richards bay wef - total species group d bat passes over ... bay wind energy project tk06.… ·...

Pre-construction Bat Monitoring Impact Report - NSS

Richards Bay Wind Energy Facility 70

Figure 14-17: Mean Species Group D Bat Passes and Weather Conditions per Date for RB1 and RB4

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Richards Bay WEF - Total Species Group D Bat Passes over Monitoring Period

Mean Species Group D (RB1 & RB4) No Monitoring Average Windspeed @ 40m Average Temperature



14.4.6 Bat Activity and Moon Phases

Bat activity was assessed against the various phases of the moon during the monitoring. The mean bat

passes per date per was lowest in Third Quarter Moon and highest in Waning Cresent (Figure 14-18).

The statistics in Section 14.4.4 showed combined season and moon phase as one important driver of

bat activity. However, NSS has not yet found a specific moon phase to be important across many

project sites in SA.

Figure 14-18 Bat Activity Index per Moon Phase

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Richards Bay WEF Activity Index for the Moon Phases

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Richards Bay WEF Activity Index for the Moon Phases

Species Group A Species Group B Species Group C



15. RICHARDS BAY BAT SENSITIVITY 15.1. Regional Areas of Bat Conservation Importance

The Richards Bay WEF site has several formally Protected Areas within a 100km radius around the site,

the closest being the Nseleni Nature Reserve, approximately 2km to the east of the site (Figure 15-2).

The smaller reserves have been buffered with a 2.5km sensitivity buffer to protect for potential bat

roosts in protected areas. The larger Nationally important reserves have been buffered with 20km. In

addition, known roosts of regional significance, such as Mission Rocks, Sibudu, Border Cave and

Hlatikulu Forest Reserve caves have been buffered by a 30km high sensitivity buffer. Most cave

dwelling bats travel in excess of 20km nightly to forage, especially if there is high competition for food

resources.

15.2. Local Areas of Bat Conservation Importance

Based on the results obtained during the March 2012 EIA site visit and the monitoring from end April

2012 to early May 2013, a Sensitivity Map has been compiled for the proposed Richards Bay WEF

(Figure 15-1). The Richards Bay WEF study area is a bat sensitive site and the following points are

important in understanding the risks and maps:

All wetlands, dams and rivers (perennial and non-perennial) and assigned buffers are

considered of High conservation value for bats and should be treated as No-Go areas to protect

bats utilizing these areas for foraging along the valley bottom and riparian fringes. There is

strong support for the importance of rivers and riparian areas for bats: Serra-Cobo et al. (2000)

confirmed the role of rivers as possible landmarks in the orientation flight of bat species. Other

studies, such as Akasaka et al. (2009), Hagen and Sabo (2012) and Lloyd et al. (2006), also

demonstrate the importance of riparian areas and water for bats. The absolute minimum buffer

of 200m for bat important features has been placed on these areas.

All confirmed roosts were assigned a 500m buffer for the protection of the highest concentration

of the bats leaving those roosts to forage nightly. This distance is the absolute minimum and

is not negotiable, as all bats travel in excess of distance nightly. Refer to Section 5 on the

foraging range of the most commonly occurring bats at Richards Bay.

It is recommended that all High sensitivity areas be No-Go for development, and the areas

remaining that are classified as Medium-High sensitivity, where any development proposed

should receive strict mitigation measures, as per those recommended in Section 16.

Mitigation recommendations in Section 16 will be based on the Sensitivity Maps.



Figure 15-1: Regional Areas of Bat Conservation Importance



Figure 15-2: Richards Bay WEF: Bat Sensitivity Map



16. IMPACT ASSESSMENT The potential for impacts on bats by the proposed wind energy facility is evaluated in terms of impacts

related to bat’s three main behavioural activities:

Roosting impacts:

o roosting habitat destruction or disturbance

o attraction of bats to towers for roosting and therefore fatalities due to collision or

barotrauma.

Foraging impacts:

o displacement from foraging habitat due to wind turbine operation; and

o bat fatalities due to collision or barotrauma during foraging activity.

