BASIC ASSESSMENT REPORT FOR THE PROPOSED UPGRADING … · Erf 2452 and the Reminder of Erf 235, Glencairn Prepared for: Glencairn Hotel (Pty) Ltd ... Keywords Hotel, Glencairn, upgrade

BASIC ASSESSMENT REPORT FOR THE PROPOSED UPGRADING OF THE

GLENCAIRN HOTEL, GLENCAIRN

Erf 2452 and the Reminder of Erf 235, Glencairn

Prepared for: Glencairn Hotel (Pty) Ltd

Authority Ref: 16/3/3/1/A6/28/2020/18

SLR Project No: 720.02065.00001 Report No: 2 Revision No: 0 Month/Year: June 2018

SLR Consulting (South Africa) (Pty) Ltd

SLR Ref. 720. 02065.00001 Report No. 2

Proposed upgrading of the Glencairn Hotel Basic Assessment Report June 2018

DOCUMENT INFORMATION Title Basic Assessment Report for the proposed upgrading of the Glencairn

Hotel, Glencairn

Project Manager Ena de Villiers

Project Manager e-mail [email protected]

Authors Ena de Villiers

Reviewer Jonathan Crowther

Client Glencairn Hotel (Pty) Ltd

Date last printed 2018/06/27 07:15:00 AM

Date last saved 2018/06/27 07:15:00 AM

Comments

Keywords Hotel, Glencairn, upgrade

Project Number 720. 02065.00001

Report Number 2

Revision Number 0

Status Report for submission to the Department of Environmental Affairs and Development Planning for consideration and decision-making

Issue Date 28 June 2018 BASIS OF REPORT

This document has been prepared by an SLR Group company with reasonable skill, care and diligence, and taking account of the manpower, timescales and resources devoted to it by agreement with Glencairn Hotel (Pty) Ltd for part or all of the services it has been appointed by the Client to carry out. It is subject to the terms and conditions of that appointment.

SLR shall not be liable for the use of or reliance on any information, advice, recommendations and opinions in this document for any purpose by any person other than the Client. Reliance may be granted to a third party only in the event that SLR and the third party have executed a reliance agreement or collateral warranty.

Information reported herein may be based on the interpretation of public domain data collected by SLR, and/or information supplied by the Client and/or its other advisors and associates. These data have been accepted in good faith as being accurate and valid.

SLR disclaims any responsibility to the Client and others in respect of any matters outside the agreed scope of the work.

The copyright and intellectual property in all drawings, reports, specifications, bills of quantities, calculations and other information set out in this report remain vested in SLR unless the terms of appointment state otherwise.

This document may contain information of a specialised and/or highly technical nature and the Client is advised to seek clarification on any elements which may be unclear to it.

Information, advice, recommendations and opinions in this document should only be relied upon in the context of the whole document and any documents referenced explicitly herein and should then only be used within the context of the appointment.

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Proposed upgrading of the Glencairn Hotel: Basic Assessment Report June 2018

BASIC ASSESSMENT REPORT

BASIC ASSESSMENT REPORT IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 (ACT NO. 107 OF 1998) AND ENVIRONMENTAL IMPACT ASSESSMENT REGULATIONS, 2014 (AS AMENDED)

OCTOBER 2017

PROJECT TITLE PROPOSED UPGRADING OF THE GLENCAIRN HOTEL, GLENCAIRN

JUNE 2018

REPORT TYPE CATEGORY REPORT REFERENCE NUMBER DATE OF REPORT

Pre-Application Basic Assessment Report (if applicable)1 N/A N/A

Draft Basic Assessment Report2 16/3/3/1/A6/28/2020/18 9 April 2018

Final Basic Assessment Report3 or, if applicable Revised Basic Assessment Report4 (strikethrough what is not applicable)

16/3/3/1/A6/28/2020/18 27 June 2018

Notes: 1. In terms of Regulation 40(3) potential or registered interested and affected parties, including the Competent Authority, may

be provided with an opportunity to comment on the Basic Assessment Report prior to submission of the application but must again be provided an opportunity to comment on such reports once an application has been submitted to the Competent Authority. The Basic Assessment Report released for comment prior to submission of the application is referred to as the “Pre-Application Basic Assessment Report”. The Basic Assessment Report made available for comment after submission of the application is referred to as the “Draft Basic Assessment Report”. The Basic Assessment Report together with all the comments received on the report which is submitted to the Competent Authority for decision-making is referred to as the “Final Basic Assessment Report”.

2. In terms of Regulation 19(1)(b) if significant changes have been made or significant new information has been added to the

Draft Basic Assessment Report , which changes or information was not contained in the Draft Basic Assessment Report consulted on during the initial public participation process, then a Final Basic Assessment Report will not be submitted, but rather a “Revised Basic Assessment Report”, which must be subjected to another public participation process of at least 30 days, must be submitted to the Competent Authority together with all the comments received.

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DEPARTMENTAL REFERENCE NUMBER(S) Pre-application reference number: N/A File reference number (EIA): 16/3/3/1/A6/28/2020/18 NEAS reference number (EIA): N/A File reference number (Waste): N/A NEAS reference number (Waste): File reference number (Air Quality): N/A NEAS reference number (Air Quality): File reference number (Other): N/A NEAS reference number (Other):

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CONTENT AND GENERAL REQUIREMENTS Note that: 1. The content of the Department’s Circular EADP 0028/2014 (dated 9 December 2014) on the “One Environmental

Management System” and the Environmental Impact Assessment (“EIA”) Regulations, 2014 (as amended), any subsequent Circulars, and guidelines must be taken into account when completing this Basic Assessment Report Form.

2. This Basic Assessment Report is the standard report format which, in terms of Regulation 16(3) of the EIA Regulations, 2014 (as amended) must be used in all instances when preparing a Basic Assessment Report for Basic Assessment applications for an environmental authorisation in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998) (“NEMA”)and the EIA Regulations, 2014 (as amended) and/or a waste management licence in terms of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) (“NEM:WA”), and/or an atmospheric emission licence in terms of the National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) (“NEM:AQA”) when the Western Cape Government: Environmental Affairs and Development Planning (“DEA&DP”) is the Competent Authority/Licensing Authority.

3. This report form is current as of October 2017. It is the responsibility of the Applicant/ Environmental Assessment Practitioner (“EAP”) to ascertain whether subsequent versions of the report form have been released by the Department. Visit the Department’s website at http://www.westerncape.gov.za/eadp to check for the latest version of this checklist.

4. The required information must be typed within the spaces provided in the form. The size of the spaces provided is not necessarily indicative of the amount of information to be provided. The tables may be expanded where necessary.

5. The use of “not applicable” in the report must be done with circumspection. All applicable sections of this report form must be completed. Where “not applicable” is used, this may result in the refusal of the application.

6. While the different sections of the report form only provide space for provision of information related to one alternative, if more than one feasible and reasonable alternative is considered, the relevant section must be copied and completed for each alternative.

7. Unless protected by law, all information contained in, and attached to this report, will become public information on receipt by the competent authority. If information is not submitted with this report due to such information being protected by law, the applicant and/or EAP must declare such non-disclosure and provide the reasons for believing that the information is protected.

8. Unless otherwise indicated by the Department, one hard copy and one electronic copy of this report must be submitted to the Department at the postal address given below or by delivery thereof to the Registry Office of the Department. Reasonable access to copies of this report must be provided to the relevant Organs of State for consultation purposes, which may, if so indicated by the Department, include providing a printed copy to a specific Organ of State.

9. This Report must be submitted to the Department and the contact details for doing so are provided below. 10. Where this Department is also identified as the Licencing Authority to decide applications under NEM:WA or NEM:AQA, the

submission of the Report must also be made as follows, for- • Waste management licence applications, this report must also (i.e., another hard copy and electronic copy) be

submitted for the attention of the Department’s Waste Management Directorate (tel: 021 483 2756 and fax: 021 483 4425) at the same postal address as the Cape Town Office.

• Atmospheric emissions licence applications, this report must also be (i.e., another hard copy and electronic copy) submitted for the attention of the Licensing Authority or this Department’s Air Quality Management Directorate (tel: 021 483 2798 and fax: 021 483 3254) at the same postal address as the Cape Town Office.

DEPARTMENTAL DETAILS

CAPE TOWN OFFICE GEORGE REGIONAL OFFICE

REGION 1 (City of Cape Town & West Coast District)

REGION 2 (Cape Winelands District & Overberg District)

REGION 3 (Central Karoo District & Eden District)

Department of Environmental Affairs and Development Planning Attention: Directorate: Development Management (Region 1) Private Bag X 9086 Cape Town, 8000 Registry Office 1st Floor Utilitas Building 1 Dorp Street, Cape Town Queries should be directed to the Directorate: Development Management (Region 1) at: Tel.: (021) 483-5829 Fax: (021) 483-4372

Department of Environmental Affairs and Development Planning Attention: Directorate: Development Management (Region 2) Private Bag X 9086 Cape Town, 8000 Registry Office 1st Floor Utilitas Building 1 Dorp Street, Cape Town Queries should be directed to the Directorate: Development Management (Region 2) at: Tel.: (021) 483-5842 Fax: (021) 483-3633

Department of Environmental Affairs and Development Planning Attention: Directorate: Development Management (Region 3) Private Bag X 6509 George, 6530 Registry Office 4th Floor, York Park Building 93 York Street George Queries should be directed to the Directorate: Development Management (Region 3) at: Tel.: (044) 805-8600 Fax: (044) 805 8650

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TABLE OF CONTENTS

TABLE OF CONTENTS ............................................................................................................................... iv ACRONYMS AND ABBREVIATIONS ......................................................................................................... vi DETAILS OF THE APPLICANT ................................................................................................................. vii DETAILS OF ENVIRONMENTAL ASSESSMENT PRACTITIONER......................................................... vii EXECUTIVE SUMMARY ............................................................................................................................ viii SECTION A: PROJECT INFORMATION ..................................................................................................... 1

1. ACTIVITY LOCATION .............................................................................................................. 1 2. PROJECT DESCRIPTION ........................................................................................................ 1 3. PHYSICAL SIZE OF THE PROPOSED DEVELOPMENT ....................................................... 4 4. SITE ACCESS .......................................................................................................................... 5 5. DESCRIPTION OF THE PROPERTY(IES) ON WHICH THE LISTED ACTIVITY(IES)

ARE TO BE UNDERTAKEN AND THE LOCATION OF THE LISTED ACTIVITY(IES) ON THE PROPERTY ...................................................................................................................... 5

6. SITE PHOTOGRAPHS ............................................................................................................. 6 SECTION B: DESCRIPTION OF THE RECEIVING ENVIRONMENT ......................................................... 7

1. GRADIENT OF THE SITE ........................................................................................................ 7 2. LOCATION IN THE LANDSCAPE ............................................................................................ 7 3. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE ............................... 7 4. SURFACE WATER ................................................................................................................... 8 5. THE SEAFRONT / SEA ............................................................................................................ 8 6. BIODIVERSITY ......................................................................................................................... 9 7. LAND USE OF THE SITE ....................................................................................................... 11 8. LAND USE CHARACTER OF THE SURROUNDING AREA ................................................. 12 9. SOCIO-ECONOMIC ASPECTS .............................................................................................. 12 10. HISTORICAL AND CULTURAL ASPECTS ............................................................................ 13 11. APPLICABLE LEGISLATION, POLICIES, CIRCULARS AND/OR GUIDELINES .................. 14

SECTION C: PUBLIC PARTICIPATION .................................................................................................... 16 SECTION D: NEED AND DESIRABILITY .................................................................................................. 20 SECTION E: DETAILS OF ALL THE ALTERNATIVES CONSIDERED ................................................... 24

1. DETAILS OF THE IDENTIFIED AND CONSIDERED ALTERNATIVES AND INDICATE THOSE ALTERNATIVES THAT WERE FOUND TO BE FEASIBLE AND REASONABLE ... 24

2. PREFERRED ALTERNATIVE ................................................................................................ 28 SECTION F: ENVIRONMENTAL ASPECTS ASSOCIATED WITH THE ALTERNATIVES ..................... 29

1. DESCRIBE THE ENVIRONMENTAL ASPECTS ASSOCIATED WITH THE PROPOSED DEVELOPMENT AND ITS ALTERNATIVES, FOCUSING ON THE FOLLOWING: .............. 29

2. WASTE AND EMISSIONS ...................................................................................................... 30 3. WATER USE ........................................................................................................................... 32 4. POWER SUPPLY ................................................................................................................... 32 5. ENERGY EFFICIENCY .......................................................................................................... 32 6. TRANSPORT, TRAFFIC AND ACCESS ................................................................................ 33 7. NUISANCE FACTOR (NOISE, ODOUR, ETC.) ..................................................................... 33 8. OTHER .................................................................................................................................... 33

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SECTION G: IMPACT ASSESSMENT, IMPACT AVOIDANCE, MANAGEMENT, MITIGATION AND MONITORING MEASURES ................................................................................................. 35

1. METHODOLOGY USED IN DETERMINING AND RANKING ENVIRONMENTAL IMPACTS AND RISKS ASSOCIATED WITH THE ALTERNATIVES ..................................... 35

2. IDENTIFICATION, ASSESSMENT AND RANKING OF IMPACTS TO REACH THE PROPOSED ALTERNATIVES INCLUDING THE PREFERRED ALTERNATIVE WITHIN THE SITE ................................................................................................................................ 35

3. SPECIALIST INPUTS / STUDIES, FINDINGS AND RECOMMENDATIONS ........................ 48 4. ENVIRONMENTAL IMPACT STATEMENT ........................................................................... 50 5. IMPACT MANAGEMENT, MITIGATION AND MONITORING MEASURES .......................... 52

SECTION H: RECOMMENDATIONS OF THE EAP AND SPECIALISTS ................................................. 57 SECTION I: APPENDICES ......................................................................................................................... 59 SECTION J: DECLARATIONS ................................................................................................................... 60

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ACRONYMS AND ABBREVIATIONS Below a list of acronyms and abbreviations used in this report.

Acronyms / Abbreviations Definition

BAR Basic Assessment Report CBA Critical Biodiversity Area CoCT City of Cape Town DEA&DP Department of Environmental Affairs and Development Planning DWS Department of Water and Sanitation EAP Environmental Assessment Practitioner EIA Environmental Impact Assessment EIA Regulations 2014 Environmental Impact Assessment Regulations (GN R982 to R985 of 4 Dec 2014), as

amended EMP Environmental Management Programme ESA Ecological Support Area GNR Government Notice Regulation HWC Heritage Western Cape I&AP Interested and Affected Party mamsl Meters above mean sea level NEMA National Environmental Management Act, 1998 (No. 107 of 1998), as amended NID Notice of Intent to Develop

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DETAILS OF THE APPLICANT

Applicant / Organisation / Organ of State: Glencairn Hotel Proprietary Limited Contact person: Raymond Resnick Postal address: PO Box 44, Green Point, Cape Town

Telephone: - Postal Code: 8005 Cellular: 076 903 1111 Fax: -

E-mail: [email protected]

DETAILS OF ENVIRONMENTAL ASSESSMENT PRACTITIONER

Name of the EAP organisation: SLR Consulting (South Africa) (Pty) Ltd Person who compiled this Report: Jonathan Crowther / Ena de Villiers

EAP Reg. No.: CEAPSA Contact Person (if not author): Jonathan Crowther / Ena de Villiers

Postal address: PO Box 10145, Caledon Square Telephone: 021 461 1118 / 9 Postal Code: 7905

Cellular: 082 777 1477 Fax: 021 461 1120 E-mail: [email protected]

EAP Qualifications: Jonathan Crowther – M.Sc. (Environmental Science) Ena de Villiers – MA in Applied Ethics (Environmental Ethics)

Please provide details of the lead EAP, including details on the expertise of the lead EAP responsible for the Basic Assessment process. Also attach his/her Curriculum Vitae to this BAR.

Jonathan Crowther has been involved in environmental consulting since 1988 and is currently a Technical Director of SLR Consulting (South Africa) (Pty) Ltd. He has expertise in a wide range of environmental disciplines, including Environmental Impact Assessments (EIA), Environmental Management Plans/Programmes, Environmental Planning & Review, Environmental Control Officer services, and Public Consultation & Facilitation. He has project managed a number of offshore oil and gas EIAs for various exploration and production activities in South Africa and Namibia. He also has extensive experience in projects related to roads, property developments and landfill sites. His CV is presented in Appendix K1.

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EXECUTIVE SUMMARY 1. INTRODUCTION The Applicant, Glencairn Hotel (Pty) Ltd, the owner of Glencairn Hotel, is proposing to upgrade the hotel and to develop the remainder of the property (Erf 2454, Glencairn) for residential, retail and office use. It is also proposed to formalise and expand the existing parking area in front of the hotel on the Remainder of Erf 235. Glencairn Hotel (Pty) Ltd had previously obtained Environmental Authorisation (EA) for the proposed upgrading and expansion of the Glencairn Hotel (then called the Southern Right Hotel) in 2006. This was the culmination of an environmental scoping process that commenced in 2003 and concluded with the submission of a Scoping Report to the Department of Environmental Affairs and Development Planning (DEA&DP) in February 2005. After a final extension of the validity period (DEA&DP reference E12/2/3/6-A5/182-0252/10) the EA lapsed on 5 August 2011. While a new Application for EA is required in terms of the current environmental legislation, the concept design remains unchanged from the original proposal presented in the January 2005 Scoping Report.1 SLR Consulting (South Africa) (Pty) Ltd has been appointed as the independent environmental assessment practitioner responsible for undertaking the required environmental authorisation process for the proposed project. The Applicant subsequently commenced with a new application process in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (as amended) promulgated in terms of the National Environmental Management Act, 1998 (No. 107 of 1998) (NEMA). On 27 March 2017, an application to undertake a Basic Assessment process was submitted to DEA&DP. This Executive Summary provides a synopsis of the final Basic Assessment Report (BAR) prepared for the proposed project. The BAR has been compiled to assess the potential environmental impacts of the proposed project and as a basis to inform Interested and Affected Parties (I&APs) of the proposed project and to obtain their feedback. It should be noted that all significant changes to the BAR are underlined and in a different font (Times New Roman) in this final BAR. The BAR and Environmental Management Programme (EMP) was distributed for a 30-day public review and comment period from 12 April to 14 May 2018. Copies of the report were made available at the Simon’s Town Public Library; Cape Town offices of SLR; and on the following website: www.slrconsulting.com/za. After the conclusion of the comment period, all comments received were collated into two Comments and Responses Reports (one for authorities and one for other Interested and Affected Parties) and included in the final BAR, which has been prepared for submission to DEA&DP for consideration of the application. The comments were duly taken into consideration in the process of updating the draft BAR and the key issues have been incorporated into the final BAR. After DEA&DP has reached a decision, all registered I&APs will be notified of the outcome of the application and the reasons for the decision. A statutory Appeal Period in terms of the National Appeal Regulations, 2014 will follow the issuing of the decision.

1 A Scoping Report was required in terms of the relevant environmental legislation in 2005, while a Basic Assessment Report is

required in terms of the NEMA EIA Regulations 2014 (as amended), which are applicable to the current application.

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2. APPLICABILITY OF THE NEMA EIA REGULATIONS A Basic Assessment is required in terms of the Environmental Impact Assessment (EIA) Regulations 2014 (Government Notice (GN) No. R982, as amended), promulgated in terms of the National Environmental Management Act No. 107 of 1998 (NEMA), as amended, as the proposed project triggers the following listed activities in terms of Listing Notices 1 and 3 of the regulations:

Listing Notice 1 - GN No. R983 of 2014, as amended by GN No. 327 Project Description 19 The infilling or depositing of any material of more than 10 m³ into, or

the dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock of more than 10 m³ from a watercourse …

The excavation from and infilling of material into the Glencairnvlei would be required for the proposed rehabilitation of the banks of the vlei outlet.

19A. The infilling or depositing of any material of more than 5 m3 into, or the dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock of more than 5 m3 from— (ii) the littoral active zone, an estuary or a distance of 100 m

inland of the high-water mark of the sea or an estuary, whichever distance is the greater…

The above-mentioned excavation from and infilling of material into the Glencairnvlei outlet channel would occur within a distance of 100 m inland of the high-water mark of the sea.

Listing Notice 3 - GN No. R985 of 2014, as amended by GN No. 324 Project Description 12. The clearance of an area of 300 m2 or more of indigenous vegetation

except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan. (i) In Western Cape: i. Within any critically endangered or endangered ecosystem

listed in terms of section 52 of the NEMBA or prior to the publication of such a list, within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004.

ii. Within critical biodiversity areas identified in bioregional plans.

The proposed project would require the removal of more than 300 m2 of indigenous vegetation. The underlying vegetation type in the study area is Peninsula Sandstone Fynbos, which is listed as ‘Critically Endangered’ on a national basis. A small portion (approximately 5%) of the vegetation falls within a CBA 1b according to the City of Cape Town Biodiversity Network.

3. PROJECT BACKGROUND AND DESCRIPTION The Applicant, Glencairn Hotel (Pty) Ltd, is proposing to upgrade and expand the existing Glencairn Hotel (see Figure 1). The rationale for the proposed project is to further develop and improve the existing hotel complex in order to enhance this community node for local residents and visitors, and to provide additional retail, commercial and office space in the South Peninsula area. The proposed development site comprises two main properties, namely Erf 2454 (measuring approximately 8 444 m²), on which the hotel complex is located, and Erf 235 (measuring approximately 820 m²), which is situated in front of the hotel and used for parking purposes. The two erven are separated by Glen Road. The hotel site is situated between the single residential area of Cairnside, which extends up the mountain slope on the south side, and Glencairn on the north side. The site is accessed via Glen Road into Glencairn Road. Erf 235 borders on Glencairnvlei, which has an outlet channel under the M4 road bridge to the sea. The original Glencairn Hotel was erected in 1904 and is a well-known landmark in the area. The Applicant proposes to redevelop the existing hotel and to develop the remainder of Erf 2454 to a combination of residential, retail and office development in order to provide a range of functions. Existing structures fronting onto Glencairn Road would be demolished. A new accommodation wing, conference centre and a complex comprising a restaurant and bar, delicatessen, lifestyle square and office units would be constructed. Five single residential units would also be constructed along the south-western border of the property (see Figure 2). The Applicant further proposes to realign a portion of Glen Road in order to provide a single access road from Gardrum Steps on the north-western boundary of Erf 2454 to provide access to the back of the hotel. The proposed new road would also service the new hotel rooms, self-catering units and the single residential erven. The road would consist of a combination of paving and premixed surfaces, with barrier

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kerbs on either side due to the steepness of the site. Access to the undeveloped property located to the west of the site (above the upper boundary of the site along the mountainside) would still be provided off Gardrum Steps as is currently the case. In front of the hotel the existing parking area on Erf 235 would be formalised and expanded for the hotel and related activities. The proposal thus includes the provision of 68 parking bays in front of the hotel, i.e. 34 bays on each side of Glencairn Road. All new parking areas would be constructed using permeable surfaces, for example, interlocking concrete lattice-type structures with grass growing in-between. A 15 m buffer area would be maintained between the edge of the Glencairnvlei outlet and the adjacent parking area, where no hardened surfaces would be constructed. The various components of the proposed expansion are described in more detail below. It should, however, be noted that, while the areas and nature of the buildings would remain essentially the same as in the concept design, the sizes, numbers and internal configurations of buildings may change at the detailed design stage. • A new rear hotel wing and conference centre would comprise six self-catering suites; six en suite

hotel rooms on the ground floor; a conference centre/function venue around the swimming pool courtyard; and four retail kiosks in front of the hotel;

• Ten luxury two-bedroon apartments on terreaces, four with double garages and six with single garages;

• Six apartments and lifestyle square comprising four two-bedroom apartments; two two-bedroom apartments overlooking the square; and six to eight retail commercial units around a reduced square with a proposed focus on lifestyle-oriented activities (adventure, tourism, children, etc.); four to eight small offices for centre management, etc; and sixteen covered parking bays; and

• Five single residential units, each comprising a four-bedroom house and flatlet and double garage on an individual erf ranging in size between approximately 559 m² and 655 m².

