PROPOSED UMSOBOMVU WIND ENERGY FACILITY, NORTHERN … Wind Energy CE200215/EIAr... · PROPOSED UMSOBOMVU WIND ENERGY FACILITY, NORTHERN CAPE & EASTERN CAPE ... EIR documentation submitted

PROPOSED UMSOBOMVU WIND ENERGY FACILITY, NORTHERN CAPE & EASTERN CAPE PROVINCES

DEA Reference: 14/12/16/3/3/2/730

ENVIRONMENTAL IMPACT ASSESSMENT REPORT: AMENDMENT SUMMARY REPORT

Prepared for:

Umsobomvu Wind Power (Pty) Ltd.

PO Box 71664, Port Elizabeth, 6006

South Africa www.innowind.com

Prepared by:

EOH Coastal & Environmental Services GRAHAMSTOWN 67 African Street

Grahamstown, 6140 046 622 2364

Also in East London, Port Elizabeth, Cape Town, Johannesburg and Maputo (Mozambique)

www.cesnet.co.za | www.eoh.co.za

August 2016

http://www.innowind.com/

http://www.eoh.co.za/

Umsobomvu Wind Energy Facility – Amendment Summary August 2016

EOH Coastal & Environmental Services 2 Umsobomvu Wind Energy Facility

COPYRIGHT INFORMATION This document contains intellectual property and proprietary information that is protected by copyright in favour of Coastal & Environmental Services and the

specialist consultants. The document may therefore not be reproduced, used or distributed to any third party without the prior written consent of Coastal &

Environmental Services. This document is prepared exclusively for submission to Umsobomvu Wind Power (Pty) Ltd, and is subject to all confidentiality, copyright and

trade secrets, rules intellectual property law and practices of South Africa.



1. INTRODUCTION Upon review of the Final EIR documentation submitted to the DEA April 2016, the Department rejected the report citing grounds contained in the letter in Section 1.1 of this report. This document serves as a summary of how the grounds stated in the rejection letter were addressed. Where necessary, the corrections have been made to the relevant documents, and indicated as such, by underlining.

1.1 Rejection Letter from the DEA









1.2 Summary Table: Response to Rejection Letter from the DEA

UMSOBOMVU WEF (DEA REF: 14/12/16/3/3/2/730) RESPONSE TO DEPARTMENT OF ENVIRONMENTAL AFFAIRS (DEA) LETTER OF REJECTION OF

ENVIRONMENTAL IMPACT ASSESSMENT (EIA) REPORT

DEA Rejection Letter statements and requirements

Responses from the EAP

DEA requests that the EIAr be amended to include the following as a matter of urgency

a) The application form must be amended to include the applicable listed activities and the activity description with the thresholds.

The amended application form has been prepared and meets the DEA requests in Section A of the DEA Letter of Rejection of EIAr. Table attached here as Appendix A.

b) The application form and EIAr must be amended to include a description of project activity that triggers listed activities applied for. (Make use of new DEA template)

The amended application form, on the updated DEA template, includes a description of the proposed project activity that triggers the listed activities. Table attached here as Appendix A.

c) The Department advises that the following listed activities and their relevant issues be addressed and assessed adequately:

GN R. 544 Item 10 The activity description in the application form as well as the EIAr does not provide an indication of the powerline capacity and length. The Environmental Assessment Practitioner (EAP) is requested to include this in the amended application form and amended EIAr

GN R. 544 Item 13 It is requested that the EAP provide additional information detailing the specifications of the proposed dangerous goods, i.e. quantities, type of goods etc. as well as the infrastructure to be used as storage on the facility. The amended EIAr must include an assessment of the

Please refer to Chapter 2.4.1 of the AMENDED EIAr as well as the GENERAL Impacts Table (Appendix C) Please refer to the Avifaunal Impact Assessment (Appendix B) Please refer to the AMENDED Application Form “4 short powerlines to connect the WEF into the existing 400 kV Eskom Transmission (Hydra/Poseidon) Powerline which runs through the site