Migration impacts:

o bat fatalities due to collision or barotrauma during long distance seasonal migrations

The Impact Assessment Methodology involved the ranking of the different impact parameters, as per

Table 16-1 below, to calculate significance. This calculated value was then used to classify the

significance of the impact into Low, Medium or High, as per Table 16-2. The Bat Impact Assessment

matrix for the Richards Bay WEF, with descriptions and ratings are in Table 16-3 overleaf and

discussed below, together with applicable mitigation measures.

Table 16-1: Impact Ranking Matrix

PARAMETER RANKING

0 1 2 3 4

EXTENT None Localised Study Area Regional / National International

DURATION None Short- term Medium-term Long-term Permanent

INTENSITY None Low Medium High Very High

PROBABILITY None Improbable Probable Highly Probable Definite

The significance is calculated as: Significance = (Extent + Duration + Intensity) x Probability

Table 16-2: Classification of Significance

NATURE OF

IMPACT SIGNIFICANCE

Negative

Low Medium High

Impact will not have an influence

on the decision or require to be

significantly accommodated in

the project design

Impact could have an influence

on the environment which will

require modification of the

project design or alternative

mitigation

Impact could have a ‘no-go’

implication for the project

unless mitigation or re-

design is practically

achievable.

1 - 16 17 - 32 33 - 48



Table 16-3: Richards Bay WEF Bat Impact Assessment Matrix

Details Rating Details Rating Details Rating Details Rating Details Total Details Rating

