UPGRADING OF WATER AND SANITATION INFRASTRUCTURE AT … Cox Agricultural... · Upgrading of Water and Sanitation Infrastructure at Fort Cox Agriculture and Forestry Farming Institute,

UPGRADING OF WATER AND SANITATION INFRASTRUCTURE AT FORT COX AGRICULTURE AND FORESTRY FARMING INSTITUTE,

ALICE, EASTERN CAPE

AQUATIC ASSESSMENT

Prepared for:

LUKHOZI CONSULTING ENGINEERS (PTY) LTD

Kwa Lukhozi, Quartzite Drive, The Quarry Selborne, 5241 043 721 1321

On behalf of:

EASTERN CAPE DEPARTMENT OF RURAL DEVELOPMENT

AND AGRARIAN REFORM (DRDAR) Independence Avenue, Private Bag X0040,

Bhisho, 5605 040 602 5000

Prepared by:

EAST LONDON 25 Tecoma street

Berea, East London, 5201 043 726 7809

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

www.cesnet.co.za or www.eoh.co.za

April 2017

http://www.cesnet.co.za/

Aquatic Assessment

EOH Coastal & Environmental Services ii Fort Cox Agriculture and Forestry Farming Institute

This Report should be cited as follows: EOH Coastal & Environmental Services, April 2017: Upgrading of Water and Sanitation Infrastructure at Fort Cox Agriculture and Forestry Farming Institute, Alice, Eastern Cape: Aquatic Assessment, EOH CES, East London.

REVISIONS TRACKING TABLE

EOH Coastal & Environmental Services

Report Title: Upgrading of Water and Sanitation Infrastructure at Fort Cox Agriculture and

Forestry Farming Institute, Alice, Eastern Cape: Aquatic Assessment Report Version: Draft Project Number: 293

Name Responsibility Date

Kim Brent Lead Author April 2017

Caitlin Smith Report writing April 2017

Rosalie Evans GIS mapping April 2017

Dr Cherie-Lynn Mack Reviewer April 2017

Copyright This document contains intellectual property and propriety information that are protected by copyright in favour of EOH Coastal & Environmental Services (EOH CES) and the specialist

consultants. The document may therefore not be reproduced, used or distributed to any third party without the prior written consent of EOH CES. The document is prepared exclusively for

submission to Lukhozi Consulting Engineers, and is subject to all confidentiality, copyright and trade secrets, rules intellectual property law and practices of South Africa.

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EOH Coastal & Environmental Services 1 Fort Cox Agriculture and Forestry Farming Institute

INFORMATION REQUIRED BY THE COMPETENT AUTHORITY On 7 April 2017, the Environmental Impact Assessment Regulations promulgated in terms of the National Environmental Management Act (Act no. 107 of 1998 as amended; NEMA) dated 8 December 2014 were amended. In terms of Appendix 6 of the Amended EIA Regulations (2017), a Specialist Report must contain all the information necessary for a proper understanding of the nature of issues identified, and must include–

(1) A specialist report prepared in terms of the Amended NEMA EIA Regulations

(2017) must contain-

(a) Details of-

(i) The specialist who prepared the report;

and

(ii) The expertise of that specialist to compile

a specialist report including a curriculum

vitae;

(b) A declaration that the specialist is independent in a form as may be specified by the competent authority;

Please refer to Chapter 1

(c) An indication of the scope of, and the purpose for which, the report was prepared;


(cA) An indication of the quality and age of the base data used for the specialist report;


(cB) A description of the existing impacts on the site, cumulative impacts of the proposed development and levels of acceptable change;


(d) The duration, date and season of the site investigation and the relevance of the season to the outcome of the assessment;


(e) A description of the methodology adopted in preparing the report or carrying out the specialised process inclusive of equipment and modelling used;


(f) Details of an assessment of a specific identified sensitivity of the site related to the proposed activity or activities and its associated structures and infrastructure inclusive of a site plan identifying alternatives;

Please refer to Chapter 5 and 6

(g) An identification of any areas to be avoided, including buffers;


(h) A map superimposing the activity including the associated structures and infrastructure on the environmental sensitivities of the site including areas to be avoided, including buffers;


(i) A description of any assumptions made and any uncertainties or gaps in knowledge;


(j) A description of the findings and potential implications of such findings on the impact of the proposed activity or activities;


(k) Any mitigation measures for inclusion in the EMPr; Please refer to Chapter 7

(I) Any conditions for inclusion in the environmental authorisation;


(m) Any monitoring requirements for inclusion in the EMPr or environmental authorisation;


(n) A reasoned opinion- (i) whether the proposed activity, activities or portions thereof should be authorised; and (iA) regarding the acceptability of the proposed activity or


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activities, and (ii) If the opinion is that the proposed activity, activities or portions thereof should be authorised, any avoidance, management and mitigation measures that should be included in the EMPr, and where applicable, the closure plan;

(o) A description of any consultation process that was undertaken during the course of preparing the specialist report;


(p) A summary and copies of any comments received during any consultation process and where applicable all responses thereto; and


(q) Any other information requested by the competent authority.


(2) Where a government notice gazetted by the minister provides for any protocol or minimum information requirement to be applied to a specialist report, the requirements as indicated in such notice will apply.