The existing hotel is connected to a 200 mm sewer main. In addition, the proposed development would require a 160 mm main pipe with 100 mm house connections gravitating to the existing sewer main. A new water reticulation system would be provided in order to link the development with a bulk combination water meter. However, the single houses would have individual meters. Municipal services would be provided by the City of Cape Town. All roofs would be equipped with guttering leading into rainwater tanks, in order to store and use rainwater for irrigation and possibly for augmenting bulk water supply for use within the hotel and residential units for flushing toilets. In relation to stormwater management, measures to limit stormwater runoff as far as possible would be implemented. A permeable paving basin is planned for the parking along Glen Road, which will both detain and treat the stormwater to acceptable levels before discharge into the Glencairnvlei outlet channel. This basin would be unlined and would thus allow water infiltration into the ground. The viability of retaining accumulated stormwater runoff in (an) appropriate storage area(s) for recycling within the development would be investigated during the detailed design phase. The Applicant is also proposing to rehabilitate the banks of the Glencairnvlei adjacent to Erf 235 by reshaping banks, removing kikuyu and revegetating the vlei banks with suitable wetland plants. Constructing a boardwalk to the beach under the road bridge is considered, depending on negotiations with and approval from the City of Cape Town. The Applicant is fully aware of the responsibility for effective management of potential fire risk associated with the site due to the location adjacent to an undeveloped property. Thus preventative measures such as removing and controlling invasive alien vegetation growth on the site and creating and maintaining the fire break along the upper boundary are in place and receive ongoing attention. The fire break would be relocated beyond the site boundary in future in collaboration with the Cape Peninsula Fire Protection Association before the proposed residential erven are developed.

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4. AFFECTED ENVIRONMENT 4.1 BIOPHYSICAL ENVIRONMENT The project site is located at the foot of the Glencairn Mountain and abutting the Glencairnvlei where its channelized outlet flows via a bridge under the M4 to Glencairn Beach. Erf 2454 is located on a steep, north-facing slope, which flattens out at the current location of the hotel and its associated commercial buildings. The upper section of the erf is undeveloped and vegetated with a mix of indigenous and alien plant species and with numerous emergent sandstone boulders. A firebreak, from which vegetation is regularly cleared, runs along the upper south-western boundary of the erf. Erf 235 is relatively flat. Most of the erf is paved and used for parking space, while the remainder is covered with kikuyu grass. The site is located close the sea, but is separated from Glencairn Beach by the road (M4) and railway line. The only aquatic ecosystem of significance is the Glencairnvlei outlet channel adjacent to Erf 235, which is considered a perennial wetland, as part of the upstream vlei from which it is separated by a weir at the Glen Road Bridge. The Glencairnvlei outlet channel is currently choked by kikuyu grass, with some Typha capensis close to the Glen Road Bridge. The northern bank of the outlet channel slopes away from the wetted edge of the outlet at a fairly gentle gradient and becomes steeper towards the berm that separates the outlet from the M4. The berm is vegetated with typical coastal groundcover species. The southern bank is also steep as it slopes away from the water, and is covered largely by kikuyu grass. A stormwater outlet discharges stormwater from the hotel site and parking area into the outlet channel. The current ecological condition of the Glencairnvlei has been significantly impacted by alterations to the natural hydrological regime of the ecosystem. This is due to the impoundment and abstraction of water in the upper Else River catchment, with smaller weirs and causeways located along the length of the remaining river. The shape and alignment of the wetland channels have also been altered through limited infilling for the construction of bridges over the river, and encroachment of developed areas on either side of the vlei. Flow obstructions and abstraction also lead to the loss of flushing flows through the system, and the build-up of sediments. These existing impacts are reflected by the Present Ecological State (PES) scores calculated for Glencairnvlei, giving the wetland an overall PES of D, which is categorised as largely modified. The overall Ecological Importance and Sensitivity (EIS) of Glencairnvlei is rated as high, while the hydrological/functional importance is moderate and the human use rating is low. The latter is due to the fact that the vlei does not provide services of direct benefit to the surrounding communities, such as potable or irrigation water, harvestable resources or crops. The vlei does, however, provide an important feeding / breeding / migration node, in an increasingly urban area. While the species that the vlei supports are not necessarily rare or endangered, these species are important in terms of the overall biodiversity of the ecosystem. In addition, the vlei is sensitive to changes in low flows and water quality. The site is located within the mapped original extent of the Peninsula Sandstone Fynbos vegetation type, which is listed as Critically Endangered on a national basis. The botanical specialist confirmed that the vegetation of the site is predominately representative of Peninsula Sandstone Fynbos. It should be noted that the Critically Endangered status of the Peninsula Sandstone Fynbos vegetation type is based on the large number of localised and threatened plant species restricted to the vegetation type (D criterion) rather than on the percentage of habitat lost (A criterion). The vegetation type is exceptionally well conserved and little loss has occurred; approximately 95% of its total original extent still remains, with approximately 98% of its total extent conserved (mostly within the Table Mountain National Park), and a national conservation target of 30%. Overall, the remaining natural vegetation on site is generally in fairly good condition. Much of the site had been under dense rooikrans for many decades prior to clearing about fifteen years ago. The indigenous plant diversity on site has been lowered by an estimated 30% to 40% due to the previously dense canopy of rooikrans. No plant Species of Conservation Concern were observed in the study area. A small

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portion of the remaining natural vegetation (~ 5%) is mapped as a CBA 1b area, while the rest is considered Other Natural Vegetation in the City of Cape Town Biodiversity Network mapping. The most heavily disturbed parts of the site are in poor ecological condition, and it is likely that these have been subject to soil disturbance associated with adjacent development. These areas are also typically dominated by alien invasive grasses such as Pennisetum clandestinum (kikuyu), Avena (oats) and Lolium (ryegrass), with very few indigenous species. 4.2 CULTURAL HERITAGE ENVIRONMENT The original Glencairn Hotel was built in 1904, and is one of the oldest buildings in Glencairn. It is a historical monument. The hotel annex was built in 1930. Based on its historical importance within the local context of Glencairn, the hotel has been graded as a Grade 3 heritage resource. Within the Glencairn context it would rank as a Grade 3A heritage resource or Grade 3B in the context of the South Peninsula or Muizenberg-Simon's Town coastline. No significant archaeological material was found on site. 5. ENVIRONMENTAL IMPACT STATEMENT The proposed upgrading of the historic Glencairn Hotel would entail a number of positive long-term impacts which would be of benefit to the local and regional community. The proposed development of the hotel complex would contribute to the local and regional economy, resulting in an impact of LOW (POSITIVE) significance; and it would contribute to job security of the existing hotel work force and create additional jobs, an impact rated as of LOW (POSITIVE) significance. The most substantive potential impact of the proposed project is the heritage impact of altering the historic Glencairn Hotel that dates from 1904 and has been a landmark in the cultural environment of the South Peninsula for more than a century. The main focus had been avoidance of impacts by developing, through iterative interaction with HWC, an appropriate design that complies with heritage standards and requirements for the restoration and conservation of the historic Glencairn Hotel. The concept design generated and approved by HWC in 2004 was confirmed in January 2018. The project description proposed as the only feasible project alternative for this application adheres to the agreed concept design approved by HWC. The proposed project is thus acceptable from the heritage perspective. The potential visual impact of the proposed project is also an important aspect in the light of the scenic tourism value of the site in the context of its prominence along the Glencairn Mountain slope from the perspective of the coastal Main Road towards Simon’s Town. In this regard, the main focus had been to develop an appropriate design approach that would serve to avoid unacceptable visual effects and to alleviate the potential visual impacts as far as possible. Thus the potential visual impact has been addressed at the design phase by means of an appropriate design that is aligned to the heritage standards and requirements for upgrading the historic hotel building. The proposed mitigation measures would reduce the negative biophysical impacts to a VERY LOW to LOW significance during the construction and the operational phases. The potential negative impact of the proposed project on the Glencairnvlei outlet channel in the longer term during the operational phase could be effectively managed and monitored by the implementation of the Operational EMP. Summaries of the potential impacts associated with the operational phase and the design and development phase, respectively, as well as the relevant significance ratings, are presented in Tables 1 and 2 (overleaf).

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Table 1: Potential Impacts during the operational phase Impact Significance without mitigation Significance with mitigation

Ecological Aspects: Terrestrial vegetation – Loss of ecological connectivity Low LOW

Freshwater ecosystems – Decrease in water quality Low to Medium LOW Freshwater ecosystems – Changes in water inputs and flow patterns Low to Medium LOW

Freshwater ecosystems – Disturbance of flora and fauna Low VERY LOW

Freshwater ecosystems – Spread and establishment of alien invasive plants Medium VERY LOW

Socio-economic Aspects: Job security of existing labour force and additional job creation Medium (Positive) MEDIUM (POSITIVE)

Contribution to the local and regional economy Low (Positive) LOW (POSITIVE) Cultural-historical aspects:

Upgrading of the Glencairn Hotel High LOW Visual Medium MEDIUM Noise Low VERY LOW Table 2: Impacts during the development phase (all impacts are negative unless stated otherwise)

Impact Significance without mitigation Significance with mitigation Ecological Aspects:

Terrestrial vegetation – Loss of vegetation Low LOW Freshwater ecosystems – Loss of open space within the sub-catchment area Low LOW

Freshwater ecosystems – Destruction, deterioration or pollution of wetland habitat Low VERY LOW

Socio-economic Aspects: Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust, noise and visual Low VERY LOW T The No-Go Option would mean that the Glencairn Hotel would not be upgraded, which means that the development potential of the undeveloped portion of the site would not be unlocked in order to contribute to the local and regional economy. Additional recreational or social opportunities would not be provided for visitors and local residents. This alternative would adversely affect job security of the existing work force. It would not be possible to create the additional jobs envisaged during the construction phase of the proposed hotel upgrade. The creation of additional jobs envisaged as a result of the expansion of retail and commercial/office space would also not materialise. This option is also not considered acceptable from a heritage perspective as it would mean that the historical and cultural value of the hotel would not be enhanced as a result of its suitable restoration in accordance with heritage standards and requirements. The impact of implementing the No-Go option was rated of MEDIUM negative significance (see Table 3). The No-Go option is thus not considered to be a sustainable or desirable option. Table 3: Impacts associated with the No-Go Option

Impact Significance without mitigation Significance with mitigation Upgrading of the Glencairn Hotel Medium MEDIUM 6. RECOMMENDATIONS 6.1 RECOMMENDED IMPACT MANAGEMENT, MITIGATION AND MONITORING MEASURES 6.1.1 Design phase A number of mitigation measures relevant to the design phase have already been incorporated into the design proposed for implementation as the proposed project. Additional management, mitigation and

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monitoring measures are recommended for the design phase in order to avoid or minimise operational phase impacts before implementation of the proposed project. This includes the following: In relation to cultural-heritage aspects: • The main focus had been avoidance of impacts by developing, through iterative interaction with

HWC, an appropriate concept design that complies with heritage standards and requirements for the restoration and conservation of the historic Glencairn Hotel. The concept design is encapsulated in the project description.

• Do not deviate from the agreed concept design approved by HWC.

In relation to visual aspects: • The main focus had been to develop an appropriate design approach that would serve to avoid

unacceptable visual effects and to alleviate the potential visual impacts as far as possible. • This design approach entails the following:

o Fragmenting the proposed development into separate units of differing architectural design would reduce the overall sense of massing and lower the visual impact. The design approach was thus to avoid large, uniform, block-like built forms.

o The proposed development surrounding the hotel has been designed to create a backdrop that would emphasise the visual prominence of the existing historical buildings, comprising the hotel and annex, rather than to compete with it.

o Specific attention was paid to ways of emphasizing the historical heritage value of the hotel. o The building height would not extend higher up the mountain backdrop than existing houses in

Glencairn, and would be lower than neighbouring Cairnside to the south.

In relation to freshwater ecology: • No hardened surfaces or stormwater detention ponds may be constructed within the recommended

15 m buffer area from the edge of the Glencairnvlei outlet channel. • Construct roads, verges and parking areas with permeable materials, such as permeable paving,

grass blocks, interlocking blocks, etc. • Provide all roofs with adequate guttering leading into rainwater tanks, for storage and recycling of

rainwater. • Provide all remaining impermeable areas, as far as possible, with appropriate measures for reducing

the quantity of runoff leaving hardened surfaces and entering stormwater systems, namely: o Vegetated filter strips (broad, sloped vegetated areas that accept shallow runoff from hardened

surfaces); o Bioswales (landscaped areas designed to remove silt and pollutants from runoff, through

ensuring that water flows slowly along these gently sloping (<6% slope) features, often planted with grass or other plant species, mulch or riprap); and/or

o Bio-retention systems (vegetated areas where runoff is filtered through a filter media layer, e.g. sand, as it percolates downwards).

• Minimise the hardening of surfaces as far as possible and retain or create natural areas, gardens and road verges where water can filter into the ground.

• Investigate the viability of retaining accumulated stormwater runoff in (an) appropriate storage area(s) for recycling within the development.

6.1.2 Development phase Construction activities would be managed through effective implementation of a Construction Environmental Management Programme (EMP) for this project and thus the key recommendation is to comply with the Construction EMP. The following mitigation measures have been included in the Construction EMP:

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In relation to terrestrial vegetation: • Restrict all construction-related disturbance to the authorised development footprint, which should be

demarcated with coloured rope or fencing prior to any development on site. • Ensure that no heavy machinery or stored or dumped material impact on adjacent areas. • Plant Search and Rescue would not change the significance levels of vegetation loss, as all translocatable

species in the development footprint are well represented outside the footprint. In relation to freshwater ecology • Establish a 15 m buffer area around the edge of the Glencairnvlei outlet channel. • Ensure that all buildings and infrastructure are located outside of the vlei buffer area. • Store all building materials at least 15 m away from the edge of the wetland area, as demarcated prior

to construction. Storage areas must be bunded adequately to prevent contaminated runoff from entering the wetland.

• Material stockpiles should not exceed 1.5 m in height and should be protected from the wind (e.g. by shadecloth fences) to prevent spread of fine materials across the site.

• Re-plant all areas that are impacted by the storage of materials after construction is complete. • Construction close to the wetland (i.e. on Erf 235) must take place during the dry season, to reduce

the risks of contamination of the ecosystem through rainfall and runoff. • Concrete mixing must take place as far as possible way from the 15 m buffer area around the edge of

the Glencairnclei outlet channel. • Locate machinery prone to oil or fuel leakage at least 15 m away from the edge of the wetland, in an

area adequately bunded in order to contain leakages. • Use drip trays for water pumps and cement mixers to contain oil and fuel leaks. • Clean all drip trays regularly. • Provide suitable toilet and wash facilities to avoid the use of sensitive areas for these activities.

These service areas must be regularly maintained and toilets emptied on at least a weekly basis. • Route pathways and access roads around the wetland and its buffer area. • Clearly demarcate and fence off sensitive areas as no-go areas (using temporary fencing and danger

tape) before the start of any construction work or site preparation. • Direct lights (if used) away from the wetland. • Inspect the site for erosion damage during storm and heavy rain events. • Direct pumped water from construction areas (e.g. after rains) into a settlement area, and not directly

into the wetland. • Source top material from a reliable source, and check it for invasie alien plant seedlings before use. • Monitor the construction site constantly for alien plant growth and eradicate alien plant species. • A Rehabilitation Plan for the Glencairnvlei outlet must be prepared and submitted to the City of Cape Town for

approval, prior to works commencing. In relation to employment: • Employ local BEE services and providers and local labour from the local community as far as

possible. • Ensure appropriate training is provided, where required. In relation to control of dust, noise and visual disturbance to local residents: • Maintain all construction machinery and vehicles in good working order. • Be familiar with and adhere to, any local by-laws and regulations regarding the generation of noise

and hours of operation. • Avoid construction activities outside of “normal working hours”. • Ensure that the generation of dust is minimised and implement a dust control programme (e.g.

wetting of disturbed areas) to maintain a safe working environment and minimise nuisance for local residents and road users.

• Ensure that the exposed soil and material stockpiles are adequately protected against the wind. • Implement litter control measures and appropriate measures for visual screening.

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6.1.3 Operational Phase The following management, mitigation and monitoring measures are recommended for the operational phase: In relation to terrestrial vegetation: Utilise suitable locally indigenous plant species for any site landscaping, such as Salvia africana-lutea, Polygala myrtifolia, Watsonia borbonica, Helichrysum patulum, Leucadendron salignum, Chasmanthe aethiopica, Robsonodendron peragua, Thamnochortus spicigerus, Lampranthus emarginatus, Pelargonium capitatum, Pelargonium cucullatum, Othonna quinquedentata, Agathosma serpyllacea and Cineriaria geifolia. In relation to freshwater ecology: Potential impacts on the Glencairnvlei outlet channel would be managed and monitored through effective implementation of the Operational EMP for this purpose. Details regarding an appropriate rehabilitation and monitoring plan for the Glencairnvlei outlet channel are contained in the Operational EMP. The key recommendation is thus to comply with the Operational EMP. The following mitigation measures are also recommended for implementation during the operational phase: • Do not discharge stormwater directly into the wetland but manage it to flow along unlined swales,

permeable areas, bioswales and/or unlined detention ponds. • Ensure that lighting faces away from the wetland. • Discourage domestic pets from entering the wetland and its buffer, through the appropriate use of

fencing and gates. • Keep landscaping to a minimum. Gardens should rather be natural areas, where locally indigenous

vegetation is allowed to grow. • Do not allow any kikuyu grass anywhere on site. Use alternative grass species such as Cynodon

dactylon or Paspalum vaginatum. • Monitor and prevent the spread of alien plant species into all natural areas. • Monitor road verges for alien species, especially grasses. In relation to visual impacts: • Rehabilitate disturbed areas by means of appropriate landscaping to ensure that remaining open

spaces along the hillside blend visually with the surroundings. • Compile and submit a landscape plan for approval by the City of Cape Town prior to the commencement of

construction. o Undertake re-vegetation in accordance with the landscape plan. o Prior to site clearing or earthworks on the upper portions of Erf 2454, locally indigenous plants suitable for

reuse in landscaping should be “searched and rescued” from this area, by an appropriate specialist, in accordance with the landscape plan.

In relation to noise: • The hotel managment and staff and all business owners operating on the premises shall be familiar

with and adhere to, any local by-laws and regulations regarding the generation of noise and hours of operation.

• Strictly adhere to authorised hours of operation in accordance with operating licence(s). 6.2 CONDITIONS FOR INCLUSION IN AN ENVIRONMENTAL AUTHORISATION It has been recommended that the following measures should be considered for inclusion as conditions should environmental authorisation be granted:

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6.2.1 Development phase Construction activities would be managed through effective implementation of a Construction Environmental Management Programme (EMP) for this project and thus the key recommendation is to comply with the Construction EMP. This includes the appointment of an independent Environmental Control Officer to ensure compliance in this regard. 6.2.2 Operational Phase Potential operational phase impacts on the Glencairnvlei outlet channel would be managed and monitored through effective implementation of the Operational EMP for this purpose and thus the key recommendation is to comply with the Operational EMP.

Figure 1: Locality map (Google Earth image) of the proposed project site (orange outlines).

Remainder of Erf 235

Existing Glencairn Hotel

Erf 2454

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SLR Ref. 720. 02065.00001 Report No. 2 Proposed upgrading of the Glencairn Hotel: Basic Assessment Report June 2018

Figure 2: Site development plan showing the proposed upgrading of Glencairn Hotel (image provided by Glencairn Hotel (Pty) Ltd, March 2017)

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SECTION A: PROJECT INFORMATION 1. ACTIVITY LOCATION

Location of all proposed sites: Glencairn Hotel is located along Glencairn Road just off Glen Road and Main Road (M4) in Glencairn, Cape Town. The proposed site is located at the foot of the Glencairn Mountain close to Glencairn Beach (see Figures A1 and A2 in Appendix A).

Farm / Erf name(s) and number(s) (including Portions thereof) for each proposed site:

Erf 2454 and the Remainder of Erf 235, Glencairn.

Property size(s) in m2 for each proposed site:

Erf 2454: Approximately (~) 8 444 square metres (m²); and Erf 235: ~ 820 m²

Development footprint size(s) in m2:

Erf 2454: ~ 6 283 m²; and Erf 235: ~ 820 m².

Surveyor General (SG) 21 digit code for each proposed site:

Erf 2454: C01600540000245400000 Erf 235: C01600540000023500000RE

2. PROJECT DESCRIPTION

(a) Is the project a new development? If “NO”, explain: YES NO The proposed project would entail the upgrading of the existing Glencairn Hotel and the construction of new retail, residential and office facilities.

(b) Provide a detailed description of the scope of the proposed development (project):

The Applicant, Glencairn Hotel (Pty) Ltd, is proposing to upgrade and expand the existing Glencairn Hotel (see Figures A1 and A2 in Appendix A). The rationale for the proposed project is to further develop and improve the existing hotel complex in order to enhance this community node for local residents and visitors, and to provide additional retail, commercial and office space in the South Peninsula area. Glencairn Hotel (Pty) Ltd had previously obtained Environmental Authorisation (EA) for the proposed upgrading and expansion of the Glencairn Hotel (then called the Southern Right Hotel) in 2006. This was the culmination of an environmental scoping process that commenced in 2003 and concluded with the submission of a Scoping Report to the Department of Environmental Affairs and Development Planning (DEA&DP) in February 2005. After a final extension of the validity period (DEA&DP reference E12/2/3/6-A5/182-0252/10) the EA lapsed on 5 August 2011. While a new Application for EA is required in terms of the current environmental legislation, the concept design remains unchanged from the original proposal presented in the January 2005 Scoping Report.2 SLR Consulting (South Africa) (Pty) Ltd has been appointed as the independent environmental assessment practitioner responsible for undertaking the required environmental authorisation process for the proposed project. The proposed development site comprises two main properties, namely Erf 2454 (measuring approximately 8 444 m²), on which the hotel complex is located, and Erf 235 (measuring approximately 820 m²), which is situated in front of the hotel and used for parking purposes. The two erven are separated by Glen Road. The hotel site is situated between the single residential area of Cairnside, which extends up the mountain slope on the south side, and Glencairn on the north side. The site is accessed via Glen Road into Glencairn Road. Erf 235 borders on Glencairnvlei, which has an outlet channel under the M4 road bridge to the sea (see Section B(4) below for a detailed description of the freshwater feature). The original Glencairn Hotel was erected in 1904 and is a well-known landmark in the area. The Applicant

2 A Scoping Report was required in terms of the relevant environmental legislation in 2005, while a Basic Assessment Report is

required in terms of the NEMA EIA Regulations 2014 (as amended), which are applicable to the current application.