Without

MitigationNegative Study Area 2 Medium Term 2 High 3

Highly

Probable 3 Medium 21 High 3

With

MitigationNegative Localised 1 Short Term 1 Medium 2 Probable 2 Low 8 High 3

Without

MitigationNegative

Regional /

National3 Permanent 4 Very High 4 Definite 4 High 44 High 3

With

MitigationNegative

Regional /

National3 Permanent 4 Medium 2 Probable 2 Medium 18 High 3

Without

MitigationNegative

Regional /


With

MitigationNegative

Regional /

National3 Permanent 4 Medium 2 Probable 2 Medium 18 High 3

Without

MitigationNegative International 4 Permanent 4 Very High 4

Highly

Probable 3 High 36 Medium 2

With

MitigationNegative

Regional /

National3 Permanent 4 High 3 Probable 2 Medium 20 Medium 2

Without

MitigationNegative

Regional /

National3 Permanent 4 Medium 2 Probable 2 Medium 18 Medium 2

With

MitigationNegative Study Area 2 Permanent 4 Low 1 Improbable 1 Low 7 Low 1

Without

MitigationNegative International 4 Permanent 4 Very High 4

Highly

Probable 3 High 36 High 3

With

MitigationNegative

Regional /

National3 Long Term 3 High 3 Probable 2 Medium 18 Medium 2

Without

MitigationNegative

Regional /

National3 Permanent 4 High 3 Probable 2 Medium 20 Medium 2

With

MitigationNegative Study Area 2 Long Term 3 Low 1 Improbable 1 Low 6 Medium 2

Without

MitigationNegative

Regional /


With

MitigationNegative Study Area 2 Long Term 3 Medium 2 Probable 2 Low 14 Medium 2

Without

MitigationNegative

Regional /

National3 Permanent 4 High 3

Highly

Probable 3 Medium 30 High 3

With

MitigationNegative Study Area 2 Long Term 3 Medium 2 Probable 2 Low 14 Medium 2

Without

MitigationNegative

Regional /

National3 Permanent 4 Very High 4

Highly

Probable 3 Medium 33 Low 1

With

MitigationNegative

Regional /

National3 Permanent 4 High 3 Improbable 1 Low 10 Low 1

No

1

2

5

3

4

Bat fatalities due to collision or

barotrauma during foraging

activity

9

10

Fragmentation to and

displacement from foraging

habitat due to w ind turbine

construction and operation


barotrauma during migration

7

6


barotrauma due to attraction

of bats to tow ers for roosting

or out of curiosity

8

ProbabilityStatus

Loss in Ecosystem Services

Provided by the Bats

Disturbance to Social

Structure of Bat Populations

Bat Fatalities due to

Electrocution from Overhead

Pow erlines

Confidence

Reduction in the size, genetic

diversity, resilience and

persistence of bat populations

Roost disturbance or

destruction due to

construction activities

Loss of Conservation

Important Bat Species from

the area due to construction

and operation activities

SignificanceImpact Description

DurationExtent Intensity



16.1. Roost disturbance and/ or destruction due to construction activities

16.1.1 Cause and significance

Construction activity will involve site clearance, hence the removal of vegetation and possibly some out

buildings for the construction of each turbine and associated infrastructure. This will destroy these roost

sites in the vicinity of each turbine. These construction impacts are seen as Medium without mitigation in

place and can be reduced to Low with the following measures in place.

16.1.2 Mitigation and Management

Mitigation measures would include:

Turbine layout to remain out of High Bat Sensitivity buffers (Figure 15-2)

Avoid roads and powerlines crossings rivers and gorges where possible,

No borrowing of fill material from quarries within No-Go areas.

Minimizing the extent of area to be disturbed by pre-construction and construction activities at the

turbine localities, and

Minimize to the maximum extent practicable, roads, power lines, fences, and other infrastructure

associated with the WEF project.

16.2. Fragmentation to and displacement from foraging habitat due to wind turbine construction

and operation


Construction and Operational practises can lead to the disturbance of foraging behaviour, for example,

turbines and power lines within key foraging habitats causing displacement from these areas, light/

illumination disturbances, disturbances to wetlands, physical barrier affect, etc. Due to the high foraging

potential at the Richards Bay WEF site, these construction and operational impacts are seen as High

without mitigation in place and can be reduced to Medium with the following measures in place.


All turbines to remain outside of the High Bat Sensitivity areas.

Gaps of at least 3 turbine blade lengths are left open between turbines, from blade tip to blade tip.

Keep road, turbine, quarry and sub-station lighting to minimum.

With the exception of red aviation safety lights on lights on the turbines and meteorological masts,

lights should be hooded downward and directed to minimize horizontal and skyward illumination.

Minimize use of high intensity lighting, steady-burning, or bright lights such as sodium vapour,

quartz, halogen, or other bright spotlights.

All internal turbine nacelle and tower lighting should be extinguished when unoccupied.

Minimize impacts to wetlands and water resources by following all applicable provisions of the

National Water Act and keep all turbines outside of No-Go areas.

16.3. Bat fatalities due to collision or barotrauma during foraging activity


Deaths caused by wind turbines are well documented internationally, even where bat activity levels are

substantially lower than at Richards Bay, therefore, this impact is a serious consideration for the Richards



Bay WEF. Mortality is increased near moving, but not static turbine blades at WEFs (Arnett et al., 2008,

Durr & Bach, 2004, Horn et al., 2008, and Kunz et al., 2007).

It is not known why bats are not able to avoid the moving turbine blade, but the following study is

interesting to consider. Bates and Simmons (2011) have shown that bats have a perceptual mechanism for

rejecting echoes from clutter that is off to the side or some distance away in order to focus on more

important targets directly in front of them. They liken the bats’ ability to ignore misaligned echoes to our

peripheral vision; just as we can vaguely distinguish objects on our periphery but not see them in high

resolution, big brown bats don’t perceive far-off clutter as accurately as a juicy moth right in front of their

noses. Hence, bats may not “see” wind turbines when concentrating on catching food.

The dominant types of bats at the current study area are species that are at high or medium-high risk of

fatality due to their foraging behaviour. The potential consequences of high death rates are:

Loss of essential ecosystem services (Kunz et al., 2011)

Social breakdown amongst the gregarious colonies (Kerth et al., 2011).

Reduction in the size, genetic diversity and resilience of a population.

