relevant Revised GA.

Present Ecological State (PES) and conservation importance of on-site wetland

A summary of the results of the WET-Health assessment that was completed by the FreshwaterConsulting cc to determine the PES of the wetland that was identified on the proposeddevelopment site is provided in Table 2, below.

Table 2: Summary of the results of the WET-Health PES assessment completed for the depression wetland on the site

The PES results show that the hydrology of the wetland is considered to be moderately modified(Ecological Category C) with a declining trajectory of change anticipated. This is mainly due toimpacts on the hydrology of the Cape Flats Aquifer from the broader catchment area, coupled withimpacts from the surrounding urban development (largely relating to catchment hardening) that arereducing inflows to the wetland and changing the flood patterns within the wetland. The modifiedhydrological functioning of the wetland, which is presumably causing the wetland to be saturatedfor shorter periods than it would have under natural conditions, is having a knock-on effect to the

14 Government Notice of 26 August 2016.

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Depression wetland

Extent (Ha) 0.0085 ha

Hydrology

PES Score (%) 65%

Ecological Category

Geomorphology

PES Score (%) 87%

Ecological Category

Vegetation

PES Score (%) 82%

Ecological Category

Overall PES

PES Score (%) 76%

Ecological Category

C ↓(Moderately modified)

B ↓(Largely natural with few

modifications)

B/C ↓↓(Largely natural to

moderately modified)

C ↓↓(Moderately modified)

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present-day condition of the geomorphology and vegetation of the wetland. The geomorphology ofthe wetland has been the least affected, considered to be in a largely natural state with fewmodifications (Ecological Category B), although it is on a slightly downward anticipated trajectory ofchange.

The WET-Health assessment concluded that the vegetation within the wetland is in a largelynatural to moderately modified present ecological condition (Ecological Category B/C), but thisrapid assessment does not adequately cater for the effect of subtle changes to the structure andcomposition of the vegetation community on overall vegetation condition (including that relating tothe previous "search-and-rescue" operation that removed a substantial number of plants from thewetland). The true condition of the vegetation within the wetland is probably more similar to that ofthe terrestrial vegetation on the site as a whole, which was rated to be "poor" and "modified totransformed" in the recent botanical assessment by NCC Environmental Services (as explainedabove). The WET-Health assessment did, however, conclude (in line with the botanicalassessment for the site as a whole) that the anticipated trajectory of change for the vegetationcondition is one of rapid ongoing degradation.

Taking all the three components of wetland condition that were considered into account, the WET-Health assessment indicated that the overall PES of the wetland on the site is moderately modified(Ecological Category C). It is the opinion of the Freshwater Consulting cc that this is probably agood reflection of the true situation on the ground.

In terms of the conservation importance of the wetland identified on the site, it was concluded(following the criteria in Table 1) that the wetland is likely to be of very low conservation value. Thisis because, despite the wetland representing a threatened habitat type (i.e. dune strandvelddepression wetland) and having been identified as part of a CESA by the City of Cape Town (whenit was previously mapped as part of a much larger wetland), it does not provide ecologically orfunctionally significant aquatic habitat because of extremely small size (being less than 0.01 ha intotal extent) and it is of zero importance as a corridor or link between other aquatic ecosystems ornatural areas (due to the isolated, disconnected nature of the site).

The state of affairs with the wetland on the site is considered to be similar to that concluded for thevegetation on the site in a previous botanical assessment by the Nature Conservation Corporationin 200715, which was echoed by NCC Environmental Services in their recent (February 2019)botanical assessment report: "Given its size it is not resilient to disturbance and is not viable as aconservation area. Without intensive management intervention it would constantly degrade as aresult of impacts associated with the urban environment".

Significance of anticipated loss of on-site wetland

The proposed development of a fuel service station on Erf 614232, Muizenberg, will inevitably leadto the loss of the wetland identified on the site, irrespective of the proposed layout plan (seealternative Site Development Plans considered to date in Appendix 2). This is because of thenature of the proposed development and the location of the wetland in the centre of the site.

Based on the extremely small size of the wetland, its currently degraded state and its isolation fromother aquatic ecosystems or natural areas, rendering it of very low conservation importance, theanticipated loss of this wetland was rated to be a negative impact of low significance (see ratings ofthe various aspects in Table 3, following the method explained in Appendix 1). No mitigation ofthis permanent impact is really possible and, because the significance of the impact is predicted tobe low, no offsetting of the impact is considered to be necessary.

15 Jangle R (2007). Botanical Opinion: Erf 164232, Muizenberg. Prepared for Sillito Environmental Consulting by theNature Conservation Corporation, December 2007.

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Table 3: Rating of impact significance for anticipated loss of on-site wetland

It is important to reiterate that the rating of the anticipated loss of wetland as a negative impact oflow significance is based on the current status quo of the wetland and the nature of the isolated site on which it occurs. Prior to the development of the surrounding areas, there would presumablyhave been extensive dune fields covered in Cape Flats Dune Strandveld vegetation in this area,with dune slack wetlands in between many of the dune ridges. The injudicious urban developmentof large parts of the Cape Flats, together with sand mining and agriculture, has resulted in the lossof extensive areas of dune strandveld depression wetlands, and is largely responsible for thehighly threatened state of this habitat type today. Bearing this in mind, it would be of someecological gain if one or two depression wetlands were to be created in the undeveloped portionsof the site (or adjacent to the site), and if these wetlands were to be vegetated with characteristicplant species that would naturally occur in and around the edges of dune strandveld depressionwetlands. This idea is expanded upon in the recommendations below.