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proposes to redevelop the existing hotel and to develop the remainder of Erf 2454 to a combination of residential, retail and office development in order to provide a range of functions. Existing structures fronting onto Glencairn Road would be demolished. A new accommodation wing, conference centre and a complex comprising a restaurant and bar, delicatessen, lifestyle square and office units would be constructed. Five single residential units would also be constructed along the south-western border of the property (see Figures B1 to B4 in Appendix B). The Applicant further proposes to realign a portion of Glen Road in order to provide a single access road from Gardrum Steps on the north-western boundary of Erf 2454 to provide access to the back of the hotel. The proposed new road would also service the new hotel rooms, self-catering units and the single residential erven. The road would consist of a combination of paving and premixed surfaces, with barrier kerbs on either side due to the steepness of the site. In front of the hotel the existing parking area on Erf 235 would be formalised and expanded for the hotel and related activities. The proposal thus includes the provision of 68 parking bays in front of the hotel, i.e. 34 bays on each side of Glencairn Road. All new parking areas would be constructed using permeable surfaces, for example, interlocking concrete lattice-type structures with grass growing in-between. A 15 m buffer area would be maintained between the edge of the Glencairnvlei outlet and the adjacent parking area, where no hardened surfaces would be constructed. The various components of the proposed expansion are described in more detail below. It should, however, be noted that, while the areas and nature of the buildings would remain essentially the same as in the concept design, the sizes, numbers and internal configurations of buildings may change at the detailed design stage. • A new rear hotel wing and conference centre would comprise the following:

o Six self-catering suites (30 m² each); o Six en suite hotel rooms (30 m² each) on the ground floor; o A conference centre/function venue around the swimming pool courtyard; and o Four retail kiosks in front of the hotel (20 m² each).

• Ten luxury apartments, namely: o Four two-bedroom apartments (146 m² each) on terraces with a double garage each; and o Six two-bedroom apartments (98 m² each) on terraces with a single garage.

• Six apartments and lifestyle square comprising: o Four two-bedroom apartments (126 m² each); o Two two-bedroom apartments (110 m² each) overlooking the square; o Six to eight retail commercial units (total footprint 375 m²) around a reduced square with a proposed

focus on lifestyle-oriented activities (adventure, tourism, children, etc.); o Four to eight small offices for centre management, etc. (total 88 m²); and o Sixteen covered parking bays.

• Five single residential units: o Each unit would comprise a four-bedroom house (250 m²) and flatlet and double garage. The size of the

individual erven would range in size between approximately 559 m² and 655 m². The existing hotel is connected to a 200 mm sewer main. In addition, the proposed development would require a 160 mm main pipe with 100 mm house connections gravitating to the existing sewer main. A new water reticulation system would be provided in order to link the development with a bulk combination water meter. However, the single houses would have individual meters. Municipal services would be provided by the City of Cape Town. All roofs would be equipped with guttering leading into rainwater tanks, in order to store and use rainwater for irrigation and possibly for augmenting bulk water supply for use within the hotel and residential units for flushing toilets. In relation to stormwater management, measures to limit stormwater runoff as far as possible would be implemented. A permeable paving basin is planned for the parking along Glen Road, which will both detain and treat the stormwater to acceptable levels before discharge into the Glencairnvlei outlet channel. This basin would be unlined and would thus allow water infiltration into the ground. The viability of retaining accumulated stormwater runoff in (an) appropriate storage area(s) for recycling within the development would be investigated during the detailed design phase. The Applicant is also proposing to rehabilitate the banks of the Glencairnvlei adjacent to Erf 235 by reshaping


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banks, removing kikuyu and revegetating the vlei banks with suitable wetland plants. Constructing a boardwalk to the beach under the road bridge is considered, depending on negotiations with and approval from the City of Cape Town.

(c) Please indicate the following periods that are recommended for inclusion in the environmental

authorisation: (i) the period within which commencement must occur; Five years (ii) the period for which the environmental authorisation should be

granted and the date by which the activity must have been concluded, where the environmental authorisation does not include operational aspects;

N/A

(iii) the period that should be granted for the non-operational aspects of the environmental authorisation; and

Ten years for the completion of the project development phase.

(iv) the period that should be granted for the operational aspects of the environmental authorisation.

Until the hotel is decommissioned, which is not anticipated.

(d) List all the listed activities triggered and being applied for:

Listed Activity No(s):

Describe the relevant Basic Assessment Activity(ies) in writing as per Listing Notice 1 (GN No. R983 of 2014, as amended by GN No. 327)

Describe the portion of the development that relates to the applicable listed activity as per the project description.

Identify if the activity is development / development and operational / decommissioning / expansion / expansion and operational.

19. The infilling or depositing of any material of more than 10 cubic metres (m3) into, or the dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock of more than 10 m3 from a watercourse.

The excavation from and infilling of material into the Glencairnvlei outlet channel would be required for the proposed rehabilitation of the banks of the vlei outlet.

Development and operational.

19 A. The infilling or depositing of any material of more than 5 m3 into, or the dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock of more than 5 m3 from— (ii) the littoral active zone, an estuary

or a distance of 100 m inland of the high-water mark of the sea or an estuary, whichever distance is the greater…

The above-mentioned excavation from and infilling of material into the Glencairnvlei outlet channel would occur within a distance of 100 m inland of the high-water mark of the sea.

Development and operational.

Listed Activity No(s):

Describe the relevant Basic Assessment Activity(ies) in writing as per Listing Notice 3 (GN No. R985 of 2014, as amended by GN No. 324)

Describe the portion of the development that relates to the applicable listed activity as per the project description.

Identify if the activity is development / development and operational / decommissioning / expansion / expansion and operational.

12. The clearance of an area of 300 m2 or more of indigenous vegetation except where such clearance of indigenous vegetation is required for maintenance purposes undertaken in accordance with a maintenance management plan. (i) In Western Cape:

The proposed project would require the removal of more than 300 m2 of indigenous vegetation. The underlying vegetation type in the study area is Peninsula Sandstone Fynbos, which is listed as ‘Critically Endangered’ on a

Development


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iii. Within any critically endangered or endangered ecosystem listed in terms of section 52 of the NEMBA or prior to the publication of such a list, within an area that has been identified as critically endangered in the National Spatial Biodiversity Assessment 2004.

iv. Within critical biodiversity areas identified in bioregional plans.

national basis. A small portion (approximately 5%) of the vegetation falls within a CBA 1b according to the City of Cape Town Biodiversity Network.

(e) Provide details of all components (including associated structures and infrastructure) of the proposed

development and attach diagrams (e.g., architectural drawings or perspectives, engineering drawings, process flowcharts, etc.).

Buildings Provide brief description below: YES NO

Refer to Section A2(b) above for a description of the proposed project. Infrastructure (e.g., roads, power and water supply/ storage) Provide brief description below: YES NO

Refer to Section A2(b) above for a description of the proposed project. Processing activities (e.g., manufacturing, storage, distribution) Provide brief description below: YES NO

No processing activities will take place. Storage facilities for raw materials and products (e.g., volume and substances to be stored) Provide brief description below:

YES NO

No storing of raw materials will occur. Storage and treatment facilities for effluent, wastewater or sewage: Provide brief description below: YES NO

As indicated in Section A2(b) above, municipal services would be utilised. Storage and treatment of solid waste Provide brief description below: YES NO

Solid waste would not be treated on site. Storage of solid waste would entail temporary storage for short periods between regular collection time by service providers (municipal waste collection and limited use of private contractors). Facilities associated with the release of emissions or pollution. Provide brief description below: YES NO

The proposed project would not entail any facilities associated with the release of emissions or pollution. Other activities (e.g., water abstraction activities, crop planting activities) – Provide brief description below: YES NO

Other activities than those described in Section A2(b) above are not proposed.

3. PHYSICAL SIZE OF THE PROPOSED DEVELOPMENT

(a) Property size(s): Indicate the size of all the properties (cadastral units) on which the development proposal is to be undertaken

Erf 2454: 8444 m2 ; and Erf 235: 820 m2

(b) Size of the facility: Indicate the size of the facility where the development proposal is to be undertaken

Same as (a) above

(c) Development footprint: Indicate the area that will be physically altered as a result of undertaking any development proposal (i.e., the physical size of the development together with all its associated structures and infrastructure)

Erf 2454: ~ 6 283 m2; and Erf 235: ~ 820 m2


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(d) Size of the activity: Indicate the physical size (footprint) of the development proposal Same as (c) above.

(e) For linear development proposals: Indicate the length (L) and width (W) of the development proposal – Proposed new access road off Gardrum Steps to the back of the hotel, Note that the footprint of the proposed road section is included in the total development footprint provided in (c) above.

L: ~ 120 m

W: ~ 5 m

(f) For storage facilities: Indicate the volume of the storage facility N/A (g) For sewage/effluent treatment facilities: Indicate the volume of the

facility (Note: the maximum design capacity must be indicated) N/A

4. SITE ACCESS (a) Is there an existing access road? YES NO (b) If no, what is the distance in (m) over which a new access road will be built? N/A (c) Describe the type of access road planned:

Access to the site would continue to be taken off Glencairn Road via Glen Road. As mentioned above, the Applicant further proposes to realign a portion of Glen Road in order to provide a single access road on the north-western boundary of Erf 2454 from Gardrum Steps. The road would provide access to the rear of the hotel and retail component for delivery purposes and would service the new hotel rooms, self-catering units and the single residential erven. The position of the proposed road is indicated on the site development plan (see Figure B1 (Portion E) in Appendix B). Access to the undeveloped property located to the west of the site (above the upper boundary of the site along the mountainside) would still be provided off Gardrum Steps as is currently the case.

5. DESCRIPTION OF THE PROPERTY(IES) ON WHICH THE LISTED ACTIVITY(IES) ARE TO BE UNDERTAKEN AND THE LOCATION OF THE LISTED ACTIVITY(IES) ON THE PROPERTY

a) Provide a description of the property on which the listed activity(ies) is/are to be undertaken and the

location of the listed activity(ies) on the property, as well as of all alternative properties and locations (duplicate section below as required).

The site comprises two main properties, namely Erf 2454 and Erf 235, located at the foot of the Glencairn Mountain and abutting the Glencairnvlei where its channelized outlet flows via a bridge under the M4 to Glencairn Beach. Erf 2454 is located on a steep, north-facing slope, which flattens out at the current location of the hotel and its associated commercial buildings. The upper section of the erf is undeveloped and vegetated with a mix of indigenous and alien plant species and with numerous emergent sandstone boulders. A firebreak, from which vegetation is regularly cleared, runs along the upper south-western boundary of the erf. Erf 235, situated adjacent to Glencairnvlei, is relatively flat. Most of the erf is paved and used for parking space, while the remainder is covered with kikuyu grass.

Coordinates of all the proposed activities on the property or properties (sites):

Latitude (S): (deg.; min.; sec) Longitude (E): (deg.; min.; sec)

General centre point of Erf 2454 34o 0.9’ 38.67’ 18o 25’‘ 46.12”

General centre point of Erf 235 34o 0.9’ 36.86’ 18o 25’ 47.36”

b) Provide a description of the area where the aquatic or ocean-based activity(ies) is/are to be

undertaken and the location of the activity(ies) and alternative sites (if applicable). No aquatic or ocean-based activities would be undertaken.


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Coordinates of the boundary / perimeter of all proposed aquatic or ocean-based activities (sites) (if applicable): N/A

Latitude (S): (deg.; min.; sec) Longitude (E): (deg.; min.; sec)

c) For a linear development proposal, please provide a description and coordinates of the corridor in

which the proposed development will be undertaken (if applicable). As stated in Section A2(b) above, the Applicant proposes to realign a portion of Glen Road and to construct a single access road from Gardrum Steps (on the north-western boundary of Erf 2454) in order to provide access to the new development behind the hotel.

For linear activities: Latitude (S): (deg.; min.; sec) Longitude (E): (deg.; min.; sec) Starting point of the activity 34° 9' 37.13" 18° 25' 44.46" Middle point of the activity 34° 9' 38.84" 18° 25' 45.70" End point of the activity 34° 9' 40.02" 18° 25' 46.78"

d) Provide a location map (see below) as Appendix A to this report that shows the location of the

proposed development and associated structures and infrastructure on the property; as well as a detailed site development plan/site map (see below) as Appendix B to this report; and if applicable, all alternative properties and locations. The GIS shape files (.shp) for maps / site development plans must be included in the electronic copy of the report submitted to the competent authority.

Locality Map: See Figures A1 to A2 in Appendix A.

Site Plan: See Figures B1 to B5 in Appendix B.

6. SITE PHOTOGRAPHS Site photographs are presented in Appendix C.


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SECTION B: DESCRIPTION OF THE RECEIVING ENVIRONMENT

1. GRADIENT OF THE SITE Indicate the general gradient of the sites (highlight the appropriate box):

Flat Flatter than 1:10 1:10 – 1:4 Steeper than 1:4

2. LOCATION IN THE LANDSCAPE (a) Indicate the landform(s) that best describes the site (highlight the appropriate box(es):

Ridgeline Plateau Side slope of hill /

mountain Closed valley

Open valley

Plain Undulating

plain/low hills Dune

Sea-front

(b) Provide a description of the location in the landscape:

The site is located at the foot of the Glencairn Mountain just off the Main Road (M4). Erf 2454 is located on a steep north-facing slope which flattens out at the current location of the hotel and its associated commercial buildings whilst Erf 235 is essentially a flat area which borders on the Glencairnvlei outlet. The site is located close the sea, but is separated from Glencairn Beach by the road (M4) and railway line.

3. GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE (a) Is the site(s) located on or near any of the following (highlight the appropriate boxes)?

Shallow water table (less than 1.5 m deep) YES NO UNSURE Seasonally wet soils (often close to water bodies) YES NO UNSURE Unstable rocky slopes or steep slopes with loose soil YES NO UNSURE Dispersive soils (soils that dissolve in water) YES NO UNSURE Soils with high clay content YES NO UNSURE Any other unstable soil or geological feature YES NO UNSURE An area sensitive to erosion YES NO UNSURE An area adjacent to or above an aquifer. YES NO UNSURE An area within 100 m of a source of surface water YES NO UNSURE An area within 500 m of a wetland YES NO UNSURE An area within the 1:50 year flood zone YES NO UNSURE A water source subject to tidal influence YES NO UNSURE

(b) If any of the answers to the above is “YES” or “UNSURE”, specialist input may be requested by the

Department. (Information in respect of the above will often be available at the planning sections of local authorities. The 1:50 000 scale Regional Geotechnical Maps prepared by Geological Survey may also be used).

(c) Indicate the type of geological formation underlying the site:

Granite Shale Sandstone Quartzite Dolomite Dolorite Other

(describe) Provide a description: Numerous emergent sandstone boulders can be found around the study area. The soils are sandy and derived from the underlying Table Mountain Group sandstone bedrock, which is evident throughout the site, both as bedrock and as scree.


SLR Ref. 720. 02065.00001 Report No. 2


4. SURFACE WATER (a) Indicate the surface water present on and or adjacent to the site and alternative sites (highlight the

appropriate boxes)? Perennial River YES NO UNSURE Non-Perennial River YES NO UNSURE Permanent Wetland YES NO UNSURE Seasonal Wetland YES NO UNSURE Artificial Wetland YES NO UNSURE Estuarine / Lagoon YES NO UNSURE

(b) Provide a description:

The Glencairnvlei outlet channel to the east of the parking area on Erf 235 has been identified as the only aquatic ecosystem that may potentially be affected by the proposed project (see Figure D1 in Appendix D). Glencairnvlei is fed by the Else River, which rises as a seasonal stream between Grootkop and Red Hill approximately 7 km upstream of the site. It is a perennial wetland, with a weir (at the Glen Road Bridge) separating the vlei from its channelized estuarine outlet. A berm or causeway in the upper reaches separates the permanent open water section of the vlei from the more seasonally inundated lower reaches. The vlei has been identified as an important habitat for a number of waterbirds and semi-aquatic mammals such as otters. Although Glencairnvlei is, strictly speaking, an estuary, it has not been identified as such on the national list of estuaries. It has lost much of its estuarine nature due to the presence of the railway line, roads and the weir which have altered tidal exchange in the lower portion of the Else River. The freshwater ecosystem has thus been considered and assessed as a wetland, and Glencairnvlei is described as a channelled valley-bottom wetland. Until fairly recently, Glencairnvlei received treated effluent from the Simons Town Wastewater Treatment Facility, which resulted in increased flows in the lower river during the summer months, and poor water quality. The vlei is still eutrophic, with occasional outbreaks of blue-green algal blooms. The altered flow regime, poor water quality and control of water height by the weir and the causeway have resulted in the proliferation of dense stands of Typha capensis and Phragmites australis across the whole wetland, with only small patches of open water and other indigenous plant communities (e.g. Psoralea pinnata). The Glencairnvlei outlet channel is currently choked by kikuyu grass, with some Typha capensis close to the Glen Road Bridge. The northern bank of the outlet channel slopes away from the wetted edge of the outlet at a fairly gentle gradient and becomes steeper towards the berm that separates the outlet from the M4. The berm is vegetated with typical coastal groundcover species. The southern bank is also steep as it slopes away from the water, and is covered largely by kikuyu grass. A stormwater outlet discharges stormwater from the hotel site and parking area into the outlet channel.

5. THE SEAFRONT / SEA (a) Is the site(s) located within any of the following areas? (highlight the appropriate boxes). If the site or

alternative site is closer than 100 m to such an area, please provide the approximate distance in (m). An area within 100 m of the high water mark of the sea

YES NO UNSURE 80 – 90 m

An area within 100 m of the high water mark of an estuary/lagoon


An area within the littoral active zone YES NO UNSURE m An area in the coastal public property YES NO UNSURE m Major anthropogenic structures YES NO UNSURE m An area within a Coastal Protection Zone YES NO UNSURE m An area seaward of the coastal management line YES NO UNSURE m An area within the high risk zone (20 years) YES NO UNSURE m


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An area within the medium risk zone (50 years) YES NO UNSURE m An area within the low risk zone (100 years) YES NO UNSURE m An area below the 5 m contour YES NO UNSURE m An area within 1 km from the high water mark of the sea


A rocky beach YES NO UNSURE m A sandy beach YES NO UNSURE 70 – 80 m

NOTE: Although the property is located in close proximity to Glencairn Beach, there is an existing road and railway line which separates the hotel site from the beach. Hence, the actual site is not on the beach nor is there any direct link to the sea. The development would therefore not affect Glencairn Beach directly. (b) If any of the answers to the above is “YES” or “UNSURE”, specialist input may be requested by the

Department. (The 1:50 000 scale Regional Geotechnical Maps prepared by Geological Survey may also be used).

A freshwater impact assessment was undertaken and is attached as Appendix G2. 6. BIODIVERSITY Note: The Department may request specialist input/studies depending on the nature of the biodiversity occurring on the site and

potential impact(s) of the proposed development. To assist with the identification of the biodiversity occurring on site and the ecosystem status, consult http://bgis.sanbi.org or [email protected] . Information is also available on compact disc (“cd”) from the Biodiversity-GIS Unit, Tel.: (021) 799 8698. This information may be updated from time to time and it is the applicant/ EAP’s responsibility to ensure that the latest version is used. A map of the relevant biodiversity information (including an indication of the habitat conditions as per (b) below) must be provided as an overlay map on the property/site plan as Appendix D to this report.

See Figure D2 in Appendix D. (a) Highlight the applicable biodiversity planning categories of all areas on preferred and alternative sites

and indicate the reason(s) provided in the biodiversity plan for the selection of the specific area as part of the specific category. Also describe the prevailing level of protection of the Critical Biodiversity Area (“CBA”) and Ecological Support Area (“ESA”) (how many hectares / what percentages are formally protected).

Systematic Biodiversity Planning Category CBA ESA Other Natural

Area (“ONA”) No Natural Area

Remaining (“NNR”)

If CBA or ESA, indicate the reason(s) for its selection in biodiversity plan and the conservation management objectives

A small portion of the site (~5%) is located within CBA 1b due to the presence of Peninsula Sandstone Fynbos, which is listed as Critically Endangered on a national basis.

N/A The rest of the remaining natural vegetation is mapped as Other Natural Vegetation.

N/A

Describe the site’s CBA/ESA quantitative values (hectares/percentage) in relation to the prevailing level of protection of CBA and ESA (how many hectares / what percentages are formally protected locally and in the province)

Approximately 95% of the total original extent of Peninsula Sandstone Fynbos still remains, with ~ 98% of its total extent conserved (mostly within the Table Mountain National Park), and a national conservation target of 30%.

N/A Other Natural Vegetation is a relatively low ranking in the hierarchy, and is not a Critical Biodiversity Area.

N/A


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(b) Highlight and describe the habitat condition on site:

Habitat Condition

Percentage of habitat condition class (adding up to 100%) and area of each in m2

Description and additional comments and observations (including additional insight into condition)

Natural

~ 5% ~ 460 m2 A small portion of the remaining natural vegetation in good condition coincides with a CBA1b area.

Near Natural (includes areas with low to moderate level of alien invasive plants)

~ 20 % ~ 1 856 m2

Most of the remaining natural vegetation is in fairly good condition but indigenous plant diversity on site has been lowered due to previously dense invasive alien cover.

Degraded (includes areas heavily invaded by alien plants)

~ 25% ~ 2 316 m2

Disturbed areas of the site are in poor ecological condition, and are dominated by alien invasive grass species with very few indigenous species.

Transformed (includes cultivation, dams, urban, plantation, roads, etc.)

~ 50% ~ 4 632 m2 Transformed areas include the existing hotel buildings, roads, and parking facilities on Erf 253.

(c) Complete the table to indicate:

(i) the type of vegetation present on the site, including its ecosystem status; and (ii) whether an aquatic ecosystem is present on/or adjacent to the site.

Terrestrial Ecosystems Description of Ecosystem, Vegetation Type, Original Extent, Threshold (ha, %), Ecosystem Status

Ecosystem threat status as per the National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004)

Critically The vegetation type is Critically Endangered Peninsula Sandstone Fynbos.

Endangered Vulnerable Least Threatened

Aquatic Ecosystems Wetland (including rivers, depressions, channelled and unchannelled wetlands, flats, seeps pans, and artificial wetlands)

Estuary Coastline

YES NO Unsure YES NO YES NO (d) Provide a description of the vegetation type and/or aquatic ecosystem present on the site, including

any important biodiversity features/information identified on the site (e.g. threatened species and special habitats). Clearly describe the biodiversity targets and management objectives in this regard:

Vegetation type: The site is located within the mapped original extent of the Peninsula Sandstone Fynbos vegetation type, which is listed as Critically Endangered on a national basis. The botanical specialist confirmed that the vegetation of the site is predominately representative of Peninsula Sandstone Fynbos. It should be noted that the Critically Endangered status of the Peninsula Sandstone Fynbos vegetation type is based on the large number of localised and threatened plant species restricted to the vegetation type (D criterion) rather than on the percentage of habitat lost (A criterion). The vegetation type is exceptionally well conserved and little loss has occurred; approximately 95% of its total original extent still remains, with approximately 98% of its total extent conserved (mostly within the Table Mountain National Park), and a national conservation target of 30%. Overall, the remaining natural vegetation on site is generally in fairly good condition. Much of the site had been under dense rooikrans for many decades prior to clearing about fifteen years ago. The indigenous plant diversity on site has been lowered by an estimated 30% to 40% due to the previously dense canopy of rooikrans. No plant


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Species of Conservation Concern were observed in the study area. A small portion of the remaining natural vegetation (~ 5%) is mapped as a CBA 1b area, while the rest is considered Other Natural Vegetation in the City of Cape Town Biodiversity Network mapping. The most heavily disturbed parts of the site are in poor ecological condition, and it is likely that these have been subject to soil disturbance associated with adjacent development. These areas are also typically dominated by alien invasive grasses such as Pennisetum clandestinum (kikuyu), Avena (oats) and Lolium (ryegrass), with very few indigenous species. Aquatic Ecosystems: The only aquatic ecosystem of significance is the Glencairnvlei outlet channel adjacent to Erf 235, which is considered a perennial wetland, as part of the upstream vlei from which it is separated by a weir at the Glen Road Bridge. The current ecological condition of the Glencairnvlei has been significantly impacted by alterations to the natural hydrological regime of the ecosystem. This is due to the impoundment and abstraction of water in the upper Else River catchment, with smaller weirs and causeways located along the length of the remaining river. The shape and alignment of the wetland channels have also been altered through limited infilling for the construction of bridges over the river, and encroachment of developed areas on either side of the vlei. Flow obstructions and abstraction also lead to the loss of flushing flows through the system, and the build-up of sediments. These existing impacts are reflected by the Present Ecological State (PES) scores calculated for Glencairnvlei, giving the wetland an overall PES of D, which is categorised as largely modified. The overall Ecological Importance and Sensitivity (EIS) of Glencairnvlei is rated as high, while the hydrological/functional importance is moderate and the human use rating is low. The latter is due to the fact that the vlei does not provide services of direct benefit to the surrounding communities, such as potable or irrigation water, harvestable resources or crops. The vlei does, however, provide an important feeding / breeding / migration node, in an increasingly urban area. While the species that the vlei supports are not necessarily rare or endangered, these species are important in terms of the overall biodiversity of the ecosystem. In addition, the vlei is sensitive to changes in low flows and water quality.