Loss of Conservation Important species

The significance of this potential impact without mitigation is considered to have a High significance for the

current turbine layout, this is assessed with a High level of confidence due to confirmation that bats are

flying within rotor sweep height on and off site. Due to the sensitivity of this site for bats, unless the

developer adopts all the of the NSS recommendations, NSS recommends that the Richards Bay WEF is a

No-Go project. There are some proven mitigation measures that can be applied to reduce the significance

to Medium. NSS will only support this project if such measures are adhered to as follows:


The following measures are proposed based on the monitoring results and :

Ongoing involvement and support of the South African Bat Assessment Advisory Panel (SABAAP)

The South African Bat fraternity has elected the SABAAP committee to be the representative body

for bat assessments in SA. They will act in an advisory, monitoring and research function. The

developer is to submit all monitoring and progress reports related to the Richards Bay WEF to the

SABAAP and support them in their research efforts in understanding bat movements in SA and how

to further reduce turbine related fatalities.

Bat Research Fund

In order to be able to facilitate ongoing and adaptive management and research, financial provision

must be guaranteed to cover the costs of initial mitigation, post-construction monitoring, the various

adaptive mitigation approaches to be recommended from ongoing post-construction monitoring

Turbine Sighting and Dimensions



o All all turbines located within High sensitive areas, according to the Sensitivity map in

Figure 15-2 should be No-Go. No part of the turbine (including the full rotor swept area)

should occur with the No-Go areas.

o Gaps of at least 3 turbine blade lengths are left open between turbines, from blade tip to

blade tip. Turbines located closer than that should be relocated.

Operational Curtailment

All turbines situated in Medium-High sensitive areas should adopt strict operational curtailment

during peak bat activity times and a more relaxed curtailment during the remainder of the night.

Curtailment is further described in Box 1.

The only way to understand the effectiveness of different mitigation strategies is to test them. An

initial operational curtailment trial is recommended for the first year of operation for all turbines

situated in Medium-High sensitive areas at the Richards Bay WEF, after which an adaptive

approach is to be applied depending on the results of the trials. The only exception to applying the

below trials will be if temperatures drop below 14°C; under this temperature, then the below

measures are not required.

Seven trial cut-in speeds are initially recommended according to 70%, 80% and 90% of the bat

activity occurrence and a control. All turbines within Medium-High sensitive areas should be divided

into seven groups of equal numbers, depending on the final number of turbines selected (no less

than 3 turbines per group). The trials are to be as follows:

Group 1

The control group will operate with no curtailment, normal turbine manufacturer cut-in speed

in to apply. HOWEVER, fatality records are to be supplied to SABAAP monthly and should

these numbers exceed acceptable levels, levels that may result in population decline,

adaptive measures are to be implemented.

Group 2:

A cut-in speed of 6.2m/s (representing 70% of bat activity at 60m) is to be applied to this

group for 2 hours from sunset and for 1.5 hours prior to sunrise throughout the year.

Group 3:


group for 2 hours from sunset and for 1.5 hours prior to sunrise throughout the year.

Group 4:


group for 2 hours from sunset and for 1.5o hours prior to sunrise throughout the year.

Group 5:


group throughout the night from sunset to sunrise throughout the year.

Group 6:





Group 7:



However, these initial measures are to be closely monitored and an adaptive management

approach must continue until the optimal operational strategy is found through intensive

post-construction monitoring.

Long-term Post-construction Monitoring

As per Sowler and Stoffberg (2012), post-construction monitoring should be conducted to monitor

the effectiveness of the mitigation and residual bat impacts, in order to readjust mitigation measures

where necessary. A detailed post-construction monitoring programme must be developed and

implemented from the very start of operation. This programme will involve Fatality Surveys (human

or dog teams), Searcher Efficiency Trials, Carcass Removal Trials, and Acoustic Monitoring (static

acoustic recording at all the pre-construction bat monitoring stations to be continued during post-

construction monitoring, in order to detect any activity level changes).