Conclusions and recommendations

The overall conclusions of the site scan and wetland assessment completed by the FreshwaterConsulting cc were as follows:• A small depression wetland (<0.01 ha in total extent) was confirmed to be present near the

centre of the proposed development site (Erf 164232, Muizenberg).• The wetland was assessed to be moderately modified (Ecological Category C) in terms of its

overall Present Ecological State.• The wetland is considered to be of very low conservation importance, largely due to its small

size, its degraded ecological state, and the lack of connectivity to other aquatic ecosystems ornatural areas.

• The proposed development will more than likely result in the loss of the entire wetland,irrespective of the configuration of the layout plan, which triggers the need for EnvironmentalAuthorisation in terms of the NEMA EIA Regulations and Water Use Authorisation (for Section21(c) and (i) water uses) in terms of the NWA.

• The anticipated loss of the wetland as a result of the proposed development was rated to be anegative impact of low significance, thus not requiring a wetland offset.

• The anticipated loss of wetland cannot be mitigated, but it is nevertheless recommended thatdepression wetlands be created on portions of the site that are not going to be developed ascompensation for the loss of wetland (as explained further below), if possible.

• With the loss of the existing wetland on the site during the construction phase, there would beno operational-phase impacts on wetlands associated with the proposed development.

It is recommended that a wetland (or a few small wetlands) be created in some of the undevelopedportions of the site, to compensate for the wetland that would be lost on the site. This wetland (orthese wetlands) should be planted up with indigenous species typically associated with dunestrandveld depression wetlands, according to a Landscaping Plan that should be drawn up by a

11

Aspect Assessment (without mitigation)

Description of impact Loss of wetland

Nature of impact Negative

Extent Site-specific (Local)

Duration Permanent (Long-term)

Intensity/Magnitude Low

Probability Definite

Reversibility Irreversible

Significance LOW

Confidence High

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suitably qualified landscape architect with the input of a wetland ecologist. One of the areas thatcould be considered for this initiative is the disturbed strip of land along the southern boundary ofthe site (as shown on the right photo in Figure 4), adjacent to St Georges Street, where theaccess road/s to the service station is/are likely to be located. Most of this land falls outside of thecadastral boundary of the site (as can be seen on the map in Figure 6), but the relevantpermissions could be negotiated with the landowner (more than likely the City of Cape Town). It isalso possible to undertake such an exercise along the western boundary of the site, but this wouldprobably be more difficult to get the relevant permission for because the land forms part of theroadside servitude of a major freeway (the M5, Prince George Drive).

Besides acting as some form of compensation for the anticipated loss of wetland, therecommended creation of wetlands on or adjacent to the site would result in an aestheticallypleasing feature that could become an integral part of the proposed development.

I hope this letter-report provides the input you require from the Freshwater Consulting cc at thisstage. Please do not hesitate to contact me if you require any further input relating to wetlands andother watercourses.

Yours sincerely

Dean Justin Ollis Pr.Sci.Nat.

for the Freshwater Consulting cc

Appendix 1: Impact significance rating method

Appendix 2: Proposed site development plans

12

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Appendix 1:Assessment method for rating of impact significance

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CRITERIA USED FOR THE ASSESSMENT OF POTENTIAL IMPACTS

The following criteria are used to attribute impact significance ratings to different developmentoptions (see detailed explanation of each criterion on following page): Nature and status of impact; Extent; Duration; Intensity; Probability; Significance; and Degree of confidence.

In assigning significance ratings to potential impacts before and after mitigation, the approachpresented below is followed:1. The status of an impact is used to describe whether the impact will have a negative, positive

or zero effect on the surrounding environment. An impact may therefore be negative, positive(i.e. a benefit) or neutral.

2. The core criteria for determining significance ratings are “extent”, “duration” and “intensity”.The preliminary significance ratings for the combination of these three criteria are given.

3. The impact is described in terms of the probability of the impact occurring and the degree ofconfidence in the impact predictions, based on the availability of information and specialistknowledge.

4. Additional criteria considered, which could increase the significance rating if deemed justified(with motivation), are the following: Permanent/irreversible impacts (as distinct from long term, reversible impacts); Potentially substantial cumulative effects; and/or High level of risk or uncertainty, with potentially substantial negative consequences.

5. Additional criteria considered, which could decrease the significance rating if deemedjustified (with motivation), are the following: Improbable impact, where confidence level in prediction is high.

6. In assigning significance ratings to impacts after mitigation, the following aspects areconsidered: First, the probable changes in intensity, extent and duration of the impact after

mitigation, assuming effective implementation of mitigation measures, leading to a revised significance rating; and

Then, the moderation of the significance rating after taking into account the likelihood of the proposed mitigation measures being effectively implemented, taking into account:o Any potentially significant risks or uncertainties associated with the effectiveness of

mitigation measures;o The technical and financial ability of the proponent to implement the measure; and o The commitment of the proponent to implementing the measure, or guarantee over

time that the measures would be implemented.