33 kV overhead lines (1.5 km) – connecting the internal reticulation network of cables from the turbines to the IPP Substation

132 kV (0.1 km) – connecting the IPP Substation to the Eskom MTS Substation

Two 400 kV (0.1 km x 2 = 0.2 km) – connecting the Eskom MTS Substation to the 400 kV Eskom Transmission (Hydra/Poseidon) Powerline”

Please refer to Chapter 2.4.2 of the AMENDED EIAr as well as the GENERAL Impacts Table (Appendix C) Please refer to the AMENDED Application Form “The construction period is expected to last 24 months. The construction dangerous goods amount to 191.23 m3 while the operational dangerous good amount to 216.10 m3. This equates to a total of 407.33 m3 of dangerous goods for the lifespan of the project.”



impacts of the types and quantity of the dangerous goods as well as the identification of appropriate storage areas for these goods.

GN R. 544 Item 18 The Applicant must provide an indication of the preferred and alternate locations from which the material used for infilling will be sourced and where excavated material will be stored and/or disposed of. In addition, the impacts associated with this activity must be adequately assessed in the amended EIAr.

GN R. 546 Item 4 The activity description does not provide an indication of the threshold for the road. The EAP is requested to indicate the width of the road and provide an indication of where in the report this was assessed.

GN R. 546 Item 13 The activity description in the application form and EIAr does not provide an indication of the total area to be cleared. The EAP is requested to indicate the size of the area to be cleared and provide an indication of where in the report this was assessed.

Please refer to Chapter 2.4.3 of the AMENDED EIAr as well as the GENERAL Impacts Table (Appendix C) Please refer to the AMENDED Application Form “The total amount of material required for the infilling of watercourses amounts to 1 000 m3 (20 watercrossings).” Please refer to Chapter 1.1 and Chapter 2.4.3 of the AMENDED EIAr as well as the GENERAL Impacts Table (Appendix C) Please refer to the AMENDED Application Form “67 km of internal roads, of which

60 km - existing farm roads to be widened (from 3.5 m wide to 12 m wide, to be rehabilitated to 5 m); and

7 km - new roads to be constructed (12 m wide to be rehabilitated to 5 m)”

Please refer to Chapter 1.1 of the AMENDED EIAr as well as the GENERAL Impacts Table and the SPECIALIST Impacts Table (Appendix C) Please refer to the Ecological Impact Assessment and the Agriculture & Soils Impact Assessment (Appendix B) Please refer to the AMENDED Application Form “The turbine footprints and associated facility infrastructure (internal access roads, substations, construction compound, batching plant and operations building) will potentially cover an area of approximately 96.82 ha during the construction phase. This footprint will be reduced through rehabilitation, resulting in a final operational footprint of 70.92 ha.”



GN R. 546 Item 14 The activity description in the application form and EIAr does not provide an indication of the total area to be cleared. The EAP is requested to indicate the size of the area to be cleared and provide an indication of where in the report this was assessed.

GN R. 546 Item 19 The EAP is requested to confirm the applicability of this activity and provide the relevant description as it related to the project. The relevant thresholds for the project must also be provided.

Please refer to Chapter 1.1 of the AMENDED EIAr as well as the GENERAL Impacts Table and the SPECIALIST Impacts Table (Appendix C) Please refer to the Ecological Impact Assessment and the Agriculture & Soils Impact Assessment (Appendix B) Please refer to the AMENDED Application Form “The turbine footprints and associated facility infrastructure (internal access roads, substations, construction compound, batching plant and operations building) will potentially cover an area of approximately 96.82 ha during the construction phase. This footprint will be reduced through rehabilitation, resulting in a final operational footprint of 70.92 ha.” Please refer to Chapter 1.1 and Chapter 2.4.3 of the AMENDED EIAr as well as the GENERAL Impacts Table (Appendix C) Please refer to the AMENDED Application Form “Existing access roads will need to be widened in order to accommodate the construction and transport vehicles during the construction phase of the WEF. The length of the roads which need to be widened (from 3.5 m to 12 m) is approximately 60 000 m (60 km). After construction the roads will be rehabilitated to 5m.”

d) Following a review of the EIAr and application form, the following information is required

- An amended application form with an indication of all of the 2010 listed activities that are still listed.