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TABLE OF CONTENTS 1 THE PROJECT TEAM AND EXPERTISE ............................................................................... 1

1.1 Details of specialist .......................................................................................................... 1 1.2 Expertise ......................................................................................................................... 2 1.3 Declaration ...................................................................................................................... 2

2 INTRODUCTION ..................................................................................................................... 1 2.1 Project overview and location (Source: Preliminary Design report, Lukhozi Consulting Engineers, 2017) ......................................................................................................................... 1 2.2 Alternatives ...................................................................................................................... 2 2.3 Public Participation .......................................................................................................... 2 2.4 Objectives and Terms of Reference (ToR)....................................................................... 2 2.5 Approach ......................................................................................................................... 3 2.6 Assumptions and Limitations ........................................................................................... 5

3 RELEVANT LEGISLATION .................................................................................................... 6 4 ASSESSMENT METHODOLOGY ........................................................................................ 11

4.1 Aquatic Assessment approach ...................................................................................... 11 4.2 Wetland Assessment ..................................................................................................... 11 4.3 Tools available to define wetlands and watercourses .................................................... 12

4.3.1 National Freshwater Ecosystem Priority Areas (NFEPA) ........................................... 12 4.4 Tools available for wetland delineation .......................................................................... 14

4.4.1 DWAF (2005) wetland delineation ............................................................................. 14 4.5 Impact assessment ........................................................................................................ 16

4.5.1 Impact rating methodology ......................................................................................... 16 5 DESCRIPTION OF THE BIOPHYSICAL ENVIRONMENT.................................................... 19

5.1 Desktop Investigation .................................................................................................... 19 5.1.1 Climate (Source: World Weather Online and www.meteoblue.com, 2017) ................. 19 5.1.2 Topography ............................................................................................................... 19 5.1.3 Geology and Soils (Source: Groundwater Sensitivity Assessment, 2017) .................. 20 5.1.4 Hydrogeological ......................................................................................................... 21 5.1.5 Surface water features ............................................................................................... 21 5.1.5.3 Ecoregions ............................................................................................................. 25 5.1.5.4 Wetlands ................................................................................................................ 26

5.2 Site survey ..................................................................................................................... 30 6 SITE SENSITIVITY ............................................................................................................... 34 7 MANNER IN WHICH THE ENVIRONMENT MAY BE AFFECTED ....................................... 36 8 IMPACT STATEMENT, CONCLUSION & RECOMMENDATIONS ....................................... 46

8.1 Conclusions ................................................................................................................... 46 8.2 Water Use Authorisation ................................................................................................ 46 8.3 Recommendations for the proposed activity .................................................................. 47

8.3.1 Planning and Design .................................................................................................. 47 8.3.2 Construction .............................................................................................................. 47 8.3.3 Operation ................................................................................................................... 48

8.4 Environmental statement and Opinion of the Specialist ................................................. 48 9 REFERENCES...................................................................................................................... 49

LIST OF FIGURES Figure 2.1. Locality Map of the proposed activity. ............................................................................................. 2 Figure 5.1: Climate (temperature and rainfall) graphs of the Alice area (Meteoblue, 2017) ........................... 19 Figure 5.2: Geology of the study area. ............................................................................................................ 20 Figure 5.3: Quaternary catchment locality (study area indicated on inset map by a star). ............................. 22 Figure 5.4. Affected rivers in the study area. ................................................................................................... 23 Figure 5.5: Conservation status of the affected rivers in the study area (NSBA, 2004). ................................. 24 Figure 5.6. Freshwater Ecosystem Priority Area status of the rivers in the study area (NFEPA, 2011-2014). 25 Figure 5.7: Affected wetlands and rivers. ........................................................................................................ 27 Figure 5.8 Wetlands located within 500 m of the infrastructure upgrades ...................................................... 28 Figure 6.1 Sensitivity map of the study area. .................................................................................................. 35

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LIST OF TABLES Table 2.1: Base data used and quality thereof .................................................................................................. 3 Table 3.1: Environmental legislation considered in the preparation of the Aquatic Assessment. ..................... 6 Table 4.1. Significance Rating Table. .............................................................................................................. 17 Table 4.2 Impact Severity Rating. ................................................................................................................... 17 Table 4.3 Overall Significance Rating. ............................................................................................................ 18 Table 5.1. Main attributes of the South Eastern Uplands ................................................................................ 26 Table 5.2. Wetland classification for the wetlands within the study area (Nel et al., 2011). ........................... 28 Table 7.1 Potential risks identified that could result from the proposed activity. ............................................. 36 Table 7.2: Impacts and mitigation measures for the Planning and Design Phase. ......................................... 38 Table 7.3: Impacts and mitigation measures for the Construction Phase. ...................................................... 40 Table 7.4: Impacts and mitigation measures for the Operational Phase. ....................................................... 44 Table 8.1: Assessment of pre- and post-mitigation impact significance. ........................................................ 46

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1 THE PROJECT TEAM AND EXPERTISE In terms of Appendix 6 of the Amended NEMA EIA Regulations (2017) a specialist report must contain- (a) Details of-

(iii) The specialist who prepared the report; and (iv) The expertise of that specialist to compile a specialist report including a curriculum vitae;

(b) A declaration that the specialist is independent in a form as may be specified by the competent

authority;