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CRITERIA USED FOR THE ASSESSMENT OF IMPACTS[taken from DEA&DP’s Guideline for Involving Biodiversity Specialists in EIA Processes (Brownlie, 2005)]

Nature of the impact – A description of positive or negative effect of the project on the affected environment, or vice versa. This description should include who or what would be affected, and how.

Extent - the impact could: be site-specific; be limited to the site and its immediate surroundings (i.e. local); have an impact on the region (e.g. if communities rely on biodiversity); have an impact on a national scale (e.g. national biodiversity conservation targets); or have an impact across international borders (e.g. where catchments cross international border,

international conventions are concerned, or migratory species).

Duration – It is important to indicate whether or not the lifetime of the impact will be: short term (e.g. during the construction phase); medium term (e.g. during part or all of the operational phase); long term (e.g. beyond the operational phase, but not permanently); permanent (where the impact is for all intents and purposes irreversible. An irreversible negative

impact may also result in irreplaceable loss of natural capital or biodiversity, if it were to result in extinction or loss of a species or ecosystem); or

discontinuous or intermittent (where the impact may only occur during specific climatic conditions orduring a particular season of the year).

Intensity or magnitude – The size of the impact (if positive) or its severity (if negative): low, where biodiversity is negligibly affected or where the impact is so low that remedial action is

not required; medium, where biodiversity pattern, process and/or ecosystem services are altered, but not

severely affected, and the impact can be remedied successfully; and high, where pattern, process and/or ecosystem services would be substantially (i.e. to a very large

degree) affected. If a negative impact, could lead to irreplaceable loss of biodiversity and/or unacceptable consequences for human wellbeing.

Probability – Should describe the likelihood of the impact actually occurring indicated as: improbable, where the possibility of the impact is very low either because of design or historic

experience; probable, where there is a distinct possibility that the impact will occur; highly probable, where it is most likely that the impact will occur; or definite, where the impact will occur regardless of any prevention measures.

Significance – The significance of impacts can be determined through a synthesis of the assessment criteria (see protocol on following page). Significance can be described as: low, where it would have negligible effect on biodiversity, and on the decision; medium, where it would have a moderate effect on biodiversity, and should influence the decision; high, where it would have, or there would be a high risk of, a large effect on biodiversity. These

impacts should have a major influence on the decision; or very high, where it would have, or there would be a high risk of, an irreversible negative impact on

biodiversity and irreplaceable loss of natural capital or a major positive effect. Impacts of very high significance should be a central factor in decision-making.

Confidence – The level of confidence in predicting the impact can be described as: low, where there is little confidence in the prediction, due to inherent uncertainty about the likely

response of the receiving ecosystem, or inadequate information;

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Protocol for determining the SIGNIFICANCE of potential impacts (developed by Ractliffe and Ewart-Smith, Freshwater Consulting Group)

Rating Description (i.t.o. intensity, extent and duration)

VERY HIGH Impacts could be EITHER:of high intensity at a regional level and endure in the long term;

OR of high intensity at a national level in the medium term;OR of medium intensity at a national level in the long term.

HIGH Impacts could be EITHER:of high intensity at a regional level and endure in the medium term;

OR of high intensity at a national level in the short term;OR of medium intensity at a national level in the medium term;OR of low intensity at a national level in the long term;OR of high intensity at a local level in the long term;OR of medium intensity at a regional level in the long term.

MEDIUM Impacts could be EITHER:of high intensity at a local level and endure in the medium term;

OR of medium intensity at a regional level in the medium term;OR of high intensity at a regional level in the short term;OR of medium intensity at a national level in the short term;OR of medium intensity at a local level in the long term;OR of low intensity at a national level in the medium term;OR of low intensity at a regional level in the long term.

LOW Impacts could be EITHER: of low intensity at a regional level and endure in the medium term;

OR of low intensity at a national level in the short term;OR of high intensity at a local level and endure in the short term;OR of medium intensity at a regional level in the short term;OR of low intensity at a local level in the long term;OR of medium intensity at a local level and endure in the medium term.

VERY LOW Impacts could be EITHER: of low intensity at a local level and endure in the medium term;

OR of low intensity at a regional level and endure in the short term;OR of low to medium intensity at a local level and endure in the short term.

NOTAPPLICABLE

Impacts with: Zero intensity with any combination of extent and duration.

UNKNOWN In certain cases it may not be possible to determine the significance of an impact.