7. LAND USE OF THE SITE (a) Highlight the current land uses and / or prominent features that occur at the site.

Untransformed area

Low density residential

Medium density residential

High density residential Informal

residential

Retail Commercial & warehousing

Light industrial Medium industrial Heavy industrial

Power station Office/consulting

room Military or police

base/station/compound Casino/entertainment

complex

Tourism and Hospitality facility

Open cast mine Underground mine Spoil heap or slimes dam Quarry, sand or borrow

pit Dam or reservoir

Hospital/medical centre

School Tertiary education facility Church Old age home

Sewage treatment plant

Train station or shunting yard

Railway line Major road (4 lanes and

more) Airport

Harbour Sport facilities Golf course Polo fields Filling station

Landfill or waste treatment site

Plantation Agriculture River, stream or

wetland Nature

conservation area Mountain, koppie

or ridge Museum Historical building Graveyard Archaeological

site

Other land uses (describe): Public road and parking facilities in front of the hotel


SLR Ref. 720. 02065.00001 Report No. 2


(a) Provide a description: The proposed site comprises an existing hotel and associated buildings and is located on Erf 2454 at the foot of the Glencairn Mountain just off the Main Road (M4). The area behind the hotel is undeveloped. The site is accessed via Glen Road into Glencairn Road, which is located to the east of and in front of the hotel. Erf 235, located at the front of the site between the hotel and the Glencairnvlei outlet channel; is used as parking space.

8. LAND USE CHARACTER OF THE SURROUNDING AREA (a) Highlight the current land uses and/or prominent features that occur within +/- 500m radius of the site

and neighbouring properties if these are located beyond 500m of the site: Untransformed

area Low density residential

Medium density residential

High density residential

Informal residential

Retail Commercial & warehousing Light industrial Medium industrial Heavy industrial

Power station Office/consulting

room Military or police

base/station/compound Casino/entertainment

complex Tourism and

Hospitality facility

Open cast mine Underground mine Spoil heap or slimes dam Quarry, sand or borrow

pit Dam or reservoir

Hospital/medical centre

School Tertiary education facility Church Old age home

Sewage treatment plant

Train station or shunting yard

Railway line Major road (4 lanes and more)

Airport

Harbour Sport facilities Golf course Polo fields Filling station

Landfill or waste treatment site

Plantation Agriculture River, stream or

wetland

Nature conservation

area Mountain, koppie

or ridge Museum Historical building Graveyard Archaeological

site

Other land uses (describe): Public roads and a public beach.

(b) Provide a description, including the distance and direction to the nearest residential area, industrial

area, agri-industrial area: The site is located between the single residential areas of Cairnside to the south-west and Glencairn to the north. Existing land uses surrounding the site comprise road and railway facilities, a perennial wetland (Glencairnvlei), Glencairn Beach. An undeveloped property to the west of the site is bordered by Table Mountain National Park. No industrial or agri-industrial areas are located in close proximity to the site.

9. SOCIO-ECONOMIC ASPECTS (a) Describe the existing social and economic characteristics of the community in the vicinity of the

proposed site, in order to provide baseline information (for example, population characteristics/demographics, level of education, the level of employment and unemployment in the area, available work force, seasonal migration patterns, major economic activities in the local municipality, gender aspects that might be of relevance to this project, etc.).

The site is located in Sub-district 4, the Far South, of the South Peninsula Planning District of the CoCT. This Sub-district includes all areas inside the urban edge from Noordhoek in the west and St James in the east, southwards to and including Scarborough and Simon’s Town. The South Peninsula District covers approximately 40 000 ha, approximately 38% of which falls within the Table Mountain National Park. In 2011, the population of the district numbered 319 040, an increase of 21% since 2001. According to the 2012


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Southern District Plan, approximately 9% of the City’s total population lives in the district. The average employment rate is the highest in the city at 88%. The district is characterised by predominately higher income residential and commercial development, thus high property prices make access to land and economic opportunities generally difficult for lower income groups. In 2011, the racial composition of the South Peninsula District population was as follows: Coloured (31%); Black African (24%); and White (40%). Of those aged 20 years and older, 60% have attained education levels of Grade 12 or higher education. Thirty (30) percent of households have a monthly income of R 3 200 or less. The position regarding dwelling status and household services is as follows: 87% of households live in formal dwellings; 93% of households have access to piped water in their dwelling or inside their yard; 94% of households have access to a flush toilet connected to the public sewer system; 97% of households have their refuse removed at least once a week; and 98% of households use electricity for lighting in their dwellings.

10. HISTORICAL AND CULTURAL ASPECTS (a) Please be advised that if section 38 of the NHRA is applicable to your proposed development, you are

requested to furnish this Department with written comment from Heritage Western Cape as part of your public participation process. Heritage Western Cape must be given an opportunity, together with the rest of the I&APs, to comment on any Pre-application BAR, a Draft BAR, and Revised BAR.

Is Section 38 of the NHRA applicable to the proposed development?

YES NO UNCERTAIN

If YES or UNCERTAIN, explain:

Section 38 (1)(c)(i) of the National Heritage Resources Act, 1999 (NHRA) is applicable because the proposed project would entail an activity exceeding 5 000 m² in extent in the form of the expansion of the hotel and associated infrastructure changes.

Will the development impact on any national estate referred to in Section 3(2) of the NHRA?

YES NO UNCERTAIN


N/A

Will any building or structure older than 60 years be affected in any way?

YES NO UNCERTAIN


Section 34 of the NHRA is applicable because the activity would entail the alteration of the Glencairn Hotel, which is older than 60 years.

Are there any signs of culturally or historically significant elements, as defined in section 2 of the NHRA, including Archaeological or palaeontological sites, on or close (within 20 m) to the site?

YES NO UNCERTAIN


The original Glencairn Hotel was built in 1904, and is one of the oldest buildings in Glencairn. It is a historical monument. The hotel annex was built in 1930. Based on its historical importance within the local context of Glencairn, the hotel has been graded as a Grade 3 heritage resource. Within the Glencairn context it would rank as a Grade 3A heritage resource or Grade 3B in the context of the South Peninsula or Muizenberg-Simon's Town coastline. No significant archaeological material was found on site. A Heritage Impact Assessment was undertaken in 2004 to obtain approval for the proposed project. Following an iterative process, which involved a heritage consultant, an architect and feedback from Heritage Western Cape (HWC) on previous sets of designs, HWC approved the preferred development option. A Notice of Intent to Develop (NID) regarding the proposed project, with the relevant previous documentation summarised and the specialist reports attached, was submitted to HWC on 23 January 2018 to obtain confirmation that this decision still applies. A


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copy of the relevant documentation submitted to HWC is appended for information purposes (see Appendix E1). On 26 January 2018 HWC notified the Applicant that, since there is no reason to believe that the proposed mixed use development will impact on heritage resources, no further action is required in terms of Section 38 of the NHRA (see Appendix E2).

11. APPLICABLE LEGISLATION, POLICIES, CIRCULARS AND/OR GUIDELINES (a) Identify all legislation, policies, plans, guidelines, spatial tools, municipal development planning

frameworks, and instruments that are applicable to the development proposal and associated listed activity(ies) being applied for and that have been considered in the preparation of the BAR:

Legislation, policies, plans, guidelines,

spatial tools, municipal

development planning frameworks, and

instruments

ADMINISTERING AUTHORITY

and how it is relevant to this application

TYPE Permit/license/authorisation/comment / relevant consideration (e.g. rezoning or

consent use, building plan approval, Water Use License and/or General Authorisation, License in terms of the SAHRA and CARA,

coastal discharge permit, etc.)

DTE (if already obtained):

National Environmental Management Act, 1998 (Act No. 107 of 1998), as amended (NEMA) & EIA Regulations 2014, as amended on 7 April 2017

DEA&DP Environmental Authorisation N/A

National Heritage Resources Act, 1999 (NHRA)

HWC Authorisation/comment 26 January 2018

National Water Act, 1998 (Act No. 36 of 1998) (NWA)

Department of Water and Sanitation (DWS)

Confirmation of general authorisation for and registration of relevant water uses.

N/A

Circular: EADP 0028/2014 on the “One Environmental Management System” and the EIA Regulations, 2014 (as amended).

DEA&DP Guideline on applications that must be submitted in terms of the EIA Regulations, 2014 (as amended).

N/A

Western Cape Provincial Spatial Development Framework (2014)

DEA&DP Provincial policies regarding land use, infrastructure development and the protection of environmental, socio-economic and cultural and heritage resources.

N/A

Cape Town Spatial Development Framework (2018)

CoCT Overarching metropolitan spatial development policies and priorities.

N/A

CoCT Integrated Development Plan (2012-2017)

CoCT Overarching metropolitan development policies and priorities.

N/A

CoCT: Southern District Plan (2012)

CoCT Local policies and planning regarding land use, infrastructure development and the protection of environmental, socio-economic and cultural and heritage resources.

N/A


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(b) Describe how the proposed development complies with and responds to the legislation and policy context, plans, guidelines, spatial tools, municipal development planning frameworks and instruments:

Legislation, policies, plans, guidelines,

spatial tools, municipal

development planning frameworks, and

instruments

Describe how the proposed development complies with and responds:

NEMA EIA Regulations 2014, as amended

This BAR was compiled in terms of the NEMA EIA Regulations of 2014, as amended and adheres to the applicable requirements.

NHRA A Notice of Intent to Develop (NID) regarding the proposed project was submitted to HWC. Refer to Section B9 above for more detail in this regard.

NWA Authorisation is required for the relevant water use activities relating to the proposed project, namely: • Section 21(c): Impeding or diverting the flow of water in a watercourse; and • Section 21(i): Altering the bed, banks, course or characteristics of a watercourse. The risk assessment matrix completed as part of the freshwater specialist study indicated that General Authorisation in terms of GN 509 of 2016 would apply, thus application for registration of the above water uses will be submitted to DWS.

Circular: EADP 0028/2014 - “One Environmental Management System” and the EIA Regulations 2014 (as amended).

The Basic Assessment process complies with the requirements of the EIA Regulations 2014 (as amended).

Western Cape PSDF (2014)

The proposed project is in line with the provincial policies regarding land use, infrastructure development and the protection of environmental, socio-economic and cultural and heritage resources – see Section D 2(a).

CoCT Integrated Development Plan (2012-2017)

The proposed project is in line with the overarching metropolitan development policies and priorities – see Section D(c).

CoCT: Southern District Plan (2012)

The proposed project is in line with the local policies and planning regarding land use, infrastructure development and the protection of environmental, socio-economic and cultural and heritage resources – see Section D2(d).

Note: Copies of any comments, permit(s) or licences received from any other Organ of State must be attached to this report as Appendix E.


SLR Ref. 720. 02065.00001 Report No. 2


SECTION C: PUBLIC PARTICIPATION 1. Please highlight the appropriate box to indicate whether the specific requirement was undertaken or

whether there was an exemption applied for. In terms of Regulation 41 of the EIA Regulations, 2014 (as amended) - (a) fixing a notice board at a place conspicuous to and accessible by the public at the boundary, on the

fence or along the corridor of - (i) the site where the activity to which the application

relates, is or is to be undertaken; and YES EXEMPTION

(ii) any alternative site YES EXEMPTION N/A (b) giving written notice, in any manner provided for in Section 47D of the NEMA, to –

(i) the occupiers of the site and, if the applicant is not the owner or person in control of the site on which the activity is to be undertaken, the owner or person in control of the site where the activity is or is to be undertaken or to any alternative site where the activity is to be undertaken;

YES EXEMPTION N/A

(ii) owners, persons in control of, and occupiers of land adjacent to the site where the activity is or is to be undertaken or to any alternative site where the activity is to be undertaken;

YES EXEMPTION

(iii) the municipal councillor of the ward in which the site or alternative site is situated and any organisation of ratepayers that represent the community in the area;

YES EXEMPTION

(iv) the municipality (Local and District Municipality) which has jurisdiction in the area; YES EXEMPTION

(v) any organ of state having jurisdiction in respect of any aspect of the activity; and YES EXEMPTION

(vi) any other party as required by the Department; YES EXEMPTION N/A (c) placing an advertisement in -

(i) one local newspaper; or YES EXEMPTION (ii) any official Gazette that is published specifically for

the purpose of providing public notice of applications or other submissions made in terms of these Regulations;

YES EXEMPTION N/A

(d) placing an advertisement in at least one provincial newspaper or national newspaper, if the activity has or may have an impact that extends beyond the boundaries of the metropolitan or district municipality in which it is or will be undertaken

YES EXEMPTION N/A

(e) using reasonable alternative methods, as agreed to by the Department, in those instances where a person is desirous of but unable to participate in the process due to—

YES EXEMPTION N/A

If you have indicated that “EXEMPTION” is applicable to any of the above, proof of the exemption decision must be appended to this report. Please note that for the NEM: WA and NEM: AQA, a notice must be placed in at least two newspapers circulating in the area where the activity applied for is proposed. If applicable, has/will an advertisement be placed in at least two newspapers? YES NO N/A

If “NO”, then proof of the exemption decision must be appended to this report. DESCRIPTION OF PUBLIC PARTICIPATION PROCESS

An Application for Environmental Authorisation for the proposed project was submitted to DEA&DP on 27 March 2018. The prescribed public participation process is being undertaken in respect to the Basic Assessment (BA) process, whereafter the final Basic Assessment Report (BAR) was submitted to DEA&DP.

Tasks undertaken to date to ensure adequate public consultation during the Basic Assessment included the following: • A preliminary Interested and Affected Party (I&AP) database was compiled consisting of landowners,


SLR Ref. 720. 02065.00001 Report No. 2


authorities (local, regional and national, as applicable), Non-Governmental Organisations, Community-based Organisations and other key stakeholders. This database was compiled using databases from previous projects undertaken in the broader study area. The 35 I&APs initially registered on the project database has increased to 61 I&APs during the public participation process (see Appendix F1).

• An advertisement (in English) was placed in a local newspaper, the False Bay Echo on 12 April 2018 (see Appendix F2).

• A site notice was erected at the entrance to the Glencairn Hotel and two copies of the notice were also displayed in the hotel reception area (see Figures F2.1 and F2.2 in Appendix F2).

• A notification letter was sent to all registered I&APs on the project database to inform them of the NEMA EIA Regulations 2014 (as amended) compliance process. The letter also announced the availability of the BAR for a 30-day public review and comment period and invited IA&Ps to submit comments on any aspect of the Basic Assessment process and the proposed project (see Appendix F3).

• A “knock-and-drop” was conducted on 12 April 2018 in order to inform residents of the area of the Basic Assessment process. Copies of the notification letter and Executive Summary of the BAR were deposited into the mailboxes of properties in the vicinity of Glencairn Hotel. A map providing details of the route covered is provided as Figure F3.1 in Appendix F3 .

• The draft BAR was distributed for a 30-day review and comment period from 12 April 2018 to 14 May 2018 (including extra days to cover the intervening public holidays) in order to provide I&APs and authorities with an opportunity to comment on any aspect of the BA process and the proposed project.

• Copies of the full report were made available at the Simon’s Town Public Library and at the offices and on the website of SLR.

• Copies of the BAR were provided to representatives of the relevant Organs of State for their review and comment (see Appendix F3).

• A copy of the BAR was also submitted to DEA&DP to request their comment as required in terms of Regulations 32(a)(aa) and (bb) and 40(3) of the EIA Regualtions 2014 (as amended).

• An information session was held on 31 May 2018 at Glencairn Hotel in response to a request received in this regard. Notification of the session was distributed to I&APs on the project database on 21 May 2018. The I&AP who had requested the session also arranged for further distribution of the notification by means of various electronic networks active in the area. Twenty (20) I&APs attended the information session, which provided the opportunity to engage with a representative of the Applicant. Proof of distribution of the notification as well as notes on the proceedings are appended to the final BAR (see Appendix F4).

• A total of ten written responses to the draft BAR were submitted, six of which were from representatives of authorities (including from DEA&DP) and four from other I&APs. The comments have been collated and responded to in two BAR Comments and Responses Reports, one for Authorities and one for I&APs, and have been appended to this final BAR (see Appendices F5 and F6). The comments were duly taken into consideration in the process of updating the draft BAR and the key issues have been incorporated into the final BAR.

• This final BAR has been prepared for submission to DEA&DP for consideration and decision-making. • Registered I&APs will be notified that a copy of the final BAR has been made available for information purposes on the

SLR website. After DEA&DP has reached a decision, all registered I&APs will be notified of the outcome of the application and the reasons for the decision. A statutory Appeal Period in terms of the National Appeal Regulations, 2014 will follow the issuing of the decision.

2. Provide a list of all the State Departments and Organs of State that were consulted:

State Department / Organ of State

Date request was sent: Date comment received: Support / not in support

CapeNature 12 April 2018 16 May 2018 Does not object City of Cape Town 12 April 2018 11 May 2018 Support from most departments Department of Water and Sanitation

12 April 2018 19 April 2018 No specific indication

SANParks: Table Mountain National Park

12 April 2018 14 May 2018 No specific indication


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Western Cape Government: Heritage Western Cape

NID submitted on 23 January 2018

26 January 2018 Support

3. Provide a summary of the issues raised by I&APs and an indication of the manner in which the issues

were incorporated, or the reasons for not including them. (The detailed outcomes of this process, including copies of the supporting documents and inputs must be included in a Comments and Response Report to be attached to the BAR (see note below) as Appendix F).

Commenting authorities raised the following key issues in response to the draft BAR (see Appendix F4 for details of the comments and responses thereto): • Stormwater management: Various aspects regarding stormwater management were addressed in comments, including the

implications of development along a steep slope, potential impact on Glencairnvlei and details regarding the stormwater management plan. The project description has been amended to provide more details (see Section A2). More details regarding the conceptual design for stormwater management measures have also been included in the description of alternatives (see Section E1(d)).

• Fire risk management: A number of respondents stated concern regarding the potential fire risk associated with the site’s location along the mountainside adjacent to an undeveloped property with a high fuel load due to invasive alien vegetation infestation. The Final BAR was amended to include a discussion of the issue (see Section F8) and a section on the management of fire risk was included in the Operational Environmental Management Plan (EMP) as recommended by the City of Cape Town (see Appendix H2).

• The City of Cape Town recommended detail amendments to the Construction EMP, which were incorporated into the document (see Appendix H1)

• DWS confirmed the applicability of Section 21(c) and (i) water uses and indicated the process to be undertaken to submit a Water Use Authorisation application. The latter process has been initiated on behalf of the Applicant and proof in this regard included in the Final BAR (see Appendix E4).

• The submissions received addressed a range of issues which have already been incorporated into the BAR and supporting documentation. Relevant comments were provided in the detailed Comments and Responses Report (see Appendix F4).

I&APs raised the following key issues and concerns (see Appendix F5 for details of the comments and responses thereto): • A request for an information session to provide more detailed information on the proposed project to the Glencairn

community was accommodated by holding such a session on 31 May 2018 at the Glencairn Hotel (see Section C1 above and Appendix F4)

• The potential impact on the Glencairnvlei, including the implementation of the recommended 15 m buffer area and stormwater management has been addressed by amending the Final BAR as mentioned previously.

• The adequacy of parking provision was questioned. The number of parking bays proposed is deemed sufficient as it was based on traffic specialist input in accordance with municipal requirements in this regard.

• Relevant comments have been provided in response to individual requests in the detailed Comments and Responses Report (see Appendix F4).

4. Provide a summary of any conditional aspects identified / highlighted by any Organs of State, which

have jurisdiction in respect of any aspect of the relevant activity. HWC’s confirmation of its 2004 approval of the preferred development option entails that the conditions stated in the original decision applies to this application. Thus the condition that any deviation from the plans to which the HWC approval refers would require re-application from HWC remains valid (refer to Section B10(a) of the BAR for detail in this regard). The Department of Water and Sanitation (DWS) stated that the Applicant must apply for and obtain a Water Use Authorisation prior to commencing with any of the proposed activities. Additional conditional aspects highlighted in their comments include the following: • Confirmation of adequate water supply and sanitation capacity for the proposed facility from the City of Cape Town

Municipality must be provided in writing as part of the water use authorisation application. • No abstraction of surface or groundwater may be done without prior authorisation from DWS, unless it is a Schedule 1

Use or an Existing Lawful Use. • No pollution of surface water or groundwater resources may occur due to any activity on the property.


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• Measures to control illegal dumping of construction waste must be in place as this may result in pollution to the surface water run-off.

• All the requirements of the National Water Act, 1998 regarding water use and pollution management must be adhered to at all times.

The City of Cape Town stated the following conditions: • The Applicant is required to otain Environmental Authorisation from DEA&DP and authorisation from HWC prior to

acting on the existing planing approval for rezoning to subdivisional area • The Environetmanl Management Department: Environmental Management Section – District H (EMS) stated support for

the Preferred Alternative option if the follwing mitigation measures are implemented: o A detailed landscape plan for all “open” areas including external road verges, the surrounding parking area and the

Glencairnvlei outlet must be submitted to the Environmental Management Section (EMS) and approved before building plan appoval.

o A rehabilitation plan for the Glencairnvlei outlet must be prepared and submitted to EMS and City Parks for approval prior to the works commencing.

o In respect to the Construction Environmental Management Programme (CEMP) The CEMP must take into account all mitigation measures identified in the ecological freshwater report

(December 2017). ECO report must be circulated to EMS. A method statement must be drafted for water use management for both potable and non-potabale water. The CEMP must specify to which entity penalties as a result of non-compliance must be paid and for what

purpose they will be used. The Water Services Branch must also be contacted regarding water use aspects of the project. Contacts for assistance with handling any venomous snakes must be included in the CEMP.

o In respect to the Operational Environmental Management Plan (OEMP) The OEMP must take into account all mitigation measures identified in the ecological freshwater report

(December 2017). The OEMP must include a section on veldfie management.

• A Stormwater Management Plan must be submitted to the Catchment, Stormwater and River Management Office detailing how the requirement for water quality will be met as per the requirement of the Management of Urban Stormwater Impacts Policy.

• Engineering design drawings outlining the proposed diversion of the existing watermain must be submitted to the District 1 Water Section Office for approval prior to construction commencing.

SANParks: TMNP indicated that potential visual impact of the proposed project should be adequately assessed and that the issue of fire management should receive more attention. CapeNature stated in conclusion that … “there are further concerns to be addressed regarding the fire management, stormwater management and steep slope mitigation for the development proposal. Should these be adequately addressed, CapeNature does not object to the proposed development”. It should be noted that the above matters have been raised in the comments submitted by the various authorities. Details regarding relevant responses are available in the BAR Comments and Responses Report appended to this BAR (see Appendix F5).


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SECTION D: NEED AND DESIRABILITY

1. Is the activity permitted in terms of the property’s existing land use rights? YES NO Please explain

The re-zoning of Erf 2454 from Undetermined to Subdivisional Area for Business, General Residential, Single Residential and Private Road purposes was approved on 3 September 2015, with a validity period of five years (until 2020). 2. Will the activity be in line with the following?