1.1 Details of specialist Mrs Kim Brent Pr.Sci.Nat. (Lead Author and Ecologist) Kim is a senior consultant with over 6 years‟ experience. She holds a BSc degree with majors in Botany and Geography as well as a BSc (Hons) degree in Botany focussing on Environmental Management and GIS systems; both from NMMU. Her honours year focussed on Environmental Impact Assessments, Environmental Management and Geographic Information Systems. Kim‟s interests include Environmental Auditing, Scoping and Environmental Impact Assessments, Geographic Information Systems and Ecological Assessments. Kim has conducted a number of Prospecting Right Applications, Basic Assessments and EIAs in South Africa, and has been involved in a number of mining projects within South Africa. Internationally, Kim has assisted on various ESIAs and ESMPs such as the Syrah Resources ESHIA for a Graphite Mine in Mozambique, the Baobab Iron Ore Mining Project, Mozambique and the Enterprise Nickel Deposit ESHIA, in Zambia. Kim has also conducted a number of Ecological Impact Assessments. Kim is registered with the South African Council for Natural Scientific Professional (SACNASP). Ms Caitlin Smith Pr.Sci.Nat. (Report Writer and Aquatic Specialist) Senior Environmental Consultant. Caitlin holds a BSc degree with majors in Geology and Geography and a BSc Honours Degree (with distinction) in Geology both obtained from Nelson Mandela Metropolitan University. Caitlin is a qualified geologist and has managed and been involved in various Environmental Impact Assessments. Her interest lies in the water sector, specifically in wetland related studies. She has completed various Aquatic and Wetland assessments for road and infrastructure projects. She is currently studying her MSc degree in Hydrology at Rhodes University focusing on the groundwater and surface water interactions of the Kromme River wetlands. Wetland Training: Rhodes University, Tools for Wetland Assessment (certified competent). Ms Rosalie Evans (GIS Mapping) Rosalie is an Environmental Consultant in the Port Elizabeth branch. She holds a BA degree in Social Dynamics with majors in Geography and Psychology as well as a BA Honours degree in Geography and Environmental Studies, both from Stellenbosch University. Rosalie's honours dissertation analysed the role of small grains in soil carbon sequestration in the agricultural sector of the Western Cape. Rosalie completed the Introduction to Environmental Impact Assessment Procedure Short Course by EOH Coastal & Environmental Services and the Department of Environmental Science Rhodes University as well as the Estuary Management Short Course by Nelson Mandela Metropolitan University. Her main focuses include the general Environmental Impact Assessment (EIA) process, GIS Mapping, Agriculture and Soils Assessments, Visual Assessments and Tourism Assessments. Dr Cherie-Lynn Mack, Pr.Sci.Nat. (Reviewer) Cherie-Lynn holds a PhD and MSc (with distinction) degree in Environmental Biotechnology, with a BSc degree in Microbiology and Biochemistry. She has postgraduate research experience in industrial and domestic wastewater treatment technologies, with particular emphasis on the coal and platinum mining industries. Her interests lie in the water sector, with experience in ecological reserve determination and water quality monitoring and analysis. She has experience in water quality analysis and industrial wastewater treatment research.

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1.2 Expertise Projects Kim, Caitlin and Cherie have worked on include:

Name of project Description of responsibility Date completed

DAFF Qolora Aquaculture Development Zone

Wetland Study 2016

Buffalo City Metropolitan Municipality: Haven Hills Cemetery

Wetland Study 2016

SANRAL R56 Road Upgrade between Matatiele and the KZN Border

Aquatic and Wetland Study 2016

Element Molteno Sewerage Infrastructure

Aquatic Impact Assessment 2015

Lusikisiki Regional Water Supply Scheme

Aquatic Impact Assessment 2015

Element Kwatshatshu Pedestrian Bridge

Aquatic and Botanical Assessment 2016

Element Becclesfarm Bridge Aquatic and Wetland Study 2016

Senqu Pedestrian Bridge Aquatic Impact Assessment 2016

SMEC MBDA Telkom park Precinct Plan

Groundtruthing and Environmental status report

November 2015

Wicklow Trust Citrus Packaging Warehouse, Sundays River Municipality, Eastern Cape

Ecological Assessment and Alien Vegetation Management Plan

January 2016

The re-construction and upgrading of the Slang river low-level crossing near Oyster Bay, Kouga Local Municipality Eastern Cape

Ecological and Wetland Impact Assessment

January 2016

Walmer Link Private School, Walmer, Port Elizabeth

Groundtruthing and Opinion letter April 2016

PPC Grassridge Quarry, Port Elizabeth

Botanical Survey and Rehabilitation Plan

November 2016

NMMU Private Nature Reserve Management plan

Nature Reserve Management Plan February 2017

The Kap River Bridge, Ndlambe Municipality, Easter Cape

Ecological and Wetland Assessment March 2017

Please find attached in Appendix A comprehensive curriculum vitae of the project team.

1.3 Declaration

I, Kim Brent, declare that, in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998), as amended and the Amended Environmental Impact Assessment Regulations, 2017;

I act as the independent specialist in this application;

I will perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant;

I declare that there are no circumstances that may compromise my objectivity in performing such work;

I have expertise in conducting the specialist report relevant to this application, including knowledge of the Act, Regulations and any guidelines that have relevance to the proposed activity;

I will comply with the Act, Regulations and all other applicable legislation;

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I have no, and will not engage in, conflicting interests in the undertaking of the activity;

I undertake to disclose to the applicant and the competent authority all material information in my possession that reasonably has or may have the potential of influencing - any decision to be taken with respect to the application by the competent authority; and - the objectivity of any report, plan or document to be prepared by myself for submission to the competent authority;

All the particulars furnished by me in this report are true and correct; and

I realise that a false declaration is an offence in terms of regulation 48 and is punishable in terms of section 24F of the Act.