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Appendix 2:Proposed site development plans

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21

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CARWASH
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SEATTLE
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or EQUAL
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WASH UP PREP AREA.
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Fillers
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LINE OF ROOF OVERHANG
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ATTENDANTS
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TOILET
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DISABLED
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FEMALE &
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92
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ATM CUBICLE
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DRIP SINK
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48
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JUICE
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03
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02
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03
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WATER
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01
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02
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01
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ENERGY
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03
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02
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03
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JUICE
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03
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04
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MALE TOILET
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BRICKWORK (SHOWN HATCHED) TO
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CHANGE ROOM
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AND LOCKERS
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ROOF SHEETS
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04
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04
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04
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04
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04
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04
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9 DOOR CHILLER FRIDGES
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STORAGE
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04
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04
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Floor drain by plumber
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04
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50
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50
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Storage Cupboards
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51
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V-chiller_Exposer CP1850
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tap
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COMPRESSOR
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UNDER
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LINE OF ROOF OVERHANG
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POS
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CASH
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safe
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C.I.T.
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M.D.B.
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OFFICE
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P.O.S. unit
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COLD ROOM
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04
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M
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64
AutoCAD SHX Text
Toaster
AutoCAD SHX Text
SH01-003 S
AutoCAD SHX Text
Bain Marie
AutoCAD SHX Text
68
AutoCAD SHX Text
SH01-004 S
AutoCAD SHX Text
sandwich counter over
AutoCAD SHX Text
Underbar fridge with
AutoCAD SHX Text
63
AutoCAD SHX Text
12
AutoCAD SHX Text
20
AutoCAD SHX Text
GREASE TRAP
AutoCAD SHX Text
14
AutoCAD SHX Text
Trolley
AutoCAD SHX Text
Pie
AutoCAD SHX Text
13
AutoCAD SHX Text
Desk and shelving
AutoCAD SHX Text
11
AutoCAD SHX Text
M
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
P.O.S. unit
AutoCAD SHX Text
70
AutoCAD SHX Text
Chip fryer
AutoCAD SHX Text
69
AutoCAD SHX Text
Grill
AutoCAD SHX Text
74
AutoCAD SHX Text
Chip dump
AutoCAD SHX Text
71
AutoCAD SHX Text
3m 5dr. Undercounter Fridge by Combibake
AutoCAD SHX Text
"HOUNO BAKEMATIC B 1.06"
AutoCAD SHX Text
BAKING OVEN
AutoCAD SHX Text
23
AutoCAD SHX Text
ROTISSERIE
AutoCAD SHX Text
24
AutoCAD SHX Text
3.0
AutoCAD SHX Text
3.0
AutoCAD SHX Text
3.0
AutoCAD SHX Text
3.0
AutoCAD SHX Text
4.0
AutoCAD SHX Text
43.5
AutoCAD SHX Text
CARWASH
AutoCAD SHX Text
SEATTLE
AutoCAD SHX Text
or EQUAL
AutoCAD SHX Text
WASH UP PREP AREA.
AutoCAD SHX Text
Fillers
AutoCAD SHX Text
LINE OF ROOF OVERHANG
AutoCAD SHX Text
ATTENDANTS
AutoCAD SHX Text
TOILET
AutoCAD SHX Text
DISABLED
AutoCAD SHX Text
FEMALE &
AutoCAD SHX Text
92
AutoCAD SHX Text
ATM CUBICLE
AutoCAD SHX Text
DRIP SINK
AutoCAD SHX Text
48
AutoCAD SHX Text
JUICE
AutoCAD SHX Text
03
AutoCAD SHX Text
COKE
AutoCAD SHX Text
03
AutoCAD SHX Text
COKE
AutoCAD SHX Text
02
AutoCAD SHX Text
01
AutoCAD SHX Text
COKE
AutoCAD SHX Text
03
AutoCAD SHX Text
03
AutoCAD SHX Text
02
AutoCAD SHX Text
01
AutoCAD SHX Text
02
AutoCAD SHX Text
01
AutoCAD SHX Text
01
AutoCAD SHX Text
03
AutoCAD SHX Text
COKE
AutoCAD SHX Text
02
AutoCAD SHX Text
COKE
AutoCAD SHX Text
01
AutoCAD SHX Text
02
AutoCAD SHX Text
03
AutoCAD SHX Text
WATER
AutoCAD SHX Text
01
AutoCAD SHX Text
02
AutoCAD SHX Text
01
AutoCAD SHX Text
ENERGY
AutoCAD SHX Text
03
AutoCAD SHX Text
02
AutoCAD SHX Text
02
AutoCAD SHX Text
01
AutoCAD SHX Text
03
AutoCAD SHX Text
JUICE
AutoCAD SHX Text
01
AutoCAD SHX Text
02
AutoCAD SHX Text
03
AutoCAD SHX Text
04
AutoCAD SHX Text
MALE TOILET
AutoCAD SHX Text
BRICKWORK (SHOWN HATCHED) TO
AutoCAD SHX Text
BE BUILT FULL HEIGHT TO UNDERSIDE OF
AutoCAD SHX Text
CHANGE ROOM
AutoCAD SHX Text
AND LOCKERS
AutoCAD SHX Text
ROOF SHEETS
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
9 DOOR CHILLER FRIDGES
AutoCAD SHX Text
STORAGE
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04
AutoCAD SHX Text
04
AutoCAD SHX Text
Floor drain by plumber
AutoCAD SHX Text
04
AutoCAD SHX Text
50
AutoCAD SHX Text
50
AutoCAD SHX Text
Storage Cupboards
AutoCAD SHX Text
51
AutoCAD SHX Text
V-chiller_Exposer CP1850
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Vent. LOBBY
AutoCAD SHX Text
tap
AutoCAD SHX Text
COMPRESSOR
AutoCAD SHX Text
UNDER
AutoCAD SHX Text
STORAGE OVER
AutoCAD SHX Text
LINE OF ROOF OVERHANG
AutoCAD SHX Text
POS
AutoCAD SHX Text
CASH
AutoCAD SHX Text
COLLECT
AutoCAD SHX Text
safe
AutoCAD SHX Text
C.I.T.
AutoCAD SHX Text
PAY IN TRAY
AutoCAD SHX Text
M.D.B.
AutoCAD SHX Text
OFFICE
AutoCAD SHX Text
P.O.S. unit
AutoCAD SHX Text
04
AutoCAD SHX Text
COLD ROOM
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
M
AutoCAD SHX Text
SH01-003 S
AutoCAD SHX Text
Microwave
AutoCAD SHX Text
34
AutoCAD SHX Text
64
AutoCAD SHX Text
Toaster
AutoCAD SHX Text
SH01-003 S
AutoCAD SHX Text
Bain Marie
AutoCAD SHX Text
68
AutoCAD SHX Text
SH01-004 S
AutoCAD SHX Text
sandwich counter over
AutoCAD SHX Text
Underbar fridge with
AutoCAD SHX Text
63
AutoCAD SHX Text
12
AutoCAD SHX Text
20
AutoCAD SHX Text
GREASE TRAP
AutoCAD SHX Text
14
AutoCAD SHX Text
Trolley
AutoCAD SHX Text
Pie
AutoCAD SHX Text
13
AutoCAD SHX Text
Desk and shelving
AutoCAD SHX Text
11
AutoCAD SHX Text
M
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
P.O.S. unit
AutoCAD SHX Text
70
AutoCAD SHX Text
Chip fryer
AutoCAD SHX Text
69
AutoCAD SHX Text
Grill
AutoCAD SHX Text
74
AutoCAD SHX Text
Chip dump
AutoCAD SHX Text
71
AutoCAD SHX Text
3m 5dr. Undercounter Fridge by Combibake
AutoCAD SHX Text
"HOUNO BAKEMATIC B 1.06"
AutoCAD SHX Text
BAKING OVEN
AutoCAD SHX Text
23
AutoCAD SHX Text
ROTISSERIE
AutoCAD SHX Text
24
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3.0
AutoCAD SHX Text
3.0
AutoCAD SHX Text
3.0
AutoCAD SHX Text
3.0
AutoCAD SHX Text
4.0
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43.5
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Oil Tanker
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Oil Tanker
Page 20: Freshwater Consulting cc · 2020-06-22 · Freshwater Consulting cc 5 April 2019 Adrian Sillito Sillito Environmental Consulting By email: adrian@environmentalconsultants.co.za Dear