16.4. Bat fatalities due to collision or barotrauma during migration


International research has shown that migrating bats are at higher risk of fatality, due to either their higher

flights or other reasons still being researched. Most of the bats killed by turbines in the USA thus far have

Box 1: Operational Curtailment

Observations by Arnett (2005) reported nights of high wind speeds to be associated with extremely low observed bat

fatalities, regardless of the level of the other variables measured, and the highest fatality rates generally were associated

with indicators of low wind speed. Arnett (2005) also mentions that bats are known to suppress their activity during

periods of rain, low temperatures and strong winds, especially if these factors are combined.

A test done by Baerwald et al. (2008) where they altered the wind speed trigger of 15 turbines at a site with high bat

fatalities in south-western Alberta, Canada, during the peak fatality period, showed a reduction of bat fatalities by 60%.

Under normal circumstances the turbine would turn slowly in low wind speeds but only starts generating electricity when

the wind speed reaches 4 m/s. During the experiment the Vestas V80 type turbines were kept stationary during low

wind speeds and only allowed to start turning and generate electricity at a cut-in speed of 5.5 m/s. Another strategy

used in the same experiment involved altering blade angles to reduce rotor speed, meaning the blades were near

motionless in low wind speeds which resulted in a significant 57.5% reduction in bat fatalities.

Arnett et al. (2010) demonstrate, from their Casselman Wind Project site in Somerset County, Pennsylvania, reductions

in average nightly bat fatality ranging from 44–93%, with marginal annual power loss, when the cut-in speed of the

turbines was increased to 5.0m/s. Their findings suggest that increasing turbine cut-in speeds at wind facilities in areas

of conservation concern during times when active bats may be at particular risk from turbines could mitigate this

detrimental aspect of wind-energy generation.

Data research conducted by Rydell et al. (2010) showed that for mortality events at wind farms in north-western Europe,

usually (90%) occurred on nights with low wind speeds in late July to early October and to a lesser extent (10%) also in

April-June.



been migratory species that roost in trees throughout the year, and the highest fatality events appear to

coincide with autumn migration (Cryan and Brown, 2007). They found that relatively low wind speeds, low

moon illumination, and relatively high degrees of cloud cover were important predictors of bat arrivals and

departures, and that low barometric pressure was an additional variable that helped predict bat arrivals.

In South Africa, our migratory species are cave-dwelling bats, for example Miniopterus. natalensis,

Miniopterus fraterculs, Myotis tricolor and possibly Rousettus aegyptiacus. Preliminary data emerging from

long-term monitoring projects indicates that there may be some seasonal movement of Tadarida

aegyptiaca as well.

Four of the above species have been confirmed for Richards Bay. Group C bats making up mostly

Miniopterus sp. and Myotis sp do tend to peak in activity in Autumn and Winter, suggesting some

movement up or down the coast during these times. Group B bats peak in Summer, and Group A bats are

active throughout the year with various activity peaks. The coastal movement of Group C bats would

require further research.

For now, this potential impact without mitigation is considered to have a High significance, reducing to a

significance of Moderate, if mitigation is applied. This impact is assessed with a Medium confidence.


The same measures proposed in Section 16.3 will be applicable here, as well as the following:

Funding a Southern African bat research project recommended by SABAAP on the movement of

bats along the eastern KZN coastline..

16.5. Bat fatalities due to collision or barotrauma due to attraction of bats to towers for roosting

and out of curiosity.


Bats have been shown, through thermal imagery studies, to be attracted to wind turbines, either looking for

potential roosting or out of curiosity and are often struck by the moving blades (Horn et al., 2008). This has

been further confirmed by Rollins et al. (2012).

As there is no specific mitigation measures proven to be effective for preventing this specific aspect, the

only mitigation recommended is the same as for reducing fatalities in flying bats, hence, the significance

goes Medium to Low if such mitigation measures are employed, but with only a Medium confidence,


The most well documented measure is curtailment to prevent fatalities, further discussed below. Whilst

ultrasonic sound emitters are currently being investigated as a deterrent for bats from wind turbines, this

research has not yet produced enough evidence to support this measure. Hence, we cannot yet

recommend this. However, NEA must be prepared to consider various technologies that become available

during the post-construction adaptive mitigation approach.