- An indication of all of the similarly listed 2014 activities

- An indication if there are any new 2014 activities that are listed

- An indication where in the report, all of the 2014 activities have been assessed and mitigated for

- A letter/affidavit from the EAP indicating that the above is true and correct

The amended application form has been prepared and meets the DEA requests in Section A of the DEA Letter of Rejection of EIAr. Table attached here as Appendix A. EAP Declaration signed and attached to the amended application.

e) The application form must be amended to remove all of the activities no longer triggered by the proposed development and to amend the activity description

The amended application form has been prepared and meets the DEA requests in Section A of the DEA Letter of Rejection of EIAr. Table attached here as Appendix A.



f) The amended EIAr must provide details of the proposed substations, including capacity and dimensions

Please refer to Chapter 2.4.1 of the AMENDED EIAr as well as the GENERAL Impacts Table (Appendix C) Please refer to the AMENDED Application Form “The 33kV internal reticulation network of cables from the turbines are collected at the 132/33kV WEF IPP transformer substation station (1.50 ha). From there it feeds into the new Eskom Main Transmission System (MTS) Substation 400/132kV (2.25 ha). The power is then transmitted via a double 400kV overhead line into the existing 400kV Eskom Hydra/Poseidon line which runs through the project site, using loop-in loop-out connection. The two substations will be (preliminary) situated adjacent to each other. The WEF IPP Substation will feed into the Eskom MTS Substation via the new 132 kV powerline (100m). The Eskom MTS Substation will feed into the existing Eskom Transmission line via the two new 400 kV powerline (100 m each). Table 2-2 and Table 2-3 indicate the dimensions of the powerlines and substations respectively.”

g) Please ensure that all mitigation measures proposed by the specialist reports are included in the EMPr to be submitted with the amended EIAr

Please refer to the AMENDED EMPr All mitigation measures have been included in the AMENDED EIAr

h) Coordinates for the proposed turbine positions, including proposed substations and powerlines must be included in the amended EIAr

Please refer to Chapter 2.1, Table 2-1 (Turbine Coordinates) of the AMENDED EIAr Please refer to Chapter 2.4.1, Table 2-2 (Powerline Coordinates) and Table 2-3 (Substation Coordinates) of the AMENDED EIAr

i) The Public Participation Process must be in accordance with Regulation 54 to 57 of the GN R543 of EIA Regulations, 2010

A 30 day comment period on the AMENDED EIAr will be undertaken (22nd August to 22nd September).

j) The EIAr must meet the requirements of this rejection letter and the requirements of Regulation 31 of the EIA Regulations, 2010

Please refer to the AMENDED EIAr and all associated Appendices (A-E) Please refer to the AMENDED Draft EMPr



Appendix A This table appears in the AMENDED EIAr (Chapter 1.2, Table 1-2), and in the AMENDED Application Form. Table 1-1: AMENDED Listed activities triggered by the proposed Umsobomvu Wind Energy Facility

DETAILED DESCRIPTION OF LISTED ACTIVITIES ASSOCIATED WITH THE PROJECT

Listed activity as described in GN R 544, 545 and 546.


Description of the listed activity. Where the 2014 listed activity been assessed in the EIR/Specialist studies.

2010 listed activities Similarly listed 2014 activities

e.g. GN R.983 Item XX(x): The development of bridge exceeding 100 square metres in size within a

watercourse

GN R. 544 Item 10 (i)

The construction of facilities or infrastructure for the transmission and distribution of electricity –

(i) Outside urban areas or industrial complexes with a capacity of more than 33 but less than 275 kilovolts.

GN R. 983 Item 11 (i)

The development of facilities or infrastructure for the transmission and distribution of electricity:

(i) Outside urban areas or industrial complexes with a capacity of more than 33 but less than 275 kilovolts.