Appendix 1:Assessment method for rating of impact significance

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CRITERIA USED FOR THE ASSESSMENT OF POTENTIAL IMPACTS

The following criteria are used to attribute impact significance ratings to different developmentoptions (see detailed explanation of each criterion on following page): Nature and status of impact; Extent; Duration; Intensity; Probability; Significance; and Degree of confidence.

In assigning significance ratings to potential impacts before and after mitigation, the approachpresented below is followed:1. The status of an impact is used to describe whether the impact will have a negative, positive

or zero effect on the surrounding environment. An impact may therefore be negative, positive(i.e. a benefit) or neutral.

2. The core criteria for determining significance ratings are “extent”, “duration” and “intensity”.The preliminary significance ratings for the combination of these three criteria are given.

3. The impact is described in terms of the probability of the impact occurring and the degree ofconfidence in the impact predictions, based on the availability of information and specialistknowledge.

4. Additional criteria considered, which could increase the significance rating if deemed justified(with motivation), are the following: Permanent/irreversible impacts (as distinct from long term, reversible impacts); Potentially substantial cumulative effects; and/or High level of risk or uncertainty, with potentially substantial negative consequences.

5. Additional criteria considered, which could decrease the significance rating if deemedjustified (with motivation), are the following: Improbable impact, where confidence level in prediction is high.

6. In assigning significance ratings to impacts after mitigation, the following aspects areconsidered: First, the probable changes in intensity, extent and duration of the impact after

mitigation, assuming effective implementation of mitigation measures, leading to a revised significance rating; and

Then, the moderation of the significance rating after taking into account the likelihood of the proposed mitigation measures being effectively implemented, taking into account:o Any potentially significant risks or uncertainties associated with the effectiveness of

mitigation measures;o The technical and financial ability of the proponent to implement the measure; and o The commitment of the proponent to implementing the measure, or guarantee over

time that the measures would be implemented.

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CRITERIA USED FOR THE ASSESSMENT OF IMPACTS[taken from DEA&DP’s Guideline for Involving Biodiversity Specialists in EIA Processes (Brownlie, 2005)]

Nature of the impact – A description of positive or negative effect of the project on the affected environment, or vice versa. This description should include who or what would be affected, and how.

Extent - the impact could: be site-specific; be limited to the site and its immediate surroundings (i.e. local); have an impact on the region (e.g. if communities rely on biodiversity); have an impact on a national scale (e.g. national biodiversity conservation targets); or have an impact across international borders (e.g. where catchments cross international border,

international conventions are concerned, or migratory species).