16.6. Loss of Conservation Important Bat Species from the greater area due to construction and

operation activities


Six of the 22 confirmed species for the Richards Bay WEF study area, 6 are of Conservation Importance,

with one confirmed species, O. martienssi being the only NEMA:TOPS listed species.

Without mitigation, the significance of this impact is assessed as High with a High confidence level. If the

recommended mitigation measures are implemented, this impact can be reduced to a Medium

significance.


Same as recommended in Sections 17.1, 17.2 and 17.3.

16.7. Reduction in the size, genetic diversity, resilience and persistence of bat populations


Bat populations are likely to be reduced in size by the fatality of bats at WEFs, and because bats have low

reproductive rates, they have slow generation turn-over and low population resilience against mass die-

offs. Smaller populations also contain less genetic diversity, and are more susceptible to genetic drift and

inbreeding. WEFs may, therefore, reduce the long-term persistence of local and even regional bat

populations. This impact is assessed as Medium pre-mitigation and Low post-mitigation.


Same as recommended in Sections 17.1, 17.2 and 17.3.

16.8. Reduction of ecosystem services


The significance of this impact is considered High at Richards Bay, both from an environmental and

economic perspective. Sugar cane cultivation dominates the area – approximately 80% of the site is

transformed sugar cane crops.

The main insect pests of sugar cane in South Africa are the stem borers (Eldana saccharina and

Scirpophaga calamistis) and the sugar cane thrips (Fulmekiola serrata) (Long, 1969). Perhaps the most

economically significant of these is the African sugar cane borer Eldana saccharina (order: Lepidoptera).

Efforts have been made since the early 1970’s to control infestations E. Saccharina (Carnegie, 1974) but it

still remains a significant pest to the sugar cane industry (Webster et al. 2005). Sugarcane is the main host

plant of E. Saccharina but as shown by Atkinson (1979) is also a pest of several other major agricultural

crops such as, maize (Zea maize), casawa (Manihot utilissima) and sorghum (Sorghum arundinaceum,

Sorghum versicolor and Sorghum vulgare). Although widely distributed throughout sub-Saharan Africa in

South Africa E. saccharina is restricted to the warmer portions of the Indian ocean coastal belt (Atkinson

1980). Adult moths emerge after a pupation period of 7-14 days. Female moths live for 6-15 days during

which time they may lay several batches of 50-100 eggs on the leaves or at the base of their host plants.

Light brown- to dark grey-coloured larvae emerge from the eggs within 6 days (depending on



temperature). The larval stage typically lasts between 33 to 173 days and it is during this time that the

insect inflicts most damage by boring into the stem (Atkinson 1980). Recently studies have begun to

investigate the use of bats as biocontrol agents in the combat of agricultural pests in Sourthern Africa

(Taylor et al. 2011). Bohmann et al. (2011) investigated the diets of two African free-tailed bats

(Chaerephon pumilus and Mops condylurus) foraging in and around sugarcane fields in north eastern

Zimbabwe. The results of the study showed that insects of the order Lepidoptera (butterflies and moths)

form the greatest part of the the diet of these species and that they do indeed feed on moths belonging to

the same family as E. Saccharina.

Predation by bats of these pests results in lower losses in crop yield and reduced usage of pesticides by

farmers. Considering that the two most commonly occurring bats encountered during the monitoring were

Chaerephon pumilus and Mops condylurus and that they are confirmed predators of moths, they are

undoubtedly playing a significant role in pest reduction on site. This has to be saving the farmers money

and the reduced use of pesticides is positive in terms of indirect additional impacts on water and soil

quality.


Either this project should be a No-Go or the measures described In Section 16.1, 16.2 and 16.3 must be

implemented. The developer should also support research efforts in terms of insect pest control and bats

and the economic consequences, i.e. quantification of such ecosystem services.