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2 INTRODUCTION In terms of Appendix 6 of the Amended EIA Regulations (2017) a specialist report must contain- (c) An indication of the scope of, and the purpose for which, the report was prepared; (cA) An indication of the quality and age of the base data used for the specialist report; (d) The duration, date and season of the site investigation and the relevance of the season to the outcome of the assessment; (i) A description of any assumptions made and any uncertainties or gaps in knowledge; (o) A description of any consultation process that was undertaken during the course of preparing the

specialist report; (p) A summary and copies of any comments received during any consultation process and where

applicable all responses thereto

2.1 Project overview and location (Source: Preliminary Design report, Lukhozi Consulting Engineers, 2017)

Lukhozi Consulting Engineers (LCE) have been appointed by the Fort Cox Agriculture and Forestry Farming Institute (Fort Cox) to undertake the design for the upgrading of water and wastewater infrastructure at Fort Cox near Alice in the Eastern Cape. The college is located approximately 45 km from King William‟s Town CBD. The site can be accessed from the R63, which is the main road between King William‟s Town and Alice. The study area straddles the boundary between two local Municipalities namely the Amahlathi and Nkonkobe Local Municipalities both seated within the Amathole District Municipality. The work will include the following: • Clearance of the site and disposal of debris. • Minor upgrading and maintenance of the existing water and sanitation infrastructure (pumps,

manholes). Sanitation: • The testing of the condition of the existing pipelines including cleaning of blocked manholes

and septic tanks. • Excavation of inspection holes to determine the position and sizes of the existing sewer pipe

network. • Construction of approximately 3 km long sewer pipeline ranging from 160 mm to 200 mm in

diameter. • Construction of sewage pump stations at the Fort Cox College Old campus and associated

rising mains (430 m) comprising of 110 mm diameter. • Minor upgrading and maintenance of the existing sanitation infrastructure (pumps, manholes

etc.) • Upgrading of existing oxidation ponds (concrete lined or similar approved, formalising

channel for effluent, installation of coarse screen). Ponds will be upgraded one at a time and sludge will not be removed from site, but rather moved to ponds that are not being upgraded.

• Upgrading of the existing chamber at base of the ponds to a treated effluent pump station. • Installation of 75 mm diameter rising main (1.2 km long) from the oxidation pond for irrigation

purposes. • Construction of a 6 m high elevated 45 kl tank for irrigation of the sports field. The Average Daily Flow Rate of sewage will be 1.3 l/s and Peak Flow Rate 3.5 l/s. Water: • Construction of 110 mm diameter interlinking pipelines (approximately 1 km) from the

existing water treatment package plant to the existing reservoir and pump station.

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Power supply • Each pump station will be supplied with overhead power lines.

Figure 2.1. Locality Map of the proposed activity.

2.2 Alternatives The activity being applied for entails the upgrading of infrastructure related to an existing facility situated at the Fort Cox College near Alice. As such no other site alternatives are deemed necessary and site alternatives were not assessed. All possible activity and technology alternatives, including pipe diameters, material types etc. will be considered in the Draft Basic Assessment report (BAR).

2.3 Public Participation The Public Participation Process (PPP) followed to date has been described in detail in the Draft Basic Assessment Report (DBAR). Once the draft report is available for public review, a formal 30 day commenting and review period will be scheduled. All proof and correspondence to date is available in the DBAR. Any comments received on this report will be included in the final report.

2.4 Objectives and Terms of Reference (ToR) The ToR of this assessment includes:

Provide a general description of the status of the surface water resources of the area according to published literature;

Review relevant legislation, policies, guidelines and standards;

Delineate identified wetland areas and include appropriate buffer zones;

Identify any rare or endangered species;

Oxidation ponds

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Assess the health and state of nearby watercourses;

Derive Present Ecological State (PES) and Ecological Importance and Sensitivity (EIS) of affected watercourses (using available desktop PES and EIS data);

Provide a sensitivity map and define and map no-go areas;

Provide an assessment of the potential direct and indirect impacts resulting from the proposed development both on the footprint and the immediate surrounding area during construction and operation; and

Provide a detailed description of appropriate mitigation measures that can be adopted to reduce negative impacts for each phase of the project, where required including appropriate recommendations.

2.5 Approach The proposed project area and surrounds were described using a two-phased approach. Firstly, a desktop assessment of the project area was conducted in terms of current surface water classifications and biodiversity programmes and plans. This included the consideration of the following base data:

Aquatic CBA classification according to the Eastern Cape Biodiversity Conservation plan (ECBCP, 2007)

Department of Water and Sanitation Desktop Present Ecological State (PES) and Ecological Importance and Sensitivity (EIS) Model (2014).

Department of Water Affairs and Forestry: Level 2 River Ecoregional Classification System for South Africa, Lesotho and Swaziland (2007).

The National Freshwater Ecosystem Priority Areas (NFEPA) project (2011 - 2014)

National Spatial Biodiversity Assessment (NSBA) – River Ecosystems (2004)

The National Wetland Classification System (NWCS) According to Buckley (1997), data quality can be defined as “the fitness for use for a specific data set”. Factors to be included when describing data quality include lineage of the data (source, compilation method etc.), accuracy, logical consistency, and completeness or gaps. As such the quality of the base data used for this specialist report has been described in Table 2.1 below. It should be noted that only datasets and base data relevant to the study area and affected environmental features have been discussed below. Table 2.1: Base data used and quality thereof

BASE DATASET DATA AGE

DATA QUALITY

Aquatic CBA classification according to the Eastern Cape Biodiversity Conservation plan (ECBCP).