Duration – It is important to indicate whether or not the lifetime of the impact will be: short term (e.g. during the construction phase); medium term (e.g. during part or all of the operational phase); long term (e.g. beyond the operational phase, but not permanently); permanent (where the impact is for all intents and purposes irreversible. An irreversible negative

impact may also result in irreplaceable loss of natural capital or biodiversity, if it were to result in extinction or loss of a species or ecosystem); or

discontinuous or intermittent (where the impact may only occur during specific climatic conditions orduring a particular season of the year).

Intensity or magnitude – The size of the impact (if positive) or its severity (if negative): low, where biodiversity is negligibly affected or where the impact is so low that remedial action is

not required; medium, where biodiversity pattern, process and/or ecosystem services are altered, but not

severely affected, and the impact can be remedied successfully; and high, where pattern, process and/or ecosystem services would be substantially (i.e. to a very large

degree) affected. If a negative impact, could lead to irreplaceable loss of biodiversity and/or unacceptable consequences for human wellbeing.

Probability – Should describe the likelihood of the impact actually occurring indicated as: improbable, where the possibility of the impact is very low either because of design or historic

experience; probable, where there is a distinct possibility that the impact will occur; highly probable, where it is most likely that the impact will occur; or definite, where the impact will occur regardless of any prevention measures.

Significance – The significance of impacts can be determined through a synthesis of the assessment criteria (see protocol on following page). Significance can be described as: low, where it would have negligible effect on biodiversity, and on the decision; medium, where it would have a moderate effect on biodiversity, and should influence the decision; high, where it would have, or there would be a high risk of, a large effect on biodiversity. These

impacts should have a major influence on the decision; or very high, where it would have, or there would be a high risk of, an irreversible negative impact on

biodiversity and irreplaceable loss of natural capital or a major positive effect. Impacts of very high significance should be a central factor in decision-making.

Confidence – The level of confidence in predicting the impact can be described as: low, where there is little confidence in the prediction, due to inherent uncertainty about the likely

response of the receiving ecosystem, or inadequate information;

Page 23: Freshwater Consulting cc · 2020-06-22 · Freshwater Consulting cc 5 April 2019 Adrian Sillito Sillito Environmental Consulting By email: adrian@environmentalconsultants.co.za Dear

Protocol for determining the SIGNIFICANCE of potential impacts (developed by Ractliffe and Ewart-Smith, Freshwater Consulting Group)

Rating Description (i.t.o. intensity, extent and duration)

VERY HIGH Impacts could be EITHER:of high intensity at a regional level and endure in the long term;

OR of high intensity at a national level in the medium term;OR of medium intensity at a national level in the long term.

HIGH Impacts could be EITHER:of high intensity at a regional level and endure in the medium term;

OR of high intensity at a national level in the short term;OR of medium intensity at a national level in the medium term;OR of low intensity at a national level in the long term;OR of high intensity at a local level in the long term;OR of medium intensity at a regional level in the long term.

MEDIUM Impacts could be EITHER:of high intensity at a local level and endure in the medium term;

OR of medium intensity at a regional level in the medium term;OR of high intensity at a regional level in the short term;OR of medium intensity at a national level in the short term;OR of medium intensity at a local level in the long term;OR of low intensity at a national level in the medium term;OR of low intensity at a regional level in the long term.

LOW Impacts could be EITHER: of low intensity at a regional level and endure in the medium term;

OR of low intensity at a national level in the short term;OR of high intensity at a local level and endure in the short term;OR of medium intensity at a regional level in the short term;OR of low intensity at a local level in the long term;OR of medium intensity at a local level and endure in the medium term.

VERY LOW Impacts could be EITHER: of low intensity at a local level and endure in the medium term;

OR of low intensity at a regional level and endure in the short term;OR of low to medium intensity at a local level and endure in the short term.

NOTAPPLICABLE

Impacts with: Zero intensity with any combination of extent and duration.

UNKNOWN In certain cases it may not be possible to determine the significance of an impact.

Page 24: Freshwater Consulting cc · 2020-06-22 · Freshwater Consulting cc 5 April 2019 Adrian Sillito Sillito Environmental Consulting By email: adrian@environmentalconsultants.co.za Dear

Appendix 2:Proposed site development plans

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Page 26: Freshwater Consulting cc · 2020-06-22 · Freshwater Consulting cc 5 April 2019 Adrian Sillito Sillito Environmental Consulting By email: adrian@environmentalconsultants.co.za Dear