16.9. Disturbance to Social Structure of Bat Populations


The loss of female fruit bats has social consequences for family units and young bats. In addition, there is

not enough information available on what the population affects could be due to high mortalities, hence,

this impact is assessed as Medium pre-mitigation and Low post-mitigation with a Medium confidence

level.

16.10. Bat fatalities due to electrocution from overhead powerlines


Whilst there have been no reports to date of this occurring in South Africa, hundreds of flying-foxes are

electrocuted annually on powerlines in Australia. This occurs when they make contact with two wires.

Electrocuted flying-foxes die from cardiac fibrillation (heart attack) or asphyxiation (paralysis of respiratory

muscles). (Bat Care Brisbane, http://www.bats.org.au). As there is regular occupancy of fruit bats (20 to 60

individuals) on site, this is a real potential concern. With a Low confidence, this impact is assessed as

Medium pre-mitigation and Low post-mitigation.


Because this is such an unknown for South Africa, the only two mitigation measures at the moment will be

(1) to put the cables underground where possible, and (2) to monitor bat movement patterns and fatalities

post-construction, then to recommend potential mitigation strategies once movement patterns are known.

http://www.bats.org.au/



16.11. Cumulative Impacts and Recommended Management

NSS is aware of 2 other WEF’s proposed for the north east KZN.

16.11.1 Cumulative impacts

The more wind turbines in the region, the more chance of disturbing bat foraging and roosting habitats and

causing large-scale fatalities.

Habitats such as wetlands, dams, pans, ridges, caves and forests should all be avoided to ensure that

minimal damage is done. Impacts to habitats may affect bats tens to hundreds of kilometres away from the

actual disturbance, as bats travel great distances in a night or in a season.

Bats also provide essential eco-system services such as pest control, pollination and seed dispersal and

contribute to biome functioning. The planned WEF’s are all located in vegetation units (Mucina &

Rutherford, 2006) with a Vulnerable to Endangered status.

16.11.2 Recommendations for reducing Cumulative Impacts

It is the intent of KZN Ezemvelo Wildlife’s IEM unit to initiate an internal workshop to determine how

Ezemvelo will move forward in terms of strategic planning for Renewable Energy in their province. Their

current view on this is that, as a principle, Ezemvelo takes a risk adverse approach (as per NEMA’s

Precautionary Principle) to any application that does not have sufficient or appropriate information, to

ensure that biodiversity is safeguarded. That is, one of the following would apply should insufficient or

questionable information be contained within an assessment (context dependant):

i) Request additional information or studies;

ii) Request an independent peer review (either by the applicant, authorising department or

ourselves – this would be dependent on the nature of the of information lacking or conclusions

drawn in the initial report);

iii) Recommend more stringent or cautious mitigatory measures; or

iv) Object to the application.

Significant bat fatalities from wind turbines may affect bat populations on a Local, Regional, as well as a

National Scale, due to migration. It is therefore important for the Department of Environmental Affairs,

together with Provincial Departments, to ensure the following:

KZN Ezemvelo Wildlife need to have discussions with DEA regarding Provincial planning in terms

of specific areas for WEF developments or specific No-Go areas.

Limit the number of wind turbines in sensitive areas, potentially making certain Eco-regions or

Biomes as No-Go areas for WEFs.

All pre- and post- construction monitoring to be conducted only by SACNASP accredited Zoologists

or Ecologists, with appropriate bat experience. The Department of Environmental Affairs together

with KZN Ezemvelo Wildlife should implement measures to restrict the development in sensitive

areas, monitor compliance, ensure best practice mitigation, and effective post-construction

monitoring to ensure that the bat populations in this area are protected.



That post-construction bat monitoring is conducted to determine the fatality rates at all WEF’s. This

should be intense for the first 2 years and less intense monitoring continuously throughout the life of

the WEF.

Have a monitoring and penalty process in place to ensure that WEF’s mitigate according to best

practice to ensure the protection of bat populations throughout the country.

richards bay wef - total species group d bat passes over ... bay wind energy project tk06.… ·...

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