(a) Provincial Spatial Development Framework (PSDF) YES NO Please explain The Western Cape PSDF (March 2014) sets out the key spatial challenges faced by the Province and the proposed spatial policies which have been formulated to address these challenges. Spatial Policy S1 entails the promotion of “smart growth ensuring the efficient use of land and infrastructure by containing urban sprawl and prioritising infill … within settlements”. As the proposed subdivision and future re-development of the Glencairn Hotel site on the subdivided portions would lead to infill development within an existing residential area, the proposed project is considered to be consistent with Spatial Policy S1 of the PSDF. (b) Urban edge / edge of built environment for the area. YES NO Please explain The subject property falls within the urban edge boundary as defined by the 2012 Southern District Plan and would support an appropriate land use for the site. (c) Integrated Development Plan and Spatial Development

Framework of the Local Municipality (e.g., would the approval of this application compromise the integrity of the existing approved and credible municipal IDP and SDF?).

YES NO Please explain

Given that the proposed project is of small scale, it is not specifically addressed in the City of Cape Town’s five-year Integrated Development Plan (IDP). The IDP sets out the vision of the City of Cape Town, which includes creating an enabling environment for economic growth and job creation. The proposed project would contribute to the local and regional economy and create additional job opportunities during the construction and operational phases. The proposed development is not considered to be inconsistent with the IDP. The Southern District Plan (2012) is one of the eight plans developed for each of the planning districts of the City of Cape Town and is informed by the city-wide Cape Town Spatial Development Framework (CTSDF). The District Plan gives effect to the key spatial strategies proposed by the Cape Town Spatial Development Framework at a district scale. Strategy 2 of the plan relates to the management of urban growth and creating a balance between urban development and environmental protection. This strategy focuses on managing the pressures of urbanisation in a deliberate and coordinated manner. The plan notes that urban development should occur as a priority within the existing footprint of the district (i.e. through the development of underutilised infill sites). As the proposed project would promote infill development within an existing residential area, it is considered to be consistent with the SDF. The proposed development and improvement of Glencairn Hotel as an existing community node and the provision of additional retail, commercial and office space in the South Peninsula area would further contribute to the management of urban growth – providing resources and facilities to local communities would limit the need for frequent travel to denser city nodes. (d) An Environmental Management Framework (“EMF”) adopted by

this Department. (e.g., Would the approval of this application compromise the integrity of the existing environmental management priorities for the area and if so, can it be justified in terms of sustainability considerations?)


The Southern District Plan provides the Environmental Impact Management Zones (EIMZ) which must be considered in planning, development and environmental and land management decisions for the district. The District Plan provides the environmental management guidelines for each management zone. The identified EIMZ are as follows: • Hydrological Zone; • Coastal and Dune Zone; • Conservation and Biodiversity Priority Zone; • Cultural and Recreational Resources Zone; • Natural Economic Resources Zone; and


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• Urban Uses and Utilities Zone. Of particular relevance to this development is the Urban Uses and Utilities Zone. Given that the upgrading of the Glencairn Hotel is not considered a new development, and the property is located within the urban edge, an area earmarked for urban use, the development would be consistent with this zone. The potential impacts on the natural environmental attributes that are sensitive or have ecological value have been assessed by means of this Basic Assessment process. (e) Any other Plans (e.g., Integrated Waste Management Plan (for

waste management activities), etc.)). YES NO Please explain

N/A

3. Is the land use (associated with the project being applied for) considered within the timeframe intended by the existing approved SDF agreed to by the relevant environmental authority (in other words, is the proposed development in line with the projects and programmes identified as priorities within the credible IDP)?


As noted in item 1(c) above, the proposed project is considered to be consistent with the SDF.

4. Should development, or if applicable, expansion of the town/area concerned in terms of this land use (associated with the activity being applied for) occur on the proposed site at this point in time?


As noted in item 1(c) above, the SDF for the Southern District prioritises urban development through the development of underutilised infill sites. Thus, the proposed project is considered to be suitable for the site at this point in time. 5. Does the community/area need the project and the associated

land use concerned (is it a societal priority)? (This refers to the strategic as well as local level (e.g., development is a National Priority, but within a specific local context it could be inappropriate.)


The proposed project would create construction job opportunities and several part time jobs would be created by the various business tenants and for the marketing of events during the operational phase. During the operational phase, the proposed project would also contribute to the local economy as well as to job security of the Glencairn Hotel work force and thus the financial status of their families. The local community would also benefit from the additional features of the hotel and the general mix of business it would bring to the area. 6. Are the necessary services available together with adequate

unallocated municipal capacity (at the time of application), or must additional capacity be created to cater for the project? (Confirmation by the relevant municipality in this regard must be attached to the BAR as Appendix E.)


A copy of the draft BAR was provided to the City of Cape Town for comment on the proposed project and confirmation has been obtained that adequate capacity is available for the proposed project (see Appendix E3). 7. Is this project provided for in the infrastructure planning of the

municipality and if not, what will the implication be on the infrastructure planning of the municipality (priority and placement of services and opportunity costs)? (Comment by the relevant municipality in this regard must be attached to the BAR as Appendix E.)


The proposed development would link into existing Municipal infrastructure and services, such as water, electricity, and sewage. 8. Is this project part of a national programme to address an issue

of national concern or importance? YES NO Please explain

The proposed project does not form part of a national programme to address an issue of national concern or importance as it relates to local development.


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9. Do location factors favour this land use (associated with the proposal and associated listed activity(ies) applied for) at this place? (This relates to the contextualisation of the proposed land use on this site within its broader context.)


The location of the subject property is considered to be favourable for residential use as it is located within the existing residential suburb of Glencairn and falls within the urban edge. 10. Will the development impact on sensitive natural and cultural

areas (built and rural / natural environment)? YES NO Please explain

In respect to the natural environment, the proposed project would not have a significant impact on terrestrial vegetation. Vegetation on site includes Peninsula Sandstone Fynbos. Only a small portion (5%) of the property falls within a mapped CBA in terms of the City of Cape Town Biodiversity Network mapping. No plant Species of Conservation Concern were found in the study area, and the vegetation type concerned is well conserved and under relatively little threat throughout its range. The Glencairnvlei outlet channel is located adjacent to the parking area on Erf 235. Although the wetland / vlei area has been modified through human intervention in the past (e.g. construction of the railway line and road, and a berm across the upper vlei area that has restricted its functioning as an estuarine system), the vlei is regarded as having high conservation value and worthy of protection and enhancement. The site has heritage importance due to the historic value of the Glencairn Hotel, which was built in 1904 and altered in 1930. As mentioned in Section B10, HWC had previously approved the preferred development option and confirmed on 26 January 2018 that no further action is required in terms of NHRA (see Appendix E2). 11. Will the development impact on people’s health and well-being

(e.g. in terms of noise, odours, visual character and sense of place, etc.)?


During construction the adjacent areas may experience elevated noise and dust levels, resulting in a short-term negative impact of very low significance. Short-term employment opportunities during the construction phase may have a positive impact of very low significance on the income levels of some community members and their dependents. During the operational phase, the proposed project would contribute to the local and regional economy and would contribute to job security of the Glencairn Hotel workforce and thus the financial status of their families. The local community would also benefit from the services and facilities associated with the upgraded hotel complex. The final layout and design proposal were developed in collaboration with HWC in order to comply with heritage standards and requirements for alterations to the historic Glencairn Hotel building. In relation to the visual character of the proposed development, specific consideration has been given to appropriate design features that would alleviate the potential visual impact in the light of the scenic nature of the location. Detail regarding the potential impacts is provided in Section G of this BAR. 12. Will the proposed activity or the land use associated with the

activity applied for, result in unacceptable opportunity costs? YES NO Please explain

It is not expected that the proposed project would have any unacceptable opportunity costs as the property is located within the existing residential suburb of Glencairn and is within the urban edge. 13. What will the cumulative impacts (positive and negative) of the proposed land use associated with

the activity applied for, be? Cumulative impacts are included in the impact assessment (see Section G). No significant cumulative biophysical or socio-economic impacts are anticipated after mitigation. 14. Is the development the best practicable environmental option

for this land / site? YES NO Please explain

As noted above, current policy and planning prioritises urban development through the development of underutilised infill sites.


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15. What will the benefits be to society in general and to the local communities? The proposed project would create construction job opportunities and several part time jobs would be created by the various business tenants and for the marketing of events during the operational phase. During the operational phase, the proposed project would also contribute to the local economy as well as to job security of the Glencairn Hotel work force and thus the financial status of their families. The local community would benefit from the additional features of the hotel and the general mix of business it would bring to the area. The new complex would also create recreational opportunities for visitors to the South Peninsula and local residents and create a social hub for Glencairn, by providing outlets for music and entertainment. The re-development would further add value to the economic base of Glencairn. 16. Any other need and desirability considerations related to the proposed activity? Please explain

None identified to date.

17. Please describe how the general objectives of Integrated Environmental Management as set out in Section 23 of NEMA have been taken into account:

The general objectives of Integrated Environmental Management were taken into account by investigating various alternative layouts and design elements prior to presenting the proposed layout and design. Potential negative and positive impacts of the proposed project on both the biophysical and socio-economic environments were assessed. In order to avoid potentially significant impacts, specialist input was obtained in relation to botany, freshwater ecology and heritage resources.3 Based on the findings of the specialist studies a number of recommendations / mitigation measures have been identified for consideration in further project design and implementation. Minimisation of potential negative impacts and optimisation of potential positive impacts will be ensured by way of implementation of an approved EMP. The public and authorities will be given adequate opportunity to comment on the proposed project and to participate in the BA process. 18. Please describe how the principles of environmental management as set out in Section 2 of NEMA

have been taken into account: The basic needs of landowners and the public were taken into account during the planning phase of the proposed project. The proposed project is deemed to be socially, environmentally and economically sustainable. Minimisation of potential negative impacts and optimisation of potential positive impacts will be ensured by way of effective implementation of the EMP (see Appendix H).

3 As indicated in Section B10, HWC confirmed that its decision to approve the development dating from 2004 remains valid. It

was not deemed necessary to update the heritage studies undertaken at the time. Copies of the studies are included for information purposes in Appendix E1.


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SECTION E: DETAILS OF ALL THE ALTERNATIVES CONSIDERED

1. DETAILS OF THE IDENTIFIED AND CONSIDERED ALTERNATIVES AND INDICATE THOSE ALTERNATIVES THAT WERE FOUND TO BE FEASIBLE AND REASONABLE

Note: A full description of the investigation of alternatives must be provided and motivation if no reasonable or feasible alternatives exists.

(a) Property and location/site alternatives to avoid negative impacts, mitigate unavoidable negative

impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist:

No site alternatives were considered as the proposed development consists of the upgrading of an existing hotel on the property, which belongs to the Applicant.

(b) Activity alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise

positive impacts, or detailed motivation if no reasonable or feasible alternatives exist: In the initial stages of site development planning for the proposed upgrading of the hotel in 2003/2004, various activities and uses for the site were considered. These included the following: Four main substantive activity alternatives were considered during the early planning stages, namely:

• Alternative A: Full Business – development of the entire site as a commercial centre. This option would not utilise the full potential of the site. There would be no contribution to residential and office space and the Applicant would therefore not be able to lease those portions and generate an income from them. This option would not allow for a good balance of the varying components on the property.

• Alternative B: Minor Business Use Area – where the site would be subdivided into a hotel zone, minor business zone and residential zone.

This option would utilise the full potential of the site as it would include a mix of all the components and provide a range of functions. The Applicant would therefore have a good balance on the property.

• Alternative C: General Residential – whole site, excluding hotel, would be developed as a cluster house development.

This option would not utilise the full potential of the site. There would be no contribution to commerical, retail or office space and thereby not allowing a good balance of the varying components on the property.

• Alternative D: Single Residential and formalize existing buildings – subdivide the remainder of the erf into

single residential units, and get approval for the existing commercial strip on Glencairn Road. This option would not utilise the full potential of the site as it would only include space for single residential units and getting approval of the exisitng commericial strip. There would therefore be no new commericial or retail opportunities and the Applicant would not have a good balance on the property. In an iterative process involving Heritage Western Cape and various architects, which formed part of the earlier EIA regulatory process undertaken for the proposed project in 2003/2004, the preferred option was determined to be a blend of general residential, single residential and business use. The reasons are that a mixed development would best serve the needs of the area, as it would respect the sensitivity of the site and the scale of adjacent development while unlocking its maximum potential. Developing the property with a mix of retail, commercial, minor residential and small office components would provide a range of functions and income-generating opportunities while fulfilling a niche market role in the South Peninsula. Alternative B above was thus selected as the preferred option to explore further in terms of layout and design options.


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(c) Design or layout alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist:

Layout alternatives: During the initial stages of site development planning for the proposed upgrading of the hotel in 2003/2004, alternative scenarios were considered regarding varying mixes of the following components: • Retail: The retail "lifestyle" complex focusing on outdoor recreation-type commercial outlets (hiking, diving,

etc) was decided upon based on the lack of other such outlets in the South Peninsula area and the perceived demand for such outlets by visitors. Only a few individual retail hiking/sport outlets existed on the South Peninsula at the time thus the Applicant visualised bringing different recreational retail units together under one roof.

• Commercial: The existing hotel and bar complex lends itself to continued functioning given its historical use for this purpose. Several local residents had indicated their desire to see the bar continue to function. There is a notable lack of restaurant/bar outlets in Glencairn and the Applicant realised that an the opportunity existed to create outlets catering to daytime and evening visitors (e. g. local deli and restaurant).

• Office: Development of office space was deemed desirable due to the paucity of small office space in the local area. Local residents had expressed interest in operating from the complex in preference to commuting to offices further afield.

• Residential: As plots on the mountainside are always prime property, the Applicant proposed to make five erven available on a plot and plan basis as a means to partially finance the proposed development. Self-catering units would also serve as an additional income-generating opportunity.

The ratio of residential to commercial/retail and office use was the main focus of the planning and layout processes in the initial planning approach (in 2003/2004). Three alternatives were considered in this process. The table below roughly summarises the proportional allocation to retail, residential and office space for the three options that was considered.

Retail (%) Residential (%) Office (%) Option 1 56 38 6 Option 2 52 44 4 Option 3 11 87 2

Option 1 – 56% residential, 38% retail and 6% office • Upgrade the existing hotel; • Add new wing of 12 rooms and enclosed pool courtyard; • Demolish existing strip of commercial development fronting Glencairn Road; remove and alter the roof of the

hotel annex on its southern side; replace with a village square with deli/foodstore, sit-down meal outlet and adventure sports boutique shops and coffee shop at ground level;

• Additional shops and offices on second floor and sports bar OR 5 flats; and • Six residential plots.

Development planning history: This option was well received by the public based on initial sketch plans presented during the initial EIA regulatory process in 2003/2004. The buildings were shown as an extension of the existing hotel architecture using similar design elements as the original building. However, the heritage consultants expressed concern over the similarity of the architecture to the original and advised that new additions should have a more contemporary style to highlight the special quality of the old buildings. A subsequent architectural survey of the original hotel using historical photographs revealed that much of the original fabric was intact and quite well preserved. The Applicant decided to restore the front façade close to its original state and fronting onto a new public deck by removing the front annex. Architects were contracted to redesign the new development in a contemporary style while retaining the hotel annex (required by HWC), leading to Option 2. Option 2 – 52% residential, 44% retail and 2% office • New hotel wing with two storeys of new accommodation (12 rooms) and basement conference centre around

a pool courtyard, increasing total size of hotel to 2 000 m2; • Two storeys of new retail development around a reduced village square of 1 000 m2; • A new restaurant of 675 m2;


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• New offices (~ 150 m2) above the village square; • Eight new sectional title units of 100 m2 each; and • Five residential erven.

Development planning history: These design plans were well received by HWC at the time (2003/2004). However, certain problems emerged, namely: • Insufficient parking and the need for prohibitively expensive basement parking; • Unlikelihood that a second restaurant could be sustained by the local market and lack of a sufficient tourism

market to Glencairn, while this option would probably be undesirable to locals; • A shift in the property market to favour residential rather than commercial development; and • Differences in "architectural vision" between the architects and the Applicant.

This resulted in locally-based architects being contracted to rework the development concept with a smaller commercial component and a larger accommodation mix, which culminated in Option 3, the preferred development option. Option 3 – 87% residential, 11% retail and 2% office • New Rear Hotel Wing and Conference Centre comprising

o Six self-catering suites (30 m2 each); o Six en suite hotel rooms (30 m2 each) on ground floor; o Conference centre / function venue around swimming pool courtyard; and o Four retail kiosks in front of hotel (20 m2 each).

• 10 luxury Apartments comprising o Four 3-bed apartments (146 m2 each) and 29 m2 terraces and double garage; and o Six 2-bed apartments (98 m2 each) and 19 m2 terraces and single garage.

• Six apartments and lifestyle square comprising o 4 x 2 bedroom apartments (126 m2 each); o 2 x 2 bed apartments (100 m2 each) overlooking square; o 6-8 retail commercial units (total 375 m2) around a reduced square with a proposed focus on lifestyle

oriented activities (adventure, tourism, children etc); o 4-8 small offices for centre management etc (total 88 m2); and o 16 covered parking bays.

• Five single residential erven (to be sold with plans) o 5 x 4-bedroom houses (250 m2) and flatlet and double garage on 600 m2 plots.

Development planning status: The plans for Option 3 were submitted to and approved by HWC in 2004 and confirmed as acceptable by HWC in 2018 (see Section B10(a) and Appendix E2). The preferred design option was therefore Option 3, which is referred to as Alternative 1 and assessed in Section G. Further aspects considered in relation to design included the following:

Location of components on site The arrangement of development units was largely determined by the existing location of the old hotel and adjacent buildings and ease of access. Hence the commercial and retail outlets would be located near the parking area in front of the property, while the residential and self-catering units would be located on the upper (back) portion away from the busier retail area and to take advantage of the views.

Architectural/built form and construction materials The architectural built form has been carefully determined with the help of heritage consultants and an architect. Various iterations of the design plans were undertaken during the original planning process (2003/2004) in order to design the new development to complement the old hotel but not compete or replicate its built form and to comply with previous suggestions given by HWC. This involved consideration of the roof pitching, building height and form, use of terraces, gables and verandas, plinths, natural materials etc.

Heritage considerations The old hotel extension, built in 1930, obscured the original façade of the hotel with its veranda across the front. It


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was eventually decided to restore the hotel to its original façade by removing the upper portion of the annex, while at the same time providing for a front deck area with space below for a delicatessen. This restoration, which ash been completed, involved removal of the 1930 front extension of the hotel to form an outside eating deck, renovation and enlargement of the hotel kitchen, renovation of the main part of the old hotel to form a 150-seat restaurant, and reproofing, plumbing and electrics of the hotel and annex.

(d) Technology alternatives (e.g., to reduce resource demand and increase resource use efficiency) to

avoid negative impacts, mitigate unavoidable negative impacts and maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist:

In relation to stormwater measures, the original proposal was to construct one or two small vegetated detention ponds at the edge of Glencairnvlei to aid infiltration and purification of stormwater runoff before release into the Glencairnvlei outlet channel. However, upon further investigation the freshwater specialist indicated that an alternative approach would be advisable due to limited space to accommodate stormwater ponds at the proposed location along the vlei. She thus recommended that it would be advisable to implement measures to limit stormwater runoff as far as possible. As stated in the project description (see Section A2), a permeable paving basin is planned for the parking along Glen Road. This would serve to both detain and treat the stormwater to acceptable levels before discharge into the Glencairnvlei outlet channel. This basin would be unlined and would thus allow water infiltration into the ground. The viability of retaining accumulated stormwater runoff in (an) appropriate storage area(s) for recycling within the development would be investigated during the detailed design phase. The measures proposed to limit stormwater runoff as far as possible in the context of the steep slope would entail diverting stormwater off the mountain around the site via a cut off drain and managing stormwater that would fall on the site. The proposed building structures would provide for the future terraces and retaining systems required. A detailed geotechnical report would be required to determine specifics regarding the existing ground conditions, slope stability and how these building structures would address stormwater retention appropriately. These further investigations would be undertaken during the detailed design stage.

(e) Operational alternatives to avoid negative impacts, mitigate unavoidable negative impacts and

maximise positive impacts, or detailed motivation if no reasonable or feasible alternatives exist: No operational alternatives were identified.

(f) The option of not implementing the activity (the ‘No-Go’ Option):

The No-Go Option means that the project would not proceed. This option is not considered economically viable s it would not unlock the development potential of the property and contribute to the local and regional economy. As such, the No-Go Option would not be environmentally, socially or economically feasible in the long-term and is thus not deemed feasible. However, the No-Go Option is nevertheless considered and assessed in relation to the potential implications of the proposed project, as required in terms of NEMA and its EIA Regulations

(g) Other alternatives to avoid negative impacts, mitigate unavoidable negative impacts and maximise

positive impacts, or detailed motivation if no reasonable or feasible alternatives exist: No other alternatives were identified.

(h) Provide a summary of all alternatives investigated and the outcome of each investigation:

The outcome of alternatives investigated can be summarised as follows: • No site or location alternatives have been identified as the project entails the upgrading of an existing hotel on

a defined property. • The following activity alternatives have been identified.

o Alternative A: Full Business; o Alternative B: Mixed Use; o Alternative C: General Residential; and o Alternative D: Single Residential and formalize existing buildings. The Mixed Use option was considered the most appropriate approach and was thus pursued in more detail.

• In respect to layout and design alternatives, three main alternatives were considered, namely: o Option 1- 38% residential, 56% retail and 6% office;


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o Option 2 - 44% residential, 52% retail and 4% office; o Option 3 - 87% residential, 11% retail and 2% office. Option 3 was considered the most viable and feasible and served as the basis for the final design plans, which were approved by HWC. This is thus the preferred alternative, referred to as Alternative 1 in this BAR going forward.

• No operational alternatives have been identified. • No-Go option – This means that the project would not proceed, which is not consdiered environmentally,

socially and economically viable in the longer term.

2. PREFERRED ALTERNATIVE (a) Provide a concluding statement indicating the preferred alternative(s), including preferred location,

site, activity and technology for the development: The preferred alternative is to upgrade the property to a Mixed Use development comprising a viable mix of residential, commercial/retail and office space. The proposed development design entails 87% residential, 11% retail and 2% office space, including the following main components: • New rear hotel wing and conference centre; • Ten luxury apartments; • Six apartments and lifestyle square; and • Five single residential erven.


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SECTION F: ENVIRONMENTAL ASPECTS ASSOCIATED WITH THE ALTERNATIVES Note: The information in this section must be DUPLICATED for all the feasible and reasonable ALTERNATIVES.

1. DESCRIBE THE ENVIRONMENTAL ASPECTS ASSOCIATED WITH THE PROPOSED DEVELOPMENT AND ITS ALTERNATIVES, FOCUSING ON THE FOLLOWING:

(a) Geographical, geological and physical aspects:

No significant long-term impacts on the geographical aspects of the site and surrounding area are expected to occur as a result of the proposed project.

(b) Ecological aspects:

Will the proposed development and its alternatives have an impact on CBAs or ESAs? If yes, please explain. Also include a description of how the proposed development will influence the quantitative values (hectares/percentage) of the categories on the CBA/ESA map.