2007 Aquatic CBAs were identified on the basis of sub-quaternary catchments, addressing the linkages between catchments, important rivers and sensitive estuaries. Priorities were identified through a systematic conservation planning analysis. The data was compiled by Derek Berliner & Philip Desmet for the Department of Water Affairs and Forestry Project No 2005-012. The data is outdated and currently all the ECBCP shapefiles and supporting documentation is under review and in the process of being updated.

Department of Water and Sanitation Desktop Present Ecological State (PES) and Ecological Importance and Sensitivity (EIS) Model.

2014 A combination of expert knowledge and available Information on SQR level were used to derive the Desktop Present Ecological State (PES). The Desktop Ecological Importance (EI) and Ecological Sensitivity (ES) was derived based on the Desktop PES. The PES was assessed according to 6 metrics that represents a very broad qualitative assessment of both the instream and riparian components of a river based on data

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The accuracy of this data can only be determined after the site visit and will be discussed in the conclusions chapter of this report.

put together by Kleynhans CJ, Louw MD, Graham M, 2008. The DWS model has been compiled by the RQIS-RDM a Planning and Information Branch of the Department of Water and Sanitation and is the most up to date data set available.

Department of Water Affairs and Forestry: Level 2 River Ecoregional Classification System for South Africa, Lesotho and Swaziland.

2007 The delineation of Ecoregions for SA has been derived from terrain and vegetation, with altitude, rainfall, runoff variability, air temperature, geology and soil. The data has been compiled by the RQIS a Planning and Information Branch of the Department of Water and Sanitation and according to the DWS website, DWS will not accept any responsibility for the accuracy of this data -- the outlines may change as the owner incorporates more data sets. Note that transition zones between regions are about 5km wide. The Ecoregions Level 2 document is still in draft form and not available at this stage.

The National Freshwater Ecosystem Priority Areas (NFEPA) project

2011-2014

NFEPA was originally completed in 2011 and has recently (2014) been updated. FEPAs were determined through a process of systematic biodiversity planning and involved collaboration of over 100 freshwater researchers and practitioners. FEPAs were identified based on a range of criteria dealing with the maintenance of key ecological processes and the conservation of ecosystem types and species associated with rivers, wetlands and estuaries, described in detail in the NFEPA Technical Report. The data was compiled by a large number of authors/specialists for the Water Research Commission of SA and the most recent data available.

National Spatial Biodiversity Assessment (NSBA) – River Ecosystems

2004 The River component of the NSBA was based on the work conducted by the DWAF, CSIR and WRC in the National Freshwater Biodiversity Initiative. The status of river ecosystems was assessed based on the river signatures and the integrity of main stream rivers. The NSBA was commissioned by the Department of Environmental Affairs and Tourism as part of the National Biodiversity Strategy and Action Plan. The NSBA was the first ever comprehensive spatial assessment of biodiversity throughout the country. This data is very old and should only be used as a baseline to show change in river conditions over time.

The National Wetland Classification System (NWCS)

2013 The NWCS uses hydrological and geomorphological traits to distinguish the direct factors that influence wetland function. This is presented as a 6 tiered structure with four spatially nested primary levels that are applied in a hierarchical manner between different wetland types on the basis of these direct factors. This Classification system has been commissioned by Freshwater Consulting Group (through SANBI). This data is the most recent data available.

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On completion of the desktop assessment a site visit was conducted on 14 September 2016 and 27 February 2017 date in order to determine the actual condition of the surface water features within the proposed study area. These site visits took place during the beginning of summer and towards the end of summer. The season will not have a large impact on the outcome of the assessment of the majority of affected watercourses are dams and drainage lines.

2.6 Assumptions and Limitations This report is based on currently available information and, as a result, the following limitations and assumptions are implicit:

The report is based on a project description taken from design specifications for the proposed activity provided to EOH CES by the engineers, which is likely to undergo a number of iterations and refinements before it can be regarded as final;

Descriptions of the natural environments are based on limited fieldwork and available literature;

It should be emphasised that information, as presented in this document, only has reference to the study area as indicated on the accompanying maps. Therefore, this information cannot be applied to any other area without a detailed investigation being undertaken.

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3 RELEVANT LEGISLATION In terms of Appendix 6 of the Amended EIA Regulations (2017) a specialist report does not legally have to cover a review of the applicable legislation however this has been included to provide the reader with an overview of the legal requirements related to the Aquatic environment.

Environmental legislation relevant to the proposed activity is summarised in Table 3.1 below. Biodiversity Plans and Programmes are discussed in Chapter 4 and 5, where they are used to describe the desktop ecological conditions of the study area. Table 3.1: Environmental legislation considered in the preparation of the Aquatic Assessment.

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LEGISLATION/POLICY DESCRIPTION IMPLICATIONS FOR THE PROPOSED ACTIVITY

The Constitution (Act 108 of 1996)

The Constitution of the Republic of South Africa is the supreme law of the land. As a result, all laws, including those pertaining to this Management Plan, must conform to the Constitution. The Bill of Rights - Chapter 2 of the Constitution, includes an environmental right (Section 24) according to which, everyone has the right: a) To an environment that is not harmful to their health or well-being; and b) To have the environment protected for the benefit of present and future

generations, through reasonable legislative and other measures that: i. Prevent pollution and ecological degradation; ii. Promote conservation; and

iii. Secure ecologically sustainable development and use of natural resources while promoting justifiable economic and social development.