21

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SEATTLE
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or EQUAL
AutoCAD SHX Text
WASH UP PREP AREA.
AutoCAD SHX Text
Fillers
AutoCAD SHX Text
LINE OF ROOF OVERHANG
AutoCAD SHX Text
ATTENDANTS
AutoCAD SHX Text
TOILET
AutoCAD SHX Text
DISABLED
AutoCAD SHX Text
FEMALE &
AutoCAD SHX Text
92
AutoCAD SHX Text
ATM CUBICLE
AutoCAD SHX Text
DRIP SINK
AutoCAD SHX Text
48
AutoCAD SHX Text
JUICE
AutoCAD SHX Text
03
AutoCAD SHX Text
COKE
AutoCAD SHX Text
03
AutoCAD SHX Text
COKE
AutoCAD SHX Text
02
AutoCAD SHX Text
01
AutoCAD SHX Text
COKE
AutoCAD SHX Text
03
AutoCAD SHX Text
03
AutoCAD SHX Text
02
AutoCAD SHX Text
01
AutoCAD SHX Text
02
AutoCAD SHX Text
01
AutoCAD SHX Text
01
AutoCAD SHX Text
03
AutoCAD SHX Text
COKE
AutoCAD SHX Text
02
AutoCAD SHX Text
COKE
AutoCAD SHX Text
01
AutoCAD SHX Text
02
AutoCAD SHX Text
03
AutoCAD SHX Text
WATER
AutoCAD SHX Text
01
AutoCAD SHX Text
02
AutoCAD SHX Text
01
AutoCAD SHX Text
ENERGY
AutoCAD SHX Text
03
AutoCAD SHX Text
02
AutoCAD SHX Text
02
AutoCAD SHX Text
01
AutoCAD SHX Text
03
AutoCAD SHX Text
JUICE
AutoCAD SHX Text
01
AutoCAD SHX Text
02
AutoCAD SHX Text
03
AutoCAD SHX Text
04
AutoCAD SHX Text
MALE TOILET
AutoCAD SHX Text
BRICKWORK (SHOWN HATCHED) TO
AutoCAD SHX Text
BE BUILT FULL HEIGHT TO UNDERSIDE OF
AutoCAD SHX Text
CHANGE ROOM
AutoCAD SHX Text
AND LOCKERS
AutoCAD SHX Text
ROOF SHEETS
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
9 DOOR CHILLER FRIDGES
AutoCAD SHX Text
STORAGE
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
Floor drain by plumber
AutoCAD SHX Text
04
AutoCAD SHX Text
50
AutoCAD SHX Text
50
AutoCAD SHX Text
Storage Cupboards
AutoCAD SHX Text
51
AutoCAD SHX Text
V-chiller_Exposer CP1850
AutoCAD SHX Text
Vent. LOBBY
AutoCAD SHX Text
tap
AutoCAD SHX Text
COMPRESSOR
AutoCAD SHX Text
UNDER
AutoCAD SHX Text
STORAGE OVER
AutoCAD SHX Text
LINE OF ROOF OVERHANG
AutoCAD SHX Text
POS
AutoCAD SHX Text
CASH
AutoCAD SHX Text
COLLECT
AutoCAD SHX Text
safe
AutoCAD SHX Text
C.I.T.
AutoCAD SHX Text
PAY IN TRAY
AutoCAD SHX Text
M.D.B.
AutoCAD SHX Text
OFFICE
AutoCAD SHX Text
P.O.S. unit
AutoCAD SHX Text
04
AutoCAD SHX Text
COLD ROOM
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
M
AutoCAD SHX Text
SH01-003 S
AutoCAD SHX Text
Microwave
AutoCAD SHX Text
34
AutoCAD SHX Text
64
AutoCAD SHX Text
Toaster
AutoCAD SHX Text
SH01-003 S
AutoCAD SHX Text
Bain Marie
AutoCAD SHX Text
68
AutoCAD SHX Text
SH01-004 S
AutoCAD SHX Text
sandwich counter over
AutoCAD SHX Text
Underbar fridge with
AutoCAD SHX Text
63
AutoCAD SHX Text
12
AutoCAD SHX Text
20
AutoCAD SHX Text
GREASE TRAP
AutoCAD SHX Text
14
AutoCAD SHX Text
Trolley
AutoCAD SHX Text
Pie
AutoCAD SHX Text
13
AutoCAD SHX Text
Desk and shelving
AutoCAD SHX Text
11
AutoCAD SHX Text
M
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
P.O.S. unit
AutoCAD SHX Text
70
AutoCAD SHX Text
Chip fryer
AutoCAD SHX Text
69
AutoCAD SHX Text
Grill
AutoCAD SHX Text
74
AutoCAD SHX Text
Chip dump
AutoCAD SHX Text
71
AutoCAD SHX Text
3m 5dr. Undercounter Fridge by Combibake
AutoCAD SHX Text
"HOUNO BAKEMATIC B 1.06"
AutoCAD SHX Text
BAKING OVEN
AutoCAD SHX Text
23
AutoCAD SHX Text
ROTISSERIE
AutoCAD SHX Text
24
AutoCAD SHX Text
3.0
AutoCAD SHX Text
3.0
AutoCAD SHX Text
3.0
AutoCAD SHX Text
3.0
AutoCAD SHX Text
4.0
AutoCAD SHX Text
43.5
AutoCAD SHX Text