YES NO

The original natural vegetation in the study area is listed as Critically Endangered Peninsula Sandstone Fynbos. However, only a small portion of the study area falls within CBA1b, while 95% of the site is mapped as Other Natural Vegetation. Peninsula Sandstone Fynbos is exceptionally well conserved – it still has 95% of its total original extent remaining, about 98% of its total extent conserved (mostly within the TMNP), and a national conservation target of 30%. The proposed development will therefore not have a significant impact on the overall conservation of the vegetation type. Will the proposed development and its alternatives have an impact on terrestrial vegetation, or aquatic ecosystems (wetlands, estuaries or the coastline)? If yes, please explain:

YES NO

As noted previously, the only aquatic ecosystem of concern is the Glencairnvlei outlet channel, situated adjacent to Erf 253. With the implementation of appropriate mitigation measures, key of which is to ensure that a 15 m buffer between the development and the edge of the vlei is maintained, the potential impacts would be contained to of very low significance during the construction and operational phases. Will the proposed development and its alternatives have an impact on any populations of threatened plant or animal species, and/or on any habitat that may contain a unique signature of plant or animal species? If yes, please explain:

YES NO

N/A Describe the manner in which any other biological aspects will be impacted: N/A. Will the proposed development also trigger section 63 of the NEM: ICMA? YES NO If yes, describe the following: (i) the extent to which the applicant has in the past complied with similar authorisations; (ii) whether coastal public property, the coastal protection zone or coastal access land will be affected,

and if so, the extent to which the proposed development proposal or listed activity is consistent with the purpose for establishing and protecting those areas;

(iii) the estuarine management plans, coastal management programmes, coastal management lines and coastal management objectives applicable in the area;

(iv) the likely socio-economic impact if the listed activity is authorised or is not authorised; (v) the likely impact of coastal environmental processes on the proposed development; (vi) whether the development proposal or listed activity—

(a) is situated within coastal public property and is inconsistent with the objective of conserving and enhancing coastal public property for the benefit of current and future generations;

(b) is situated within the coastal protection zone and is inconsistent with the purpose for which a coastal protection zone is established as set out in section 17 of NEM: ICMA;

(c) is situated within coastal access land and is inconsistent with the purpose for which coastal access land is designated as set out in section 18 of NEM: ICMA;


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(d) is likely to cause irreversible or long-lasting adverse effects to any aspect of the coastal environment that cannot satisfactorily be mitigated;

(e) is likely to be significantly damaged or prejudiced by dynamic coastal processes; (f) would substantially prejudice the achievement of any coastal management objective; or (g) would be contrary to the interests of the whole community;

(vii) whether the very nature of the proposed activity or development requires it to be located within coastal public property, the coastal protection zone or coastal access land;

(viii) whether the proposed development will provide important services to the public when using coastal public property, the coastal protection zone, coastal access land or a coastal protected area; and

(ix) the objects of NEM: ICMA, where applicable. Although the property is located in close proximity to Glencairn Beach, there is an existing road and railway line which separates the hotel site from the beach. Hence, there is no direct link between the hotel and the sea. The proposed development will therefore not trigger section 63 of NEM: ICMA.

(c) Social and Economic aspects:

What is the expected capital value of the project on completion? R 50 million of which R 40 million would be spent on built fabric.

What is the expected yearly income or contribution to the economy that will be generated by or as a result of the project?

R 4 million

Will the project contribute to service infrastructure? YES NO Is the project a public amenity? YES NO How many new employment opportunities will be created during the development phase?

~ 100 (skilled and unskilled)

What is the expected value of the employment opportunities during the development phase?

R 10 million

What percentage of this will accrue to previously disadvantaged individuals? 50% How will this be ensured and monitored (please explain): The Contractor would be contractually required to reach agreed targets. How many permanent new employment opportunities will be created during the operational phase of the project?

~ 50

What is the expected current value of the employment opportunities during the first 10 years?

R 50 million

What percentage of this will accrue to previously disadvantaged individuals? 70% How will this be ensured and monitored (please explain): In relation to the Glencairn Hotel staff complement, 15 of the 20 existing job opportunities are currently held by previously disadvantaged (Black and Coloured) employees. The hotel owners are committed to retain this approach in future. Any other information related to the manner in which the socio-economic aspects will be impacted: See Section G of this BAR.

(d) Heritage and Cultural aspects:

The potential impacts of the proposed upgrade on heritage and cultural-historic aspects have been identified and are described in Section G of this BAR.

2. WASTE AND EMISSIONS (a) Waste (including effluent) management

Will the development proposal produce waste (including rubble) during the development phase? YES NO

If yes, indicate the types of waste (actual type of waste, e.g. oil, and whether hazardous or not) and estimated quantity per type?

Rubble (non-hazardous) ~ 100 m3

A minimal volume of construction waste would be produced during the construction phase, such as solid waste, concrete waste and spoil material. A very small portion of the construction waste would likely be hazardous waste


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in the form of fuel and / or oil spills collected in drip trays and any contaminated soil resulting from accidental spills.

Will the development proposal produce waste during its operational phase? YES NO

If yes, indicate the types of waste (actual type of waste, e.g. oil, and whether hazardous or not) and estimated quantity per type?

Refuse (non-hazardous) ~ 20 m3 per week

General waste, comprising solid domestic waste, would be produced during the operational phase. The existing municipal waste collection system would be utilised, while private waste management services would also be employed, specifically for waste recycling where possible.

Will the development proposal require waste to be treated / disposed of on-site? YES NO

If yes, indicate the types of waste (actual type of waste, e.g. oil, and whether hazardous or not) and estimated quantity per type per phase of the proposed development to be treated/disposed of?

m3

N/A. If no, where and how will the waste be treated / disposed of? Please explain. Indicate the types of waste (actual type of waste, e.g. oil, and whether hazardous or not) and estimated quantity per type per phase of the

m3

Construction waste would be disposed of at an approved landfill site. During the operational phase, the existing municipal waste collection system would be utilised for waste disposal, while private waste management services would also be employed, specifically for waste recycling where possible. Has the municipality or relevant authority confirmed that sufficient capacity exists for treating / disposing of the waste to be generated by the development proposal? YES NO

If yes, provide written confirmation from the municipality or relevant authority. YES NO

Confirmation of available capacity by the City of Cape Town is included in Appendix E3. Will the development proposal produce waste that will be treated and/or disposed of at another facility other than into a municipal waste stream? YES NO

If yes, has this facility confirmed that sufficient capacity exists for treating / disposing of the waste to be generated by the development proposal? N/A YES NO

Describe the measures that will be taken to reduce, reuse or recycle waste: The appointed Contractor would be responsible for the establishment of a solid waste control and removal system in order to prevent the spread of waste in, and beyond, the construction area. The following measures have been included in the Construction EMP (see Appendix H): • An integrated waste management approach would be used, based on the principles of waste minimisation,

reduction, reuse and recycling of materials. Containers for glass, paper, metals and plastics would be provided. All non-recyclable solid waste would be disposed of off-site at a licenced landfill site; and

• All hydrocarbons (e.g. fuel, oils and contaminated soil / materials) and other hazardous waste resulting from spills, refuelling and maintenance activities would be disposed of at a licenced hazardous waste site or, where possible, sold to an approved used-oil recycling company.

As mentioned above, waste recycling by the hotel and other commercial and business enterprises would be encouraged and private waste management services would be employed for collecting waste suitable for recycling.

(b) Emissions into the atmosphere

Will the development proposal produce emissions that will be released into the atmosphere? YES NO

If yes, does this require approval in terms of relevant legislation? YES NO

If yes, what is the approximate volume(s) of emissions released into the atmosphere? m3


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Describe the emissions in terms of type and concentration and how these will be avoided / managed / treated / mitigated: Dust and noise may be generated during the construction phase as a result of earthworks. The appointed Contractor would be required to ensure that the generation of dust is minimised by implementing a dust control programme (e.g. wetting of areas being disturbed) to maintain a safe working environment and minimise nuisance for surrounding residents and road users. These activities would be managed in terms of the requirements of the Construction EMP (refer to Appendix H). The Contractor would also be required to be familiar with and adhere to any regulations and by-laws regarding the generation of noise and hours of operation.

3. WATER USE (a) Indicate the source(s) of water for the development proposal by highlighting the appropriate box(es).

Municipal Water board Groundwater River, Stream, Dam or Lake

Other The project will not use water

A minimal volume of water would be required for construction activities and would be obtained from the existing municipal bulk water infrastructure. Municipal bulk water supply services would also be utilised during the operational phase, as described in Section A2(b) above. (b) If water is to be extracted from a groundwater source, river, stream, dam,

lake or any other natural feature, please indicate the volume that will be extracted per month:

N/A

(c) Does the development proposal require a water use permit / license from DWS? If yes, please submit the necessary application to the DWS and attach proof thereof to this application as an Appendix.

YES NO

A copy of the draft BAR and freshwater assessment specialist report was submitted to DWS for comment and confirmation of the applicability of Section 21(c) and (i) water uses was received. The process of submitting a Water Use Authorisation application has been initiated on behalf of the Applicant. Proof of application for the registration of the water uses has been included in the final BAR (see Appendix E4). (d) Describe the measures that will be taken to reduce water demand, and measures to reuse or

recycle water: Only a minimal volume of water may be required for dust suppression measures during the construction phase. Areas would only be wetted during windy days and / or when dust may become a nuisance to surrounding residents and businesses. All water tanks and water trucks would be maintained in a good working condition to ensure that no unnecessary water leaks occur.

4. POWER SUPPLY (a) Describe the source of power e.g. municipality / Eskom / renewable energy source:

During the construction phase generators would be used. Municipal sources would be used for power supply during the operational phase.

(b) If power supply is not available, where will power be sourced?

N/A. 5. ENERGY EFFICIENCY (a) Describe the design measures, if any, that have been taken to ensure that the development proposal

will be energy efficient: Appropriate energy efficient measures would be incorporated into the development proposal during the detailed design phase, in accordance with the City of Cape Town requirements in this regard.


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(b) Describe how alternative energy sources have been taken into account or been built into the design of the project, if any:

N/A.

6. TRANSPORT, TRAFFIC AND ACCESS (a) Describe the impacts in terms of transport, traffic and access:

During the construction phase the movement of construction vehicles transporting building materials to the site may have a limited impact on traffic in the area. During the operational phase a small increase in traffic associated with the Mixed Use development is anticipated. However, it should be noted that the existing hotel, restaurant and bar facilities as well as the retail outlets already generate a regular traffic flow and volumes. Thus it is not foreseen that the changes would generate significant traffic increases that would affect transport, traffic and access to the Glencairn Hotel or in the surrounding areas significantly during the operational phase. The existing levels of service at the various intersections are likely to be maintained.

7. NUISANCE FACTOR (NOISE, ODOUR, ETC.) (a) Describe the potential nuisance factor or impacts in terms of noise and odours:

As stated in Section F2(b) above, dust and noise may be generated during the construction phase as a result of earthworks. The appointed Contractor would be required to ensure that the generation of dust is minimised by implementing a dust control programme (e.g. wetting of areas being disturbed) to maintain a safe working environment and minimise nuisance for surrounding residents and road users. These activities would be managed in terms of the requirements of the Construction EMP (refer to Appendix H). The Contractor would also be required to be familiar with and adhere to any regulations and by-laws regarding the generation of noise and hours of operation. While the proposed project may entail potential nuisance factors related to noise during the operational phase from the restaurant and bar on the property, these impacts already exist and would not entail a significant change to the current status. The above-mentioned potential impacts of the proposed project are described and assessed in Section G of this BAR.

Note: Include impacts that the surrounding environment will have on the proposed development. 8. OTHER

Visual impact The site is visually prominent when travelling towards Simon’s Town along the Main Road, which is a major tourist route on the False Bay coast of the South Peninsula. The potential visual impact of the proposed project is described and assessed in Section G of this BAR. Potential fire risk The site is located along the mountainside adjacent to an undeveloped property with a high fuel load due to invasive alien vegetation infestation. As the landowner of the property and the existing hotel complex, the Applicant is fully aware of the responsibility for effective management of potential fire risk associated with the site. Thus preventative measures such as removing and controlling invasive alien vegetation growth on the site and creating and maintaining the fire break along the upper boundary are in place and receive ongoing attention. In respect to the proposed upgrading project, the Applicant is committed to comply with all current legislation, bylaws and policy and guideline documents as required. Detail will be finalised at the detailed design phase when the Site Development


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Plan is finalised for submission to the City of Cape Town. This will include detail regarding access to all areas of the site as well as relevant fire-fighting infrastructure, for example, the location of and access to a fire hydrant and associated water pressure. The detailed design will also incorporate relevant detail regarding landscaping, building materials and construction methodology that are compatible with the legal and policy framework regarding fire risk management. A section on fire management has been included in the Operational EMP appended to this BAR (see Appendix H2), which stipulates details regarding the relocation of the fire break beyond the site boundary in future before the proposed residential erven are developed and the development of a detailed fire management plan. It should also be noted that the Applicant has engaged with the Cape Peninsula Fire Protection Association regarding future cooperation in respect to fire risk management. A letter from the Association to this effect is included in the Final BAR (see Appendix K2). In summary, while it is acknowledged that effective fire risk management is a key responsibility of the Applicant as a landowner in a high fire risk environment, it is not foreseen that the proposed changes would generate a significant increase in fire risk that would affect the surrounding areas significantly during the operational phase.


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SECTION G: IMPACT ASSESSMENT, IMPACT AVOIDANCE, MANAGEMENT, MITIGATION AND MONITORING MEASURES

1. METHODOLOGY USED IN DETERMINING AND RANKING ENVIRONMENTAL IMPACTS AND RISKS ASSOCIATED WITH THE ALTERNATIVES

(a) Describe the methodology used in determining and ranking the nature, significance consequences,

extent, duration and probability of potential environmental impacts and risks associated with the proposed development and alternatives.

The assessment of potential impacts of the proposed project and compilation of this report were undertaken in compliance with the requirements of NEMA and the EIA Regulations 2014 (as amended). All impacts have been systematically assessed and presented according to the ‘Convention for assigning significance ratings to impacts’, which is described in detail in Appendix J1.

(b) Please describe any gaps in knowledge.

No gaps in knowledge have been identified. (c) Please describe the underlying assumptions.

SLR assumes that there would be no significant change to the project description or change in the nature of the receiving environment, which would require a re-assessment of the potential impacts as assessed in this report. SLR also assumes that all the data and information provided by the Applicant and project consulting engineer were accurate and unbiased.

(d) Please describe the uncertainties.

No uncertainties have been identified. (e) Describe adequacy of the assessment methods used.

All impacts have been systematically assessed and presented according to the ‘Convention for assigning significance ratings to impacts’ (see Appendix J1). SLR is confident that all potential impacts have been assessed as part of this Basic Assessment process and that this report should provide DEA&DP with sufficient information to make an informed decision on the application.

2. IDENTIFICATION, ASSESSMENT AND RANKING OF IMPACTS TO REACH

THE PROPOSED ALTERNATIVES INCLUDING THE PREFERRED ALTERNATIVE WITHIN THE SITE

Note: In this section the focus is on the identified issues, impacts and risks that influenced the identification of the alternatives. This includes how aspects of the receiving environment have influenced the selection.

(a) List the identified impacts and risks for each alternative.

Alternative 1: The following impacts have been identified: Impacts that may result from the development phase (planning, design and construction): • Ecological Aspects:

o Loss of terrestrial vegetation; o Loss of open space within the sub-catchment area; and o Destruction, deterioration or pollution of the Glencairnvlei outlet channel as a

result of construction activities. • Socio-economic Aspects: Employment. • Construction-related dust, noise and visual.


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Impacts that may result from the operational phase: • Ecological Aspects:

o Loss of ecological connectivity; o Decrease in water quality; o Changes in water inputs and flow patterns; o Disturbance of fauna and flora; and o Spread and establishment of alien invasive plants.

• Socio-economic Aspects: o Job security of existing labour force and additional job creation.

• Contribution to the local and regional economy. • Visual impact. • Noise impact. • Heritage and Cultural-historical aspects:

o Upgrading of the historic Glencairn Hotel.

Impacts that may result from the decommissioning and closure phase: No impacts have been identified because the proposed project would not be decommissioned in the foreseeable future.

No-go Alternative: The No-Go Option means that the proposed project would not proceed, which would result in the following consequences: • Glencairn Hotel would not be upgraded and would thus not be suitably restored in

accordance with heritage requirements; • The historical and cultural value of the hotel would not be enhanced as a result of its

upgrading; • The development potential of the undeveloped portion of the site would not be

unlocked in order to contribute to the local and regional economy;

• Additional recreational and tourism opportunities would not be provided for visitors and local residents;

• Employment and development opportunities and long-term job security of the existing work force would not be enhanced;

• The creation of additional jobs envisaged as a result of the expansion of retail and commercial/office space would not materialise; and

• The property owners would not be able to realise a return on their investment in the property.

(b) Describe the impacts and risks identified for each alternative, including the nature, significance,

consequence, extent, duration and probability of the impacts, including the degree to which these impacts can be reversed; may cause irreplaceable loss of resources; and can be avoided, managed or mitigated.

ALTERNATIVE 1

1. IMPACTS THAT MAY RESULT FROM THE PLANNING, DESIGN AND DEVELOPMENT PHASE

1.1 Potential impacts on geographical and physical aspects No geographical and physical impacts are expected during the planning, design and development phase.

1.2 Potential impacts on ecological aspects: Terrestrial vegetation Criteria Description Nature of impact: Loss of all Low and Medium sensitivity vegetation on site. Extent and duration of impact: Local; permanent Intensity of impact or risk: High Probability of occurrence: Definite


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Degree to which the impact may cause irreplaceable loss of resources: Very Low

Degree to which the impact can be reversed: Irreversible Indirect impacts: Very Low Cumulative impact prior to mitigation: Very Low Significance rating of impact prior to mitigation Low*

Degree to which the impact can be avoided: None Degree to which the impact can be managed: Very Low Degree to which the impact can be mitigated: None Proposed mitigation: • Restrict all construction-related disturbance to the

authorised development footprint, which should be demarcated with coloured rope or fencing prior to any development on site.

• Ensure that no heavy machinery or stored or dumped material impact on adjacent areas.

• Plant Search and Rescue would not change the significance levels of vegetation loss, as all translocatable species in the development footprint are well represented outside the footprint.

Residual impacts: Low Cumulative impact post mitigation: Very Low Significance rating of impact after mitigation LOW

*Note: The botanical specialist confirmed the significance rating of Low prior to mitigation even though the “Convention” followed would indicate a different significance rating on the basis of an intensity rating of High. The reason is that the specialist rates the intensity of any loss of vegetation High, but the significance rating in this case is confirmed as Low in the light of the specific circumstances related to the study area as described in Section B6(d). Also refer to the specialist’s conclusions and recommendations in Section G3.

1.3 Potential impacts on ecological aspects: Freshwater ecosystems - Loss of open space within the sub-catchment area

Criteria Description Nature of impact: The development of the site would result in the loss of open

space between the Glencairn Mountain and the vlei. Fragmentation of the connectivity between the wetland and the surrounding area could lead to deterioration of habitat conditions.

Extent and duration of impact: Local; short-term Intensity of impact or risk: Low Probability of occurrence: Probable Degree to which the impact may cause irreplaceable loss of resources: Low

Degree to which the impact can be reversed: Fully reversible Indirect impacts: Low Cumulative impact prior to mitigation: Medium Significance rating of impact prior to mitigation Low

Degree to which the impact can be avoided: High Degree to which the impact can be managed: Medium to high Degree to which the impact can be mitigated: Very low Proposed mitigation: • Establish a 15 m buffer area around the edge of the

Glencairnvlei outlet channel. • Ensure that all buildings and infrastructure are located

outside of the vlei buffer area. Residual impacts: Low Cumulative impact post mitigation: Medium Significance rating of impact after mitigation LOW


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1.4 Potential impacts on ecological aspects: Freshwater ecosystems - Destruction, deterioration or pollution of wetland habitat

Criteria Description Nature of impact: Destruction or deterioration of the wetland habitat and pollution

of the wetland could result from the following construction-related activities: • Storage of building materials too close to the vlei buffer; • Foot and vehicular traffic; • Disturbance of freshwater fauna and flora; • Input of sediments; • Introduction and spread of alien invasive species; and • Leakage of fuels, oils, etc. from construction machinery.

Extent and duration of impact: Local; short-term Intensity of impact or risk: Low to Medium Probability of occurrence: Probable Degree to which the impact may cause irreplaceable loss of resources: Low

Degree to which the impact can be reversed: Partly to fully reversible Indirect impacts: Low Cumulative impact prior to mitigation: Low to medium Significance rating of impact prior to mitigation Low

Degree to which the impact can be avoided: Low to medium Degree to which the impact can be managed: Medium to high Degree to which the impact can be mitigated: Partly to fully mitigated Proposed mitigation: • Store all building materials at least 15 m away from the

edge of the wetland area, as demarcated prior to construction. Storage areas must be bunded adequately to prevent contaminated runoff from entering the wetland.


• Re-plant all areas that are impacted by the storage of materials after construction is complete.

• Construction close to the wetland (i.e. on Erf 235) must take place during the dry season, to reduce the risks of contamination of the ecosystem through rainfall and runoff.

• Concrete mixing must take place as far as possible way from the 15 m buffer area around the edge of the Glencairnclei outlet channel.

• Locate machinery prone to oil or fuel leakage at least 15 m away from the edge of the wetland, in an area adequately bunded in order to contain leakages.

• Use drip trays for water pumps and cement mixers to contain oil and fuel leaks.

• Clean all drip trays regularly. • Provide suitable toilet and wash facilities to avoid the use

of sensitive areas for these activities. These service areas must be regularly maintained and toilets emptied on at least a weekly basis.

• Route pathways and access roads around the wetland and its buffer area.

• Clearly demarcate and fence off sensitive areas as no-go


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areas (using temporary fencing and danger tape) before the start of any construction work or site preparation.

• Direct lights (if used) away from the wetland. • Inspect the site for erosion damage during storm and

heavy rain events. • Direct pumped water from construction areas (e.g. after

rains) into a settlement area, and not directly into the wetland.

• Source top material from a reliable source, and check it for invasie alien plant seedlings before use.

• Monitor the construction site constantly for alien plant growth and eradicate alien plant species.

Residual impacts: Low Cumulative impact post mitigation: Low Significance rating of impact after mitigation VERY LOW

1.5 Potential impacts on socio-economic aspects: Employment Criteria Description Nature of impact: The proposed project would create a limited number of

employment opportunities during the construction phase. Extent and duration of impact: Local; short-term Intensity of impact or risk: Low Probability of occurrence: Highly probable Degree to which the impact may cause irreplaceable loss of resources: N/A

Degree to which the impact can be reversed: N/A Indirect impacts: Low to medium as income from employment would contribute

to improving quality of life of employees’ dependents, albeit for a short period of time.

Cumulative impact prior to mitigation: Very low Significance rating of impact prior to mitigation Very Low (positive)

Degree to which the impact can be avoided: Avoidance is not appropriate in the case of a positive impact Degree to which the impact can be managed: Medium to high Degree to which the impact can be enhanced: Low

Proposed enhancement: • Employ local BEE services and providers and local labour from the local community as far as possible.

• Ensure appropriate training is provided, where required. Residual impacts: N/A Cumulative impact post mitigation: Very low (positive) Significance rating of impact after mitigation VERY LOW (POSITIVE)

1.6 Potential impacts on heritage and cultural-historical aspects No heritage and cultural-historical impacts are expected during the design, planning and development phase. No archaeological artifacts of any significance are expected to be found as the site is too steep for pre-historic inhabitation.

1.7 Potential impacts on dust, noise and visual Criteria Description Nature of impact: Dust would be generated during the construction phase which

may impact on local air quality. Construction activities could increase noise levels which may be a nuisance to local


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residents. Construction activities would have a temporary visual impact on local residents due to the presence of construction machinery and vehicles, material stockpiles, etc.

Extent and duration of impact: Local; short-term Intensity of impact or risk: Medium Probability of occurrence: Highly probable Degree to which the impact may cause irreplaceable loss of resources: N/A

Degree to which the impact can be reversed: Fully reversible Indirect impacts: N/A Cumulative impact prior to mitigation: None Significance rating of impact prior to mitigation Low

Degree to which the impact can be avoided: Low to Medium Degree to which the impact can be managed: Medium to High Degree to which the impact can be mitigated: Low Proposed mitigation: • Maintain all construction machinery and vehicles in good

working order. • Be familiar with and adhere to, any local by-laws and

regulations regarding the generation of noise and hours of operation.