33kV underground electrical cables will be laid to transmit electricity generated by the wind turbines to the onsite switching station. A 33 kV overhead powerline (1.5 km) will be constructed to connect the electricity generated by the WEF to the WEF IPP Substation. A 132 kV powerline (0.1 km) connect the WEF IPP Substation to the Eskom MTS Substation.

ENVIRONMENTAL IMPACT ASSESSMENT: GENERAL IMPACTS

ECOLOGICAL IMPACT ASSESSMENT

AVIFAUNAL IMPACT ASSESSMENT

GN R. 544 Item 11 (iii), (xi)

The construction of bridges and infrastructure or structures covering 50 square meters or more where such construction occurs

(xi) within a watercourse or within 32 meters of a watercourse.

GN R. 983 Item 12 (iii), (xii)

The development of bridges and infrastructure or structures with a physical footprint of 100 square metres or more, where such a development occurs

(a) within a watercourse

This relates specifically to low level crossings and bridges that may need to be constructed or upgraded, along with the associated road infrastructure that may fall within 32 m of a watercourse.





(c) within 32 metres of a water course, measured from the edge of a water course.

GN R. 544 Item 13

The construction of facilities or infrastructure for the storage, of the storage and handling, of dangerous good, where such storage occurs in containers with a capacity of 80 but not exceeding 500 cubic meters.

GN R. 983 14:

The development of facilities or infrastructure for the storage, or for the storage and handling, of a dangerous good, where such storage occurs in containers with a combined capacity of 80 but not exceeding 500 cubic meters.

This relates specifically to aspects such as storage of transformer oil at the switching station site and at the maintenance storage facility during operation. Also small volumes of other chemicals may be stored during construction (including diesel and petrol), which may trigger this activity.

The construction period is expected to last 24 months. The construction dangerous goods amount to 191.23 m3 while the operational dangerous good amount to 216.10 m3. This equates to a total of 407.33 m3 of dangerous goods for the lifespan of the project.


GN R. 544 Item 18 (i)

The infilling or depositing of any material of more than 5 cubic meters into, or the dredging, excavation, removal, or moving of soil, sand, shells, shell grit, pebbles or rock from

(i) a watercourse.

GN R. R983 Item 19 (i) The infilling or depositing of any material of more than 5 cubic metres into, or the dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock of more than 5 cubic metres from

(i) a watercourse.

This relates specifically to low level crossings and bridges that may need to be constructed or upgraded. The total amount of material required for the infilling of watercourses amounts to 1 000 m3 (20 watercrossings).


GN R. 545 Item 1

The construction of facilities or infrastructure for the generation of electricity where the electricity output is 20 megawatts or more.

GN R. 984 Item 1

The development of facilities or infrastructure for the generation of electricity from a renewable resource where the electricity output is 20 megawatts or more.

The EIA process is focussed on this activity, and thus most of the impacts identified can be related to the development of a facility for the generation of electricity. The Umsobomvu WEF will host 84 turbines with an output capacity of 277.2 MW

ALL IMPACTS



GN R. 545 Item 8

The construction of facilities or infrastructure for the transmission and distribution of electricity with a capacity of 275 kilovolts or more, outside an urban area or industrial complex.

Two 400 kV (0.1 km x 2 = 0.2 km) powerline will be constructed to connect the Eskom MTS Substation to the existing Eskom (Hydra/Poseidon) Transmission Powerline.



AVIFAUNAL IMPACT ASSESSMENT

GN R. 545 Item 15

Physical alteration of undeveloped, vacant or derelict land for residential, retail, commercial, recreational, industrial or institutional use where the total area to be transformed is 20 hectares or more.

GN R. 984 Item 15

The clearance of an area 20 hectares or more of indigenous vegetation.

Vegetation will need to be cleared for turbine footprints, access roads, electrical infrastructure, and general infrastructure associated with the WEF. The total WEF footprint is anticipated to be 96.82 ha during the construction phase. This footprint will be reduced through rehabilitation, resulting in a final footprint of 70.92 ha. This amounts to less than 1% of the total project area of 18 263 ha.