Obligation to ensure that the proposed activity will not result in pollution and ecological degradation; and

Obligation to ensure that the proposed development is ecologically sustainable, while demonstrating economic and social development.

National Environmental Management Act (NEMA) (Act 108 of 1998), and its subsequent amendments. Amended NEMA EIA Regulations (GNR. 326) (2017)

Relevant Sections of the Act: Section 2, 23, 24, 24-1, 28-33

Application of the NEMA principles (e.g. need to avoid or minimise impacts, use of the precautionary principle, polluter pays principle, etc.)

Application of fair decision-making and conflict management procedures are provided for in NEMA.

Application of the principles of Integrated Environmental Management and the consideration, investigation and assessment of the potential impact of existing and planned activities on the environment; socio-economic conditions; and the cultural heritage.

NEMA introduces the duty of care concept, which is based on the policy of strict liability. This duty of care extends to the prevention, control and rehabilitation of significant pollution and environmental degradation. It also dictates a duty of care to address emergency incidents of pollution. A failure to perform this duty of care may lead to criminal prosecution, and may lead to the prosecution of managers or directors of companies for the conduct of the legal persons. In addition NEMA introduced a new framework for environmental impact assessments, the EIA Regulations (2014) which has recently been amended. The Amended EIA Regulations (2017) aim to avoid detrimental environmental impacts through the regulation of specific activities that cannot commence without prior environmental authorisation. Authorisation either requires a Basic Assessment or a Full Scoping and Environmental Impact Assessment, depending on the type of activity. These assessments specify mitigation and management guidelines to minimise negative environmental impacts and

An application for Environmental Authorisation (as triggered by the Amended EIA Regulations) has been submitted to the Competent Authority (i.e. DEDEAT).

In terms of Section 28, every person who causes; has caused, or may cause significant pollution or degradation of the environment must take reasonable measures to prevent pollution or rectify the damage caused – The undertaking of a specialist study, in this case an Aquatic study in order to identify potential impacts on the aquatic environment and to recommend mitigation measures to minimise these impacts, complies with Section 28 of NEMA.

This report complies with Appendix 6 of the Amended Environmental Impact Assessment Regulations (GNR. 326 of 2017) as regulated by the National Environmental Management Act (Act 107 of 1998 and amended in 2014; NEMA), which cover the requirements of the content of a Specialist Report.

The developer must apply the NEMA principles, the fair decision-making and conflict management procedures that are provided for in NEMA.

The developer must apply the principles of Integrated Environmental Management and consider, investigate and assess the potential impact of existing and planned activities on the environment, socio-economic conditions and the cultural heritage.

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optimise positive impacts. National Environmental Management: Biodiversity Act (Act 10 of 2004), and its subsequent amendments. Alien Invasive Species Regulations, 2014.

The National Environmental Management: Biodiversity Act (NEMBA), No. 10 of 2004, aims to assist with the management and conservation of South Africa‟s biological diversity through the use of legislated planning tools. These planning tools include the declaration of bioregions and the associated bioregional plans as well as other mechanisms for managing and conserving biodiversity. The objectives of the Act include inter alia: To provide for:

The management and conservation of biological diversity within the Republic and of the components of such biological diversity;

The use of indigenous biological resources in a suitable manner;

The fair and equitable sharing of benefits arising from bio-prospecting of genetic material derived from indigenous biological resources; and

To give effect to ratified international agreements relating to biodiversity which are binding on the Republic.

To provide for co-operative governance in biodiversity management and conservation; and

To provide for a South African National Biodiversity Institute to assist in achieving the objectives of the Act.

In addition to this, Sections 50-62 of the Act provide details relating to the protection of threatened or protected ecosystems and species, while Sections 63-77 of the Act provide details relating to alien and invasive species with the purpose of preventing their introduction and spread, managing, controlling and eradicating of alien and invasive species. The NEMBA Alien and Invasive Species List (Government Notice 599 of 2014) lists Alien and Invasive species that are regulated by the NEMBA Alien and Invasive Species Regulations (Government Notice 98 of 2014).

An invasive species management, control and eradication plan for land/activities under their control should be developed, as part of their environmental plans in accordance with section 11 of NEMA.

Activities may not be carried out in threatened or protected ecosystems without first gaining authorisation for such activities. It should however be noted that no threatened or protected ecosystems as listed in NEMBA has been identified within the project area and thus this is not considered to be relevant to this project.

No protected species may be removed or damaged without a permit;

National Water Act (Act 36 of 1998) and it subsequent amendments.

The purpose of this Act (Section 2) is to ensure that the Nation‟s water resources are protected, used, developed, conserved and controlled in ways that take into account, including:

(a) Promoting sustainable use of water (b) Protection of aquatic and associated ecosystems and their biological

diversity (c) Reducing and preventing pollution and degradation of water resources

Protection of Water Resources (Sections 12-20) Provides details of measures intended to ensure the comprehensive protection of all water resources, including the water reserve and water quality.

Appropriate measures must be taken to prevent the pollution of water courses and other water resources.

Riparian zones must be protected.

Construction within a River, within the Regulated area of a watercourse and within a wetland or within the 500 m buffer of a wetland will require a GA/WUA under section 21 (c) & (i) issued by the Department of Water and Sanitation.