• Avoid construction activities outside of “normal working hours”.

• Ensure that the generation of dust is minimised and shall implement a dust control programme (e.g. wetting of disturbed areas) to maintain a safe working environment and minimise nuisance for local residents and road users.

• Ensure that the exposed soil and material stockpiles are adequately protected against the wind.

• Implement litter control measures and appropriate measures for visual screening.

Residual impacts: Isolated incidents of nuisance factors such as noise and dust may still occur despite the implementation of appropriate mitigation measures.

Cumulative impact post mitigation: None Significance rating of impact after mitigation VERY LOW

2. IMPACTS THAT MAY RESULT FROM THE OPERATIONAL PHASE

2.1 Potential impacts on geographical and physical aspects No geographical and physical impacts are expected during the operational phase.

2.2 Potential impacts on ecological aspects: Terrestrial vegetation Criteria Description Nature of impact: Loss of all current partial ecological connectivity across the

site. Extent and duration of impact: Local; permanent Intensity of impact or risk: High Probability of occurrence: Definite Degree to which the impact may cause irreplaceable loss of resources: Very low

Degree to which the impact can be reversed: Irreversible


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Indirect impacts: None. Cumulative impact prior to mitigation: Very Low. No significant habitat fragmentation or loss of

ecological connectivity is expected as this is essentially an infill development with a relatively small footprint.

Significance rating of impact prior to mitigation Low*

Degree to which the impact can be avoided: None Degree to which the impact can be managed: None Degree to which the impact can be mitigated: None Proposed mitigation: • Utilise suitable locally indigenous plant species for any stie

landscaping, such as Salvia africana-lutea, Polygala myrtifolia, Watsonia borbonica, Helichrysum patulum, Leucadendron salignum, Chasmanthe aethiopica, Robsonodendron peragua, Thamnochortus spicigerus, Lampranthus emarginatus, Pelargonium capitatum, Pelargonium cucullatum, Othonna quinquedentata, Agathosma serpyllacea and Cineriaria geifolia.

Residual impacts: None Cumulative impact post mitigation: Very Low Significance rating of impact after mitigation LOW

*Note: The botanical specialist confirmed the significance rating of Low prior to mitigation even though the “Convention” followed would indicate a different significance rating on the basis of an intensity rating of High. The reason is that the specialist rates the intensity of any loss of vegetation High, but the significance rating in this case is confirmed as Low in the light of the specific circumstances related to the study area as described in Section B6(d). Also refer to the specialist’s conclusions and recommendations in Section G3.

2.3 Potential impacts on ecological aspects: Freshwater ecosystems - Decrease in water quality Criteria Description Nature of impact: A decrease in water quality could result from discharge of

residential stormwater into natural areas. Extent and duration of impact: Local; long-term Intensity of impact or risk: Low to Medium Probability of occurrence: Probable Degree to which the impact may cause irreplaceable loss of resources: Low to medium

Degree to which the impact can be reversed: Partially reversible Indirect impacts: Pollution impacts from residential stormwater is possible

although not very likely Cumulative impact prior to mitigation: High Significance rating of impact prior to mitigation Low to Medium

Degree to which the impact can be avoided: Medium to High Degree to which the impact can be managed: Medium to High Degree to which the impact can be mitigated: Low Proposed mitigation: • No hardened surfaces or stormwater detention ponds may

be constructed within the recommended 15 m buffer area from the edge of the Glencairnvlei outlet channel.

• Construct roads, verges and parking areas with permeable materials, such as permeable paving, grass blocks, interlocking blocks, etc.

• Provide all roofs with adequate guttering leading into rainwater tanks, for storage and recycling of rainwater.

• Provide all remaining impermeable areas, as far as possible, with appropriate measures for reducing the quantity of runoff leaving hardened surfaces and entering stormwater systems, namely:


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o Vegetated filter strips (broad, sloped vegetated areas that accept shallow runoff from hardened surfaces);

o Bioswales (landscaped areas designed to remove silt and pollutants from runoff, through ensuring that water flows slowly along these gently sloping (<6% slope) features, often planted with grass or other plant species, mulch or riprap); and/or


• Rehabilitate the banks of the Glencairnvlei outlet in front of the hotel in accordance with the Operational EMP (see Appendix H2).

• A Rehabilitation Plan for the Glencairnvlei outlet must be prepared and submitted to the City of Cape Town for approval, prior to works commencing.

• Monitor the Glencairnvlei outlet for three years after the completion of construction in accordance with the Operational EMP (see Appendix H2).

Residual impacts: Low – pollution impacts may have some residual impact in the long-term

Cumulative impact post mitigation: Low to medium Significance rating of impact after mitigation LOW

2.4 Potential impacts on ecological aspects: Freshwater ecosystems – Changes in water inputs and flow patterns

Criteria Description Nature of impact: Discharge of slightly increased volumes of stormwater runoff

into the Glencairnvlei outlet channel would impact on the hydrology of this part of the vlei.

Extent and duration of impact: Local; long-term Intensity of impact or risk: Medium Probability of occurrence: Definite Degree to which the impact may cause irreplaceable loss of resources: Low

Degree to which the impact can be reversed: Partially reversible Indirect impacts: Medium Cumulative impact prior to mitigation: Medium Significance rating of impact prior to mitigation Low to medium

Degree to which the impact can be avoided: Low Degree to which the impact can be managed: Medium Degree to which the impact can be mitigated: Low Proposed mitigation: • Minimise the hardening of surfaces as far as possible and

retain or create natural areas, gardens and road verges where water can filter into the ground.

• Implement the mitigation measures to reduce stormwater volumes discharged from the site recommended in Section 2.3 above.

• Do not discharge stormwater directly into the wetland but manage it to flow along unlined swales, permeable areas, bioswales and/or unlined detention ponds.

• Investigate (during the detailed design phase) the viability of retaining accumulated stormwater runoff in (an) appropriate storage area(s) for recycling within the development.


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Residual impacts: Low Cumulative impact post mitigation: Low Significance rating of impact after mitigation LOW

2.5 Potential impacts on ecological aspects: Freshwater ecosystems – Disturbance of flora and fauna Criteria Description Nature of impact: Disturbance of wetland fauna and flora is likely due to the

proximity of the development to the vlei outlet channel. Extent and duration of impact: Local; long-term Intensity of impact or risk: Low Probability of occurrence: Probable Degree to which the impact may cause irreplaceable loss of resources: Low

Degree to which the impact can be reversed: Partially reversible Indirect impacts: Medium Cumulative impact prior to mitigation: Medium Significance rating of impact prior to mitigation Low

Degree to which the impact can be avoided: Low Degree to which the impact can be managed: Low Degree to which the impact can be mitigated: Low Proposed mitigation: • Ensure that lighting faces away from the wetland.

• Discourage domestic pets from entering the wetland and its buffer, through the appropriate use of fencing and gates.

Residual impacts: Low Cumulative impact post mitigation: Low Significance rating of impact after mitigation VERY LOW

2.6 Potential impacts on ecological aspects: Freshwater ecosystems – Spread and establishment of alien invasive plants

Criteria Description Nature of impact: Alien and invasive plants may establish and spread in the

wetland as a result of the introduction of seeds and seedlings and soil disturbance during construction.

Extent and duration of impact: Local; long-term Intensity of impact or risk: Medium Probability of occurrence: Probable Degree to which the impact may cause irreplaceable loss of resources: Low

Degree to which the impact can be reversed: Fully reversible Indirect impacts: High Cumulative impact prior to mitigation: High Significance rating of impact prior to mitigation Medium

Degree to which the impact can be avoided: Medium Degree to which the impact can be managed: High Degree to which the impact can be mitigated: Medium Proposed mitigation: • Keep landscaping to a minimum. Gardens should rather

be natural areas, where locally indigenous vegetation is allowed to grow.

• Do not allow any kikuyu grass anywhere on site. Use alternative grass species such as Cynodon dactylon or Paspalum vaginatum.

• Monitor and prevent the spread of alien plant species into all natural areas.

• Monitor road verges for alien species, especially grasses. Residual impacts: Low


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Cumulative impact post mitigation: Low Significance rating of impact after mitigation VERY LOW

2.7 Potential impacts on socio-economic aspects: Job security of existing labour force and additional job creation

Criteria Description Nature of impact: It is anticipated that additional staff would be employed when

the hotel is operational. The upgrading of the hotel, especially the inclusion of a new hotel wing and conference centre, kiosks, and lifestyle centre, would contribute to job security of the existing labour force and the continued socio-economic sustenance of themselves and their dependents. It would also create additional job opportunities for the community.

Extent and duration of impact: Local; medium-term Intensity of impact or risk: High Probability of occurrence: Highly probable Degree to which the impact may cause irreplaceable loss of resources: N/A

Degree to which the impact can be reversed: Reversible Indirect impacts: Low to Medium as employment and the associated income

would enhance quality of life of employees’ dependents. Cumulative impact prior to mitigation: Medium Significance rating of impact prior to mitigation Medium (positive)

Degree to which the impact can be avoided: Avoidance is not appropriate in the case of a positive impact Degree to which the impact can be managed: N/A Degree to which the impact can be mitigated: N/A Proposed enhancement: None identified Residual impacts: N/A Cumulative impact post mitigation: N/A Significance rating of impact after mitigation MEDIUM (POSITIVE)

2.8 Potential impacts on socio-economic aspects: Contribution to the local and regional economy Criteria Description Nature of impact: The provision of commercial and retail space as part of the

proposed upgrading of the hotel complex would stimulate local small business development and create additional job opportunities. The upgraded hotel complex would contribute to the development of tourism, which is an important driver of local and regional economic development.

Extent and duration of impact: Local to regional; medium- to long-term Intensity of impact or risk: Low Probability of occurrence: Highly probable Degree to which the impact may cause irreplaceable loss of resources: N/A

Degree to which the impact can be reversed: Reversible Indirect impacts: Low to Medium Cumulative impact prior to mitigation: Low Significance rating of impact prior to mitigation Low (Positive)

Degree to which the impact can be avoided: Avoidance is not appropriate in the case of a positive impact Degree to which the impact can be managed: Medium Degree to which the impact can be mitigated: N/A Proposed enhancement: None identified


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Residual impacts: N/A Cumulative impact post mitigation: Low Significance rating of impact after mitigation LOW (POSITIVE)

2.9 Potential impacts on heritage and cultural-historical: Upgrading of the Glencairn hotel Criteria Description Nature of impact: Heritage impacts would result from the proposed alteration to

the hotel, which is more than 60 years old (built in 1904). The hotel also has historical importance. The design plans have taken the heritage and historical importance of the site under consideration and was approved by HWC.

Extent and duration of impact: Local; permanent Intensity of impact or risk: High Probability of occurrence: Probable Degree to which the impact may cause irreplaceable loss of resources: N/A

Degree to which the impact can be reversed: Irreversible Indirect impacts: N/A Cumulative impact prior to mitigation: Medium Significance rating of impact prior to mitigation High

Degree to which the impact can be avoided: Low Degree to which the impact can be managed: High Degree to which the impact can be mitigated: Low Proposed mitigation: • The main focus had been avoidance of impacts by

developing, through iterative interaction with HWC, an appropriate concept design that complies with heritage standards and requirements for the restoration and conservation of the historic Glencairn Hotel. The concept design is encapsulated in project description.


Residual impacts: N/A Cumulative impact post mitigation: Low Significance rating of impact after mitigation LOW

2.10 Potential visual impacts Criteria Description Nature of impact: The site is considered a scenic location as it is visually

prominent when travelling towards Simon’s Town along the Main Road, which is a major tourist route on the False Bay coast of the South Peninsula. The proposed hotel upgrade and associated development would change the visual landscape of the site. The main visual alterations comprise an increased hotel surface area, the addition of new buildings behind the hotel, and a road and parking facilities in front of the hotel. Due consideration was given in the proposed concept design to alleviating potential visual impacts by means of sensitive design planning.

Extent and duration of impact: Local; long-term Intensity of impact or risk: Medium Probability of occurrence: Definite Degree to which the impact may cause irreplaceable loss of resources: Low

Degree to which the impact can be reversed: Irreversible


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Indirect impacts: None Cumulative impact prior to mitigation: None Significance rating of impact prior to mitigation Medium

Degree to which the impact can be avoided: Low Degree to which the impact can be managed: Low Degree to which the impact can be mitigated: None Proposed mitigation: • The main focus had been to develop an appropriate design

approach that would serve to avoid unacceptable visual effects and to alleviate the potential visual impacts as far as possible.

• This design approach entails the following: o Fragmenting the proposed development into separate

units of differing architectural design would reduce the overall sense of massing and lower the visual impact. The design approach was thus to avoid large, uniform, block-like built forms.


o Specific attention was paid to ways of emphasizing the historical heritage value of the hotel.

o The building height would not extend higher up the mountain backdrop than existing houses in Glencairn, and would be lower than neighbouring Cairnside to the south.

• Rehabilitate disturbed areas by means of appropriate landscaping to ensure that remaining open spaces along the hillside blend visually with the surroundings.

• Compile and submit a landscape plan for approval by the City of Cape Town prior to the commencement of construction. o Undertake re-vegetation in accordance with the landscape

plan. o Prior to site clearing or earthworks on the upper portions of

Erf 2454, locally indigenous plants suitable for reuse in landscaping should be “searched and rescued” from this area, by an appropriate specialist, in accordance with the landscape plan.

Residual impacts: None Cumulative impact post mitigation: None Significance rating of impact after mitigation MEDIUM

2.11 Potential noise impacts Criteria Description Nature of impact: The development would generate general noise, mainly from

the bar and restaurant, during the operational phase. It should be noted that general noise associated with the hotel has been emanating from the site since it has been in operation in the area. The bar and restaurant and similar facilities would be located in the middle and towards the front of the property facing towards the vlei and sea views and thus away from the main receptors in the adjacent residences.

Extent and duration of impact: Local; short- to medium-term


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Intensity of impact or risk: Low Probability of occurrence: Probable Degree to which the impact may cause irreplaceable loss of resources: N/A

Degree to which the impact can be reversed: Fully reversible Indirect impacts: None Cumulative impact prior to mitigation: None Significance rating of impact prior to mitigation Low

Degree to which the impact can be avoided: Medium to High Degree to which the impact can be managed: Medium to High Degree to which the impact can be mitigated: Low Proposed mitigation: • The hotel management and staff and all business owners

operating on the premises shall be familiar with and adhere to any local by-laws and regulations regarding the generation of noise and hours of operation.

• Strictly adhere to authorised hours of operation in accordance with operating licence(s).

Residual impacts: Isolated incidents of noise generated by clients after hours may still occur despite the implementation of appropriate mitigation measures.

Cumulative impact post mitigation: None Significance rating of impact after mitigation VERY LOW

3. IMPACTS THAT MAY RESULT FROM THE DECOMMISSIONING AND CLOSURE PHASE Not applicable because the hotel would not be decommissioned in the foreseeable future. NO-GO ALTERNATIVE

POTENTIAL IMPACTS ON SOCIO-ECOLOGICAL ASPECTS: UPGRADING OF GLENCAIRN HOTEL Criteria Description Nature of impact: The No-Go alternative is the option of not proceeding with the

proposed project. This option is not considered acceptable from a heritage perspective as it would mean that the historical and cultural value of the hotel would not be enhanced as a result of its suitable restoration in accordance with heritage standards and requirements. It is also not considered economically viable in the longer term as the development potential of the undeveloped portion of the site would not be unlocked in order to contribute to the local and regional economy. Additional recreational or social opportunities would not be provided for visitors and local residents. This alternative would adversely affect job security of the existing work force. It would not be possible to create the additional jobs envisaged during the construction phase of the proposed hotel upgrade. The creation of additional jobs envisaged as a result of the expansion of retail and commercial/office space would also not materialise.

Extent and duration of impact: Local to regional; long-term Consequence of impact or risk: Medium Probability of occurrence: Definite Degree to which the impact may cause N/A


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irreplaceable loss of resources: Degree to which the impact can be reversed: Reversible Indirect impacts: N/A Cumulative impact prior to mitigation: N/A Significance rating of impact prior to mitigation Medium

Degree to which the impact can be avoided: The impact can be avoided by implementing the proposed project, i.e. upgrading the existing Glencairn Hotel.

Degree to which the impact can be managed: N/A Degree to which the impact can be mitigated: N/A Proposed mitigation: N/A Residual impacts: N/A Cumulative impact post mitigation: N/A Significance rating of impact after mitigation Medium

(c) Provide a summary of the site selection matrix.

As described in Section E1(a), no location or site alternatives were identified as the location of the proposed upgrade is determined by the location of the property. Thus only the preferred alternative was assessed and compared to the No-Go Option, namely to upgrade and expand the existing Glencairn Hotel to a mix of residential, retail and office space in the remaining undeveloped portion of the Glencairn Hotel site in Glencairn. In summary it can be stated that Alternative 1 is considered feasible from an ecological, socio-economic, and cultural heritage perspective. The No-Go Option is not considered feasible or desirable in the long-term mainly because the development potential of the undeveloped portion of the site would not be unlocked in order to contribute to the local and regional economy.

(d) Outcome of the site selection matrix.

A comparison of Alternative 1 and the No-Go Option resulted in the conclusion that Alternative 1 is the most appropriate and feasible alternative.

3. SPECIALIST INPUTS / STUDIES, FINDINGS AND RECOMMENDATIONS Provide a summary of the findings and impact management measures identified in any specialist report and an indication of how these findings and recommendations have been included in the BAR.

Botanical Assessment The key conclusions and recommendations of the botanical study are summarised below. Refer to Appendix G1 for the full report. • Conclusions:

o The underlying vegetation type in the study area is Critically Endangered Peninsula Sandstone Fynbos, but the development footprint is very small, is surrounded on three sides by urban development, and about 30% of the site is of Low sensitivity and has been heavily disturbed, while about 70% is of Medium botanical sensitivity. No plant Species of Conservation Concern were found in the study area, and the vegetation type concerned is well conserved and under relatively little threat throughout its range. Less than 5% of the site is a designated CBA in the City of Cape Biodiversity Network mapping.

o Construction and operational phase botanical impacts are likely to be Low negative before and after mitigation, with no irreplaceable loss of habitat or botanical resources.

o On balance there are no significant botanical reasons why the proposed project should not be authorised, and no special mitigation is required.

• Recommendations: o It is recommended that any site landscaping should use suitable locally indigenous plant species, such as

Salvia africana-lutea, Polygala myrtifolia, Watsonia borbonica, Helichrysum patulum, Leucadendron salignum, Chasmanthe aethiopica, Robsonodendron peragua, Thamnochortus spicigerus, Lampranthus emarginatus, Pelargonium capitatum, Pelargonium cucullatum, Othonna quinquedentata, Agathosma


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serpyllacea and Cineriaria geifolia. Freshwater Assessment The key conclusions and required recommendations of the freshwater study are summarised below. Refer to Appendix G2 for the full report. • The proposed upgrade and development of the Glencairn Hotel site will affect the outlet channel of

Glencairnvlei. Glencairnvlei is fed by the Else River, which rises as a seasonal stream on the slopes between Grootkop and Red Hill. The river is approximately 7 km long and drains an 18 km2 catchment. Historically, Glencairnvlei was probably a seasonal system, with areas of open water occurring during the wet winter months, and drying up over summer (Day, 2001). The mouth of the vlei would generally have been closed, opening only after heavy rains in winter

• Erf 235 is located on the banks of the vlei outlet, and a proposed parking is planned to be constructed to the full extent of the erf. Erf 235 is essentially a flat plot, currently used for parking space and some commercial activities. The land not tarred for parking is covered by kikuyu grass, which has spread down the slope towards the Glencairnvlei outlet, with a few other planted exotic species. The vegetation type historically found on both erven is Cape Flats Dune Strandveld, an endangered vegetation type that occurs on alkaline sands.

• The current ecological condition of the Glencairnvlei has been significantly impacted by alterations to the natural hydrological regime of the ecosystem. This is due to the impoundment and abstraction of water in the upper Else River catchment (Kleinplaas and Lewis Gay dams), with smaller weirs and causeways located along the length of the remaining river. The shape and alignment of the wetland channels have also been altered through limited infilling for the construction of bridges over the river, and encroachment of developed areas on either side of the vlei. Flow obstructions and abstraction also lead to the loss of flushing flows through the system, and the build-up of sediments. The vegetation in the vlei has responded to these changes in hydrology and geomorphology, leading to establishment of beds of reeds and bulrush, instead of a more diverse wetland community. These existing impacts are reflected by the PES scores calculated for Glencairnvlei, giving the wetland an overall wetland PES of D – largely modified.

• The overall ecological importance and sensitivity of Glencairnvlei is high (score of 3), while the hydrological/functional importance is moderate and the human use rating is low. The latter is due to the fact that the vlei does not provide services of direct benefit to the surrounding communities, such as potable or irrigation water, harvestable resources (such as reeds and restios, fish etc) or crops. The vlei does, however, provide an important feeding / breeding / migration node, in an increasingly urban area. While the species that the vlei supports are not necessarily rare or endangered, these species are important in terms of the overall biodiversity of the ecosystem. In addition, the vlei is sensitive to changes in low flows and water quality.

• The recommended minimum buffer for Glencairnvlei is 15 m measured from the edge of the outlet wetland (as delineated in this report), for both the construction and operational phases, assuming that the vegetation cover currently covering the slope between the parking area and the outlet channel is revegetated with appropriate low-growing vegetation, as opposed to kikuyu grass.

• The most effective mitigation measure is avoidance of an impact. It is felt that the expected impacts associated with the proposed construction and operation of the Glencairn Hotel site development would best be mitigated through ensuring that no hardened surfaces are constructed within the recommended ecological buffer of 15 m. An exception to this could be a wooden walkway.

• In addition to the recommended buffer, further mitigation measures deal with the reduction in the amount of stormwater runoff generated by the development, and improvement in the quality of water exiting the property. These measures focus quite strongly on the re-use of water on the property, which is appropriate given the water supply crisis currently persisting in the Western Cape. A proportion of the stormwater, combined with rainwater, could be cycled back into the development for re-use.

• In the light of these recommendations, the amount of runoff accumulating at the lower end of the site should not require storage within a detention pond. This may need to be verified by an engineer.

• In addition to water re-use, it is advised that all runoff be allowed to flow along unlined channels, wherever possible, with water being allowed to filter into landscaped areas. New parking areas should be constructed with permeable materials.

• Implementation of the mitigation measures recommended in this report will ensure that the risks to Glencairnvlei are of low negative significance, thus qualifying the proposed activities for general authorisation, according to GN 509 (2016), despite the proposal being located within 500 m of a wetland.


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• It is recommended that the banks of the Glencairnvlei outlet be rehabilitated. It is envisaged that the proposed rehabilitation will ensure that the PES of the vlei will not decrease, and may even lead to an improvement in condition locally at the outlet. The objectives of rehabilitation would be as follows: o Improved biodiversity value: This will be achieved through re-shaping and planting of the banks with

appropriate wetland plants. These plants will attract a wider range of faunal groups (e.g. invertebrates such as dragonflies and damselflies, or vertebrates such as frogs and birds), than has previously inhabited or passed through the site. All invasive alien plants must be cleared from the area. These species tend to grow in disturbed soils, especially where there is available water, spreading further into previously undisturbed areas.

o Improved water quality: Planting of the banks will ensure that any stormwater entering the system will flow slowly through beds of plants and sediments, which play an important role in taking up excess nutrients and in capturing sediments, toxins and hydrocarbons. In this way, runoff entering Glencairnvlei is likely to be of good quality and unlikely to lead to a deterioration in water quality.

o Improved infiltration: Water attenuated by the rehabilitated areas will filter slowly into the ground, thereby improving the subsurface flow of water in the area.

o Maintenance of natural slope and geomorphology: The more gentle slope for the vlei banks in front of the hotel will reduce the likelihood of erosion and downstream sedimentation.