CARWASH
AutoCAD SHX Text
SEATTLE
AutoCAD SHX Text
or EQUAL
AutoCAD SHX Text
WASH UP PREP AREA.
AutoCAD SHX Text
Fillers
AutoCAD SHX Text
LINE OF ROOF OVERHANG
AutoCAD SHX Text
ATTENDANTS
AutoCAD SHX Text
TOILET
AutoCAD SHX Text
DISABLED
AutoCAD SHX Text
FEMALE &
AutoCAD SHX Text
92
AutoCAD SHX Text
ATM CUBICLE
AutoCAD SHX Text
DRIP SINK
AutoCAD SHX Text
48
AutoCAD SHX Text
JUICE
AutoCAD SHX Text
03
AutoCAD SHX Text
COKE
AutoCAD SHX Text
03
AutoCAD SHX Text
COKE
AutoCAD SHX Text
02
AutoCAD SHX Text
01
AutoCAD SHX Text
COKE
AutoCAD SHX Text
03
AutoCAD SHX Text
03
AutoCAD SHX Text
02
AutoCAD SHX Text
01
AutoCAD SHX Text
02
AutoCAD SHX Text
01
AutoCAD SHX Text
01
AutoCAD SHX Text
03
AutoCAD SHX Text
COKE
AutoCAD SHX Text
02
AutoCAD SHX Text
COKE
AutoCAD SHX Text
01
AutoCAD SHX Text
02
AutoCAD SHX Text
03
AutoCAD SHX Text
WATER
AutoCAD SHX Text
01
AutoCAD SHX Text
02
AutoCAD SHX Text
01
AutoCAD SHX Text
ENERGY
AutoCAD SHX Text
03
AutoCAD SHX Text
02
AutoCAD SHX Text
02
AutoCAD SHX Text
01
AutoCAD SHX Text
03
AutoCAD SHX Text
JUICE
AutoCAD SHX Text
01
AutoCAD SHX Text
02
AutoCAD SHX Text
03
AutoCAD SHX Text
04
AutoCAD SHX Text
MALE TOILET
AutoCAD SHX Text
BRICKWORK (SHOWN HATCHED) TO
AutoCAD SHX Text
BE BUILT FULL HEIGHT TO UNDERSIDE OF
AutoCAD SHX Text
CHANGE ROOM
AutoCAD SHX Text
AND LOCKERS
AutoCAD SHX Text
ROOF SHEETS
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
9 DOOR CHILLER FRIDGES
AutoCAD SHX Text
STORAGE
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
Floor drain by plumber
AutoCAD SHX Text
04
AutoCAD SHX Text
50
AutoCAD SHX Text
50
AutoCAD SHX Text
Storage Cupboards
AutoCAD SHX Text
51
AutoCAD SHX Text
V-chiller_Exposer CP1850
AutoCAD SHX Text
Vent. LOBBY
AutoCAD SHX Text
tap
AutoCAD SHX Text
COMPRESSOR
AutoCAD SHX Text
UNDER
AutoCAD SHX Text
STORAGE OVER
AutoCAD SHX Text
LINE OF ROOF OVERHANG
AutoCAD SHX Text
POS
AutoCAD SHX Text
CASH
AutoCAD SHX Text
COLLECT
AutoCAD SHX Text
safe
AutoCAD SHX Text
C.I.T.
AutoCAD SHX Text
PAY IN TRAY
AutoCAD SHX Text
M.D.B.
AutoCAD SHX Text
OFFICE
AutoCAD SHX Text
P.O.S. unit
AutoCAD SHX Text
04
AutoCAD SHX Text
COLD ROOM
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
M
AutoCAD SHX Text
SH01-003 S
AutoCAD SHX Text
Microwave
AutoCAD SHX Text
34
AutoCAD SHX Text
64
AutoCAD SHX Text
Toaster
AutoCAD SHX Text
SH01-003 S
AutoCAD SHX Text
Bain Marie
AutoCAD SHX Text
68
AutoCAD SHX Text
SH01-004 S
AutoCAD SHX Text
sandwich counter over
AutoCAD SHX Text
Underbar fridge with
AutoCAD SHX Text
63
AutoCAD SHX Text
12
AutoCAD SHX Text
20
AutoCAD SHX Text
GREASE TRAP
AutoCAD SHX Text
14
AutoCAD SHX Text
Trolley
AutoCAD SHX Text
Pie
AutoCAD SHX Text
13
AutoCAD SHX Text
Desk and shelving
AutoCAD SHX Text
11
AutoCAD SHX Text
M
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
04
AutoCAD SHX Text
P.O.S. unit
AutoCAD SHX Text
70
AutoCAD SHX Text
Chip fryer
AutoCAD SHX Text
69
AutoCAD SHX Text
Grill
AutoCAD SHX Text
74
AutoCAD SHX Text
Chip dump
AutoCAD SHX Text
71
AutoCAD SHX Text
3m 5dr. Undercounter Fridge by Combibake
AutoCAD SHX Text
"HOUNO BAKEMATIC B 1.06"
AutoCAD SHX Text
BAKING OVEN
AutoCAD SHX Text
23
AutoCAD SHX Text
ROTISSERIE
AutoCAD SHX Text
24
AutoCAD SHX Text
3.0
AutoCAD SHX Text
3.0
AutoCAD SHX Text
3.0
AutoCAD SHX Text
3.0
AutoCAD SHX Text
4.0
AutoCAD SHX Text
43.5
AutoCAD SHX Text
Oil Tanker
AutoCAD SHX Text
Oil Tanker