Aquatic Assessment


With respect to the establishment of water quality objectives, objectives may relate to (Section 13):

the presence and concentration of particular substances in the water

the characteristics and quality of the water resource and the in-stream and riparian habitat

the characteristics and distribution of aquatic biota

the regulation and prohibition of in-stream and land-based activities which may affect the quantity and quality of the water resources

Section 19 deals with Pollution Prevention (Part 4) The person (including a municipality) who owns, controls occupies or uses the land in question, is responsible for taking reasonable measures to prevent pollution of water resources. If such measures are not taken, the catchment management agency concerned, may itself do whatever is necessary to prevent the pollution or remedy its effects and recover all reasonable costs from the persons responsible for the pollution. The „reasonable measures‟ which have to be taken may include measures to:

Cease, modify or control any act or process causing the pollution;

Comply with any prescribed waste standard or management practice;

Contain or prevent the movement of pollutants;

Eliminate any source of the pollution;

Remedy the effects of the pollution; and

Remedy the effect of any disturbance to the bed and banks of a watercourse.

With respect to pollution of rivers, the following definition is relevant when considering the potential impacts of development on water resources. Pollution may be deemed to occur when the following are affected:

the quality, pattern, timing, water level and assurance of instream flow;

the water quality, including the physical, chemical and biological characteristics of the water;

the character and condition of the in-stream and riparian habitat;

the characteristics, condition and distribution of the aquatic biota. The Act defines „instream habitat‟ as including the physical structure of a watercourse and the associated vegetation in relation to the bed of the watercourse. Riparian Ecosystems

Aquatic Assessment


„Riparian habitat‟ includes the physical structure and associated vegetation of the areas associated with a watercourse which are commonly characterised by alluvial soils, and which are inundated or flooded to an extent and with a frequency sufficient to support vegetation of species and physical structure distinct from those of adjacent land areas. Section 21 deals with the Use of Water Section 21 (a-k) describes activities defined as a water use under the Act. These activities may only be undertaken subject to the application for, and issue of, a water use licence.

Aquatic Assessment


4 ASSESSMENT METHODOLOGY In terms of Appendix 6 of the Amended EIA Regulations (2017) a specialist report must contain- (e) A description of the methodology adopted in preparing the report or carrying out the specialised process

inclusive of equipment and modelling used;

4.1 Aquatic Assessment approach The aim of this assessment is to identify the aquatic importance of the rivers and wetlands affected by the project and to evaluate the sensitivity of these features. The proposed project area and surrounds were described using a two-phased approach. Firstly, a desktop assessment of the project area was conducted in terms of current surface water classifications and biodiversity programmes and plans. This included the consideration of:

Aquatic CBA classification according to the Eastern Cape Biodiversity Conservation plan (ECBCP, 2007)

Department of Water and Sanitation Desktop Present Ecological State (PES) and Ecological Importance and Sensitivity (EIS) Model (2014).

Department of Water Affairs and Forestry: Level 2 River Ecoregional Classification System for South Africa, Lesotho and Swaziland (2005).

The National Freshwater Ecosystem Priority Areas (NFEPA) project (2011 - 2014)

National Spatial Biodiversity Assessment (NSBA) – River Ecosystems (2004)

The National Wetland Classification System (NWCS, 2013) Thereafter a site visit was conducted on 14 September 2016 and 27 February 2017 in order to determine the actual condition of the surface water features within the proposed study area. Photographs were taken using a Nikon Coolpix AW100 camera. GIS maps were drawn using Quantum GIS (version 2.14.9 (essen)).

4.2 Wetland Assessment

“Wetland” is a name given to a variety of ecosystems ranging from rivers, springs, seeps and mires in upper catchments, to midland marshes, pans and floodplains, coastal lakes, mangrove swamps and estuaries at the bottom of a catchment. These ecosystems all share the common primary driver of water and its prolonged presence is a fundamental determinant of soil characteristics, vegetation and animal life (DWAF, 2005). The National Water Act (Act No. 36, 1998 as amended in 2013) defines wetlands as: “Land which is transitional between terrestrial and aquatic systems where the water table is usually at or near the surface, or the land is periodically covered with shallow water, and which land in normal circumstances supports or would support vegetation typically adapted to life in saturated soil.” Thus wetlands must have one or more of the following characteristics:

Hydromorphic soils: characteristic soils of prolonged saturation;

Hydrophytes, at least occasionally: highly saturated plants; and

High water table: a high water table that results in saturation at or near the surface, leading to anaerobic conditions developing in the top 50 cm of the soil.

Wetlands are formed from a combination of geology, hydrology and topography. These landforms form in parts of a catchment where the movement of water is slowed down or obstructed, causing soil to become temporarily, seasonally or permanently waterlogged.