AGRICULTURE & SOILS IMPACT ASSESSMENT


GN R. 546 Item 4 (ii)(bb)

The construction of a road wider than 4 meters with a reserve less than 13.5 meters outside an urban area in National Protected Area Expansion Strategy Focus area.

GN R. 985 Item 4 (b) ii (bb):

The construction of a road wider than 4 meters with a reserve less than 13.5 meters outside an urban area in National Protected Area Expansion Strategy Focus area.

New access roads will need to be constructed to connect proposed turbine footprints and associated infrastructure. The length of the new roads is approximately 7 000 m (7 km).



GN R. 546 Item 13 (b) No equivalent in the 2014 Regulations.

Vegetation will need to be cleared for turbine footprints, access roads, electrical infrastructure, and general infrastructure associated with the WEF. The total WEF footprint is anticipated to be 96.82 ha during the construction phase. This footprint will be reduced through rehabilitation, resulting in a final footprint of 70.92 ha.





The clearance of an area of 5 hectares or more of vegetation where 75% or more of the vegetation cover constitutes indigenous vegetation in a National Protected Area Expansion Strategy Focus area.

GN R. 546 Item 14 (a) i.

The clearance of an area of 5 hectares or more of vegetation where 75% or more of the vegetation cover constitutes indigenous vegetation.

(a) In Eastern Cape and Northern Cape

provinces.

i. All areas outside urban areas

No equivalent in the 2014 Regulations.

Vegetation will need to be cleared for turbine footprints, access roads, electrical infrastructure, and general infrastructure associated with the WEF. The total WEF footprint is anticipated to be 96.82 ha during the construction phase. This footprint will be reduced through rehabilitation, resulting in a final footprint of 70.92 ha



GN R. 546 Item 16 (iv)(a)(ii)(bb)

(iv) Infrastructure covering 10 square metres or more where such construction occurs within a watercourse or within 32 metres of a watercourse, measured from the edge of a watercourse.

(a) In Eastern Cape and Northern Cape: (ii) Outside urban areas.

GN R. 985 Item 14 (xii)(a, ii, bb) (c, ii, bb) Infrastructure or structures with a physical footprint of 10 square metres or more in

(a & c) the Eastern Cape and Northern Cape;

(ii) Outside urban areas, in:

(bb) National Protected Area Expansion Strategy Focus area.

This relates specifically to low level crossings that may need to be constructed or upgraded during the construction and upgrading of the road network.

ALL IMPACTS




GN R. 546 Item 19 (ii)(bb)

The widening of a road by more than 4 meters, or the lengthening of a road by more than kilometre outside an urban area in a National Protected Area Expansion Strategy Focus area.

GN R. 985 Item 18 (a, ii, bb) (b, ii, bb:

The widening of a road by more than 4 meters or the lengthening of a road by more than 1 kilometre in

(a & b) the Eastern Cape and Northern Cape;

(ii) Outside urban areas, in:


Existing access roads will need to be widened in order to accommodate the construction and transport vehicles during the construction phase of the WEF. The length of the roads which need to be widened (from 3.5 m to 12 m) is approximately 60 000 m (60 km). After construction the roads will be rehabilitated to 5 m.




New 2014 Listed Activities. Description of the listed activity. Where the 2014 listed activity been assessed.

No equivalent in the 2010 Regulations.

GN R. 983 Item 28(ii):

Residential, mixed, retail, commercial, industrial or institutional developments where such land was used for agriculture or afforestation on or after 01 April 1998 and where such development will occur outside an urban area, where the total land to be developed is bigger than 1 hectare.

Agricultural land will be transformed. The operational footprint is calculated to be approximately 70.92 hectares.


AGRICULTURE & SOILS IMPACT ASSESSMENT


Documents

PROPOSED UMSOBOMVU WIND ENERGY FACILITY, NORTHERN … Wind Energy CE200215/EIAr... · PROPOSED UMSOBOMVU WIND ENERGY FACILITY, NORTHERN CAPE & EASTERN CAPE ... EIR documentation submitted