• The vlei outlet area should be monitored seasonally for at least three years after construction is completed. The rehabilitated banks should be monitored for invasive alien plant encroachment, and for the establishment of indigenous plants in revegetated areas. A very basic set of water quality variables should be monitored every 3 months in the vlei outlet itself – this should include in situ electrical conductivity, turbidity, pH, dissolved oxygen and chlorophyll-a (in the water column).

• The requirement for monitoring is stipulated in GN 509 (see Section 4.6). The reasoning for this is to ensure that the risks/impacts identified and assessed are indeed of (at worst) low negative significance. The recommended monitoring indicators listed above will record sufficient information to make this judgement call.

• It is the duty of the property owner (or homeowners association, for residential developments) to ensure that the monitoring takes place. Monitoring should be done by a suitably qualified freshwater ecologist. Annual reports (containing the data collected seasonally, i.e. every 3 months) must be submitted to the relevant DWS official (Bellville office).

4. ENVIRONMENTAL IMPACT STATEMENT Provide an environmental impact statement of the following:

(i) A summary of the key findings of the EIA. The proposed upgrading of the historic Glencairn Hotel would entail a number of positive long-term impacts which would be of benefit to the local and regional community. The proposed development of the hotel complex would contribute to the local and regional economy, resulting in an impact of LOW (POSITIVE) significance; and it would contribute to job security of the existing hotel work force and create additional jobs, an impact rated as of LOW (POSITIVE) significance. The most substantive potential impact of the proposed project is the heritage impact of altering the historic Glencairn Hotel that dates from 1904 and has been a landmark in the cultural environment of the South Peninsula for more than a century. The main focus had been avoidance of impacts by developing, through iterative interaction with HWC, an appropriate design that complies with heritage standards and requirements for the restoration and conservation of the historic Glencairn Hotel. The concept design generated and approved by HWC in 2004 was confirmed in January 2018. The project description proposed as the only feasible project alternative for this application adheres to the agreed concept design approved by HWC. The proposed project is thus acceptable from the heritage perspective. The potential visual impact of the proposed project is also an important aspect in the light of the scenic tourism value of the site in the context of its prominence along the Glencairn Mountain slope from the perspective of the coastal Main Road towards Simon’s Town. In this regard, the main focus had been to develop an appropriate design approach that would serve to avoid unacceptable visual effects and to alleviate the potential visual impacts as far as possible. Thus the potential visual impact has been addressed at the design phase by means of an


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appropriate design that is aligned to the heritage standards and requirements for upgrading the historic hotel building. The proposed mitigation measures would reduce the negative biophysical impacts to a VERY LOW to LOW significance during the construction and the operational phases. The potential negative impact of the proposed project on the Glencairnvlei outlet channel in the longer term during the operational phase could be effectively managed and monitored by the implementation of the Operational EMP developed for this purpose. (ii) Has a map of appropriate scale been provided, which superimposes the

proposed development and its associated structures and infrastructure on the environmental sensitivities of the preferred site, indicating any areas that should be avoided, including buffers?

See Figure B5 in Appendix B

YES NO

(iii) A summary of the positive and negative impacts that the proposed development and alternatives will

cause in the environment and community. ALTERNATIVE 1: Development phase – planning, design and construction: A limited number of potential impacts associated with the design and development phase have been identified and are discussed below (see Table 1): • One potential positive impact that may occur during the construction phase has been identified, namely the

provision of employment opportunities, which has been rated as of VERY LOW (Positive) significance. • Two of the three potential ecological impacts anticipated as a result of construction activities have been rated as

of LOW significance after mitigation, namely the loss of terrestrial vegetation and the loss of open space within the sub-catchment area. The third ecological impact identified, namely the destruction, deterioration or pollution of the wetland habitat as a result of construction activities, has been rated as of VERY LOW significance after mitigation.

• The only other negative impact identified relate to noise, dust and visual impacts associated with construction phase activities. This has also been rated as of VERY LOW significance after mitigation.

Table 1: Impacts during the development phase (all impacts are negative unless stated otherwise)

Impact Significance without mitigation Significance with mitigation Ecological Aspects:

Terrestrial vegetation – Loss of vegetation Low LOW Freshwater ecosystems – Loss of open space within the sub-catchment area Low LOW

Freshwater ecosystems – Destruction, deterioration or pollution of wetland habitat Low VERY LOW

Socio-economic Aspects: Employment Very Low (Positive) VERY LOW (POSITIVE) Construction-related dust, noise and visual Low VERY LOW

T Operational phase: Most of the potential impacts of the proposed project are expected to occur during the operational phase (see Table 2 - overleaf). The ecological impacts relate to potential impacts of the proposed project on the terrestrial and wetland environment, namely: • Loss of all current partial ecological connectivity across the site, rated as of LOW significance after mitigation; • Decrease in water quality, rated as of LOW significance after mitigation; • Changes in water inputs and flow patterns, rated as of LOW significance after mitigation; • Disturbance of wetland flora and fauna, rated as of VERY LOW significance after mitigation; and • Spread and establishment of alien invasive plants in the Glencairnvlei outlet channel, rated as of VERY LOW

significance after mitigation. Both the potential socio-economic impacts identified would be positive, namely: • Job security of the existing work force and the creation of additional jobs, rated as of MEDIUM (POSITIVE)

significance; and • Contribution to the local and regional economy, rated as of LOW (POSITIVE) significance.


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The potential visual impact of the proposed development has been rated as of MEDIUM significance after mitigation, while the potential noise impact has been rated as of VERY LOW significance after mitigation. The historic Glencairn Hotel building, which was erected in 1904, has been identified as a significant cultural-historical resource. The potential negative impact of the proposed upgrading of the hotel has been rated as of LOW significance after mitigation. Appropriate mitigation measures were developed in an iterative process with HWC before the proposed alternative was approved in 2004. In January 2018, HWC confirmed that no further action is required in terms of NHRA. Table 2: Impacts during the operational phase

Impact Significance without mitigation Significance with mitigation

Ecological Aspects: Terrestrial vegetation – Loss of ecological connectivity Low LOW

Freshwater ecosystems – Decrease in water quality Low to Medium LOW

Freshwater ecosystems – Changes in water inputs and flow patterns Low to Medium LOW

Freshwater ecosystems – Disturbance of flora and fauna Low VERY LOW

Freshwater ecosystems – Spread and establishment of alien invasive plants Medium VERY LOW

Socio-economic Aspects: Job security of existing labour force and additional job creation Medium (Positive) MEDIUM (POSITIVE)

Contribution to the local and regional economy Low (Positive) LOW (POSITIVE) Cultural-historical aspects:

Upgrading of the Glencairn Hotel High LOW Visual Medium MEDIUM Noise Low VERY LOW

NO-GO ALTERNATIVE:

The No-Go Option would mean that the Glencairn Hotel would not be upgraded, which means that the development potential of the undeveloped portion of the site would not be unlocked in order to contribute to the local and regional economy. Additional recreational or social opportunities would not be provided for visitors and local residents. This alternative would adversely affect job security of the existing work force. It would not be possible to create the additional jobs envisaged during the construction phase of the proposed hotel upgrade. The creation of additional jobs envisaged as a result of the expansion of retail and commercial/office space would also not materialise. This option is also not considered acceptable from a heritage perspective as it would mean that the historical and cultural value of the hotel would not be enhanced as a result of its suitable restoration in accordance with heritage standards and requirements. The impact of implementing the No-Go option was rated of MEDIUM negative significance (see Table 3). The No-Go option is thus not considered to be a sustainable or desirable option. Table 3: Impacts associated with the No-Go Option

Impact Significance without mitigation Significance with mitigation

Upgrading of the Glencairn Hotel Medium MEDIUM

5. IMPACT MANAGEMENT, MITIGATION AND MONITORING MEASURES (a) Based on the assessment, describe the impact management, mitigation and monitoring

measures as well as the impact management objectives and impact management outcomes included in the EMPr. The EMPr must be attached to this report as Appendix H.

Design phase A number of mitigation measures relevant to the design phase have already been incorporated into the design proposed for implementation as Alternative 1. Additional management, mitigation and monitoring measures are recommended for the design phase in order to avoid or minimise operational phase impacts before implementation


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of the proposed project. This includes the following: In relation to cultural-heritage aspects:

• The main focus had been avoidance of impacts by developing, through iterative interaction with HWC, an appropriate concept design that complies with heritage standards and requirements for the restoration and conservation of the historic Glencairn Hotel. The concept design is encapsulated in the project description.


In relation to visual aspects: • The main focus had been to develop an appropriate design approach that would serve to avoid

unacceptable visual effects and to alleviate the potential visual impacts as far as possible. • This design approach entails the following:

o Fragmenting the proposed development into separate units of differing architectural design would reduce the overall sense of massing and lower the visual impact. The design approach was thus to avoid large, uniform, block-like built forms.


o Specific attention was paid to ways of emphasizing the historical heritage value of the hotel. o The building height would not extend higher up the mountain backdrop than existing houses in

Glencairn, and would be lower than neighbouring Cairnside to the south.

In relation to freshwater ecology: • No hardened surfaces or stormwater detention ponds may be constructed within the recommended 15 m

buffer area from the edge of the Glencairnvlei outlet channel. • Construct roads, verges and parking areas with permeable materials, such as permeable paving, grass

blocks, interlocking blocks, etc. • Provide all roofs with adequate guttering leading into rainwater tanks, for storage and recycling of

rainwater. • Provide all remaining impermeable areas, as far as possible, with appropriate measures for reducing the

quantity of runoff leaving hardened surfaces and entering stormwater systems, namely: o Vegetated filter strips (broad, sloped vegetated areas that accept shallow runoff from hardened

surfaces); o Bioswales (landscaped areas designed to remove silt and pollutants from runoff, through ensuring

that water flows slowly along these gently sloping (<6% slope) features, often planted with grass or other plant species, mulch or riprap); and/or


• Minimise the hardening of surfaces as far as possible and retain or create natural areas, gardens and road verges where water can filter into the ground.

• Investigate the viability of retaining accumulated stormwater runoff in (an) appropriate storage area(s) for recycling within the development.

Development phase Construction activities would be managed through effective implementation of a Construction Environmental Management Programme (EMP) for this project and thus the key recommendation is to comply with the Construction EMP (see Appendix H1). The following mitigation measures have been included in the Construction EMP: In relation to terrestrial vegetation:

• Restrict all construction-related disturbance to the authorised development footprint, which should be demarcated with coloured rope or fencing prior to any development on site.


SLR Ref. 720. 02065.00001 Report No. 2


• Ensure that no heavy machinery or stored or dumped material impact on adjacent areas. • Plant Search and Rescue would not change the significance levels of vegetation loss, as all translocatable

species in the development footprint are well represented outside the footprint.

In relation to freshwater ecology • Establish a 15 m buffer area around the edge of the Glencairnvlei outlet channel. • Ensure that all buildings and infrastructure are located outside of the vlei buffer area. • Store all building materials at least 15 m away from the edge of the wetland area, as demarcated prior to

construction. Storage areas must be bunded adequately to prevent contaminated runoff from entering the wetland.


• Re-plant all areas that are impacted by the storage of materials after construction is complete. • Construction close to the wetland (i.e. on Erf 235) must take place during the dry season, to reduce the

risks of contamination of the ecosystem through rainfall and runoff. • Concrete mixing must take place as far as possible way from the 15 m buffer area around the edge of the

Glencairnclei outlet channel. • Locate machinery prone to oil or fuel leakage at least 15 m away from the edge of the wetland, in an area

adequately bunded in order to contain leakages. • Use drip trays for water pumps and cement mixers to contain oil and fuel leaks. • Clean all drip trays regularly. • Provide suitable toilet and wash facilities to avoid the use of sensitive areas for these activities. These

service areas must be regularly maintained and toilets emptied on at least a weekly basis. • Route pathways and access roads around the wetland and its buffer area. • Clearly demarcate and fence off sensitive areas as no-go areas (using temporary fencing and danger

tape) before the start of any construction work or site preparation. • Direct lights (if used) away from the wetland. • Inspect the site for erosion damage during storm and heavy rain events. • Direct pumped water from construction areas (e.g. after rains) into a settlement area, and not directly into

the wetland. • Source top material from a reliable source, and check it for invasie alien plant seedlings before use. • Monitor the construction site constantly for alien plant growth and eradicate alien plant species. • A Rehabilitation Plan for the Glencairnvlei outlet must be prepared and submitted to the City of Cape Town for

approval, prior to works commencing. In relation to employment:

• Employ local BEE services and providers and local labour from the local community as far as possible. • Ensure appropriate training is provided, where required.

In relation to control of dust, noise and visual disturbance to local residents:

• Maintain all construction machinery and vehicles in good working order. • Be familiar with and adhere to, any local by-laws and regulations regarding the generation of noise and

hours of operation. • Avoid construction activities outside of “normal working hours”. • Ensure that the generation of dust is minimised and implement a dust control programme (e.g. wetting of

disturbed areas) to maintain a safe working environment and minimise nuisance for local residents and road users.

• Ensure that the exposed soil and material stockpiles are adequately protected against the wind. • Implement litter control measures and appropriate measures for visual screening.

Operational Phase The following management, mitigation and monitoring measures are recommended for the operational phase:


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In relation to terrestrial vegetation: Utilise suitable locally indigenous plant species for any site landscaping, such as Salvia africana-lutea, Polygala myrtifolia, Watsonia borbonica, Helichrysum patulum, Leucadendron salignum, Chasmanthe aethiopica, Robsonodendron peragua, Thamnochortus spicigerus, Lampranthus emarginatus, Pelargonium capitatum, Pelargonium cucullatum, Othonna quinquedentata, Agathosma serpyllacea and Cineriaria geifolia. In relation to freshwater ecology: Potential impacts on the Glencairnvlei outlet channel would be managed and monitored through effective implementation of the Operational EMP for this purpose. Details regarding an appropriate rehabilitation and monitoring plan for the Glencairnvlei outlet channel are contained in the Operational EMP (see Appendix H2). The key recommendation is thus to comply with the Operational EMP. The following mitigation measures are also recommended for implementation during the operational phase:

• Do not discharge stormwater directly into the wetland but manage it to flow along unlined swales, permeable areas, bioswales and/or unlined detention ponds.

• Ensure that lighting faces away from the wetland. • Discourage domestic pets from entering the wetland and its buffer, through the appropriate use of fencing

and gates. • Keep landscaping to a minimum. Gardens should rather be natural areas, where locally indigenous

vegetation is allowed to grow. • Do not allow any kikuyu grass anywhere on site. Use alternative grass species such as Cynodon

dactylon or Paspalum vaginatum. • Monitor and prevent the spread of alien plant species into all natural areas. • Monitor road verges for alien species, especially grasses.

In relation to visual impacts:

• Rehabilitate disturbed areas by means of appropriate landscaping to ensure that remaining open spaces along the hillside blend visually with the surroundings.

• Compile and submit a landscape plan for approval by the City of Cape Town prior to the commencement of construction. o Undertake re-vegetation in accordance with the landscape plan. o Prior to site clearing or earthworks on the upper portions of Erf 2454, locally indigenous plants suitable for

reuse in landscaping should be “searched and rescued” from this area, by an appropriate specialist, in accordance with the landscape plan.

In relation to noise:

• The hotel managment and staff and all business owners operating on the premises shall be familiar with and adhere to, any local by-laws and regulations regarding the generation of noise and hours of operation.

• Strictly adhere to authorised hours of operation in accordance with operating licence(s). (b) Describe any provisions for the adherence to requirements that are prescribed in a Specific

Environmental Management Act relevant to the listed activity or specified activity in question.

Specific Environmental Management Acts do not apply to the proposed project. (c) Describe the ability of the applicant to implement the management, mitigation and

monitoring measures. The Applicant is regarded as fully capable of implementing the management, mitigation and monitoring measures included in the EMP, consisting of the Construction EMP, which would ensure effective environmental management during the development phase, and the Operational EMP, which would ensure effective rehabilitation and environmental monitoring and management of any potential impacts on the Glencairnvlei outlet channel. The


SLR Ref. 720. 02065.00001 Report No. 2


main reason is that Glencairn Hotel (Pty) Ltd is a registered company which would operate the hotel complex as a business entity. As such, it would generate increased income from the upgraded hotel complex. The surrounding environment forms an important resource for the long-term success of the complex as it enhances its tourism potential. It is thus in the interest of the Applicant to manage potential impacts on the environment, including the Glencairnvlei outlet channel, in such a manner that it can continue to function optimally in the future.

(d) Provide the details of any financial provisions for the management of negative

environmental impacts, rehabilitation and closure of the proposed development. Please refer to item 5(c) above.

(e) Describe any assumptions, uncertainties, and gaps in knowledge which relate to the impact

management, mitigation and monitoring measures proposed. No assumptions, uncertainties, and gaps in knowledge have been identified in this regard.


SLR Ref. 720. 02065.00001 Report No. 2


SECTION H: RECOMMENDATIONS OF THE EAP AND SPECIALISTS

(a) In my view as the appointed EAP, the information contained in this BAR and the documentation attached hereto is sufficient to make a decision in respect of the listed activity(ies) applied for.

YES NO

(b) If the documentation attached hereto is sufficient to make a decision, please indicate below whether, in your opinion, the listed activity(ies) should or should not be authorised:

Listed activity(ies) should be authorised: YES NO

Provide reasons for your opinion As mentioned in the Environmental Statement (see Section G4(i) above), the proposed upgrading of the historic Glencairn Hotel would entail a number of positive long-term impacts which would be of benefit to the local and regional community. The proposed development of the hotel complex would contribute to the local and regional economy and it would contribute to job security of the existing hotel work force and create additional jobs. The concept design generated and approved by HWC in 2004 focuses on avoiding impacts by means of an appropriate design that complies with heritage standards and requirements for the restoration and conservation of the historic Glencairn Hotel. The project description proposed as the only feasible project alternative for this application adheres to the agreed concept design approved by HWC. The proposed project is thus acceptable from the heritage perspective. The potential visual impact of the proposed project has also been addressed at the design phase by means of an appropriate design aligned to the heritage standards and requirements for site. The proposed negative biophysical impacts can be effectively managed and mitigated during the development as well as the operational phases by the implementation of the EMP, comprising the Construction EMP and the Operational EMP developed for this purpose. The No-Go Option is not considered desirable and feasible in the long term as the development potential of the site would not be unlocked in order to contribute to the local and regional economy, including the creation of jobs. All recommended mitigation measures are deemed feasible for implementation and the proposed project is deemed to be socially, environmentally and economically acceptable. (c) Provide a description of any aspects that were conditional to the findings of the assessment by the

EAP and Specialists which are to be included as conditions of authorisation. None identified. (d) If you are of the opinion that the activity should be authorised, please provide any conditions,

including mitigation measures that should in your view be considered for inclusion in an environmental authorisation.

Development phase Construction activities would be managed through effective implementation of a Construction Environmental Management Programme (EMP) for this project and thus the key recommendation is to comply with the Construction EMP (see Appendix H1). This includes the appointment of an independent Environmental Control Officer to ensure compliance in this regard. Operational Phase Potential operational phase impacts on the Glencairnvlei outlet channel would be managed and monitored through effective implementation of the Operational EMP for this purpose and thus the key recommendation is to comply with the Operational EMP (see Appendix H2) (e) Please indicate the recommended periods in terms of the following periods that should be

specified in the environmental authorisation: i. the period within which commencement must occur; Five years ii. the period for which the environmental authorisation is

granted and the date on which the development proposal will have been concluded, where the environmental authorisation does not include operational aspects;

N/A


SLR Ref. 720. 02065.00001 Report No. 2


iii. the period for which the portion of the environmental authorisation that deals with non-operational aspects is granted; and

Ten years for the completion of the project development phase.

iv. the period for which the portion of the environmental authorisation that deals with operational aspects is granted.

Until the hotel is decommissioned, which is not anticipated.


SLR Ref. 720. 02065.00001 Report No. 2


SECTION I: APPENDICES The following appendices must be attached to this report:

Appendix Tick the box if Appendix is attached

Appendix A: Locality Map

Appendix B:

Site development plan(s)

A map of appropriate scale, which superimposes the proposed development and its associated structures and infrastructure on the environmental sensitivities of the preferred site, indicating any areas that should be avoided, including buffer areas

Appendix C: Photographs Appendix D: Biodiversity overlay map

Appendix E:

Permit(s) / license(s) from any other Organ of State, including service letters from the municipality

Appendix E1: Copy of relevant documentation submitted to HWC Appendix E2: Comment from HWC Appendix E3: Confirmation of service availability from City of Cape Town Appendix E4: Proof of submission of Water Use Authorisation Application to

DWS

Appendix F:

Public Participation Information Appendix F1: I&AP database Appendix F2: Advertisement and Site Notice Appendix F3: I&AP Notification Letters Appendix F4: Information session held on 31 May 2018 Appendix F5: BAR Comments and Responses Report 1 – Authorities Appendix F5: BAR Comments and Responses Report 2 – I&APs

Appendix G:

Specialist Report(s) Appendix G1: Botanical specialist report for Basic Assessment process

for Proposed Glencairn Hotel Development (Erf 2454), Glencairn, Cape Town

Appendix G2: Glencairn Hotel: Freshwater ecological input to Basic Assessment

Appendix H: Environmental Management Programme Appendix H1: Construction Environmental Management Programme Appendix H2: Operational Environmental Management Programme

Appendix I: Additional information related to listed waste management activities (if applicable) N/A

Appendix J: If applicable, description of the impact assessment process followed to reach the proposed preferred alternative within the site Appendix J1: Convention for assigning impact assessment ratings

Appendix K: Any Other (if applicable). Appendix K1: CV of lead Environmental Assessment Practitioner Appendix K2: Letter from Cape Peninsula Fire Protection Association


SLR Ref. 720. 02065.00001 Report No. 2


THE REVIEW ENVIRONMENTAL ASSESSMENT PRACTITIONER – NOT APPLICABLE I ………………………………………………………., as the appointed Review EAP hereby declare/affirm: • that I have reviewed all the work produced by the EAP; • the correctness of the information provided as part of this Report; • that I have, throughout this EIA process met all of the general requirements of EAPs as set out in

Regulation 13; • I have, throughout this EIA process disclosed to the applicant, the EAP, the specialist (if any), the

review specialist (if any), the Department and I&APs, all material information that has or may have the potential to influence the decision of the Department or the objectivity of any report, plan or document prepared as part of the application; and

• am aware that a false declaration is an offence in terms of Regulation 48 of the EIA Regulations, 2014 (as amended).

Signature of the Review EAP:

Name of Company:

Date:


SLR Ref. 720. 02065.00001 Report No. 2


THE REVIEW SPECIALIST – NOT APPLICABLE I ………………………………………………………., as the appointed Review Specialist hereby declare/affirm:

• that I have reviewed all the work produced by the Specialist(s); • the correctness of the specialist information provided as part of this Report; • that I have, throughout this EIA process met all of the general requirements of specialists as set out

in Regulation 13; • I have, throughout this EIA process disclosed to the applicant, the EAP, the review EAP (if

applicable), the Specialist(s), the Department and I&APs, all material information that has or may have the potential to influence the decision of the Department or the objectivity of any report, plan or document prepared as part of the application; and

• I am aware that a false declaration is an offence in terms of Regulation 48 of the EIA Regulations, 2014 (as amended).

Signature of the Review Specialist:

Name of Company:

Date:

Documents

BASIC ASSESSMENT REPORT FOR THE PROPOSED UPGRADING … · Erf 2452 and the Reminder of Erf 235, Glencairn Prepared for: Glencairn Hotel (Pty) Ltd ... Keywords Hotel, Glencairn, upgrade