Aquatic Assessment


Wetland Importance South Africa is a Contracting Party to the Ramsar Convention on Wetlands and has thus committed itself to the intergovernmental treaty, which provides the framework for the national protection of wetlands and the resources they could provide. The Ramsar Convention is the only global environmental treaty that deals with a particular ecosystem. The treaty was adopted in the Iranian city of Ramsar in 1971 and the Convention's member countries cover all geographic regions of the planet. Wetland conservation in South Africa is now driven by SANBI under the requirements of the National Environmental Management: Biodiversity Act (NEMBA, 10, 2004). In natural capital terms, wetlands may be seen as a significant economic investment. This monetary value is rooted to the fact that the primary tasks of a wetland are to process water and regulate runoff. This is important as the South African economy is heavily dependent on water and yet the climatic variability of the country has meant that for the most part rainfall occurs as intermittent, high intensity storms. The inherent value of wetlands is that they protect and regulate this water source by acting like sponges, soaking up water during flood events and releasing it during dry periods (DWAF, 2005). By regulating water flows during floods, wetlands may reduce flood damage and help prevent soil erosion. As natural filters wetlands help to purify water by trapping pollutants such as heavy metals and disease causing organisms. The most common ecosystem services provided by wetlands (in general) are:

Improved water quality

Flood attenuation

Sediment trapping

Reduce number of water borne diseases

Herbal medicine

Water storage These ecosystem services are provided at very little cost but with significant payback for the South African economy. Despite being classified as the third most significant life support system on earth (IUCN, 1980), wetlands are some of the most threatened habitats in the world today. Breen & Begg (1989) reported that more than 50% of the wetland inventory in South Africa had disappeared. The main issues have been draining wetlands for crops and pastures, poorly managed burning and grazing resulting in headcut and donga erosion, planting alien invasive vegetation, mining, pollution and urban development. These have been significant as they alter the natural flow of water in wetlands and as water is the driver of wetland formation it follows that any changes would be damaging. A buffer around a wetland is usually recommended in order to protect the wetland from development in close proximity to it. Aside from the negative impacts of construction in the vicinity of a watercourse or wetland, a major impact that needs to be considered should be the geotechnical competence of soil which is often waterlogged and prone to flooding. Wetland soils are usually high in clay and prone to wet and dry periods, allowing for expansion and contraction of soils. The wetland and watercourse buffers are therefore also important with regards to the demarcation of areas that are not suitable for construction due to the high soil moisture content and unstable soils. Developing solutions to these problems would be expensive and may not be sustainable in the long term.

4.3 Tools available to define wetlands and watercourses 4.3.1 National Freshwater Ecosystem Priority Areas (NFEPA)

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The NFEPA programme provides strategic spatial priorities for conserving South Africa‟s freshwater ecosystems and supports sustainable use of water resources. These priority areas are called Freshwater Ecosystem Priority Areas, or FEPAs. The system comprises a hierarchical classification process of defining a wetland based on the principles of the hydro-geomorphic (HGM) approach at higher levels, with structural features being included at the finer levels (SANBI, 2009). Wetland ecosystem types were used by NFEPA for representing natural examples of the diversity of wetland ecosystem types across South Africa. Wetlands of the same ecosystem type are expected to share similar functionality and ecological characteristics. The biodiversity target for freshwater ecosystems in South Africa is 20%, which means that we should keep at least 20% of each wetland ecosystem type in a natural or near-natural condition. This serves to conserve many common species and communities, and the habitats in which they evolve. Information used to classify wetlands as FEPAs included:

Ramsar status;

Known threatened frog and waterbird occurrences; and

Expert knowledge on biodiversity importance. For the purposes of this study Version 4 of the National Wetland Classification System (NWCS) was used as baseline information, as per SANBI‟s BGIS interactive tool. The NWCS uses hydrological and geomorphological traits to distinguish the direct factors that influence wetland function. This is presented as a 6 tiered structure with four spatially nested primary levels that are applied in a hierarchical manner between different wetland types on the basis of these direct factors (SANBI, 2009).

Level 1: Distinguishes between marine, estuarine and inland ecosystems based on the degree of connectivity the systems have with the ocean.

Level 2: Categorises the regional wetland setting using a combination of biophysical attributes at the landscape level.

Level 3: Assesses the topographical position of inland wetlands.

Level 4: Concerns the hydrogeomorphic (HGM) units as defined as follows:

Landform - considering the shape and localised setting of the wetland;

Hydrological characteristics - nature of water movement into, through and out of the wetland; and

Hydrodynamics - the direction and strength of flow through the wetland. The HGM unit is considered the focal point for NWCS as the upper levels mean to classify the broad bio-geographical context for grouping functional wetland units at the HGM level, whilst the lower levels provide more descriptive detail. Wetland FEPAs were chosen based on significant specialist input that relates to information as diverse as crane breeding areas and protected frog habitats. As wetlands are formed under the influence of geology, hydrology and topography it is necessary to note these features when delineating a wetland.

Geology: Geology influences the formation of a wetland by geological obstructions such as erosion resistant rock or impervious material close to the surface forcing groundwater to move close to or onto the soil surface.

Hydrology: The water transfer mechanisms such as source, movement and exit are important features of a wetland.

Topography: The topography of the landscape influences the likelihood of whether a wetland will form. For instance, under the right conditions wetlands may form in floodplains, valley bottoms, hillslopes, depressions and coastal flats.

Aquatic Assessment


A range of „hydro-geomorphic‟ types can be defined by considering the above features. Six HGM units are defined for South African inland wetlands (SANBI, 2009):

Figure 4.1: The HGM types for South African Inland wetlands (SANBI, 2009). Important rivers are also classified according to the NFEPA rivers maps. These rivers are considered Freshwater Ecosystem Priority Areas (FEPAs). FEPAs are strategic spatial priorities for conserving freshwater ecosystems and supporting sustainable use of water resources. FEPAs are an essential part of an equitable and sustainable water resource strategy meaning that they need to stay in a good condition to manage and conserve freshwater ecosystems, and to protect water resources for human use. This means that the areas should be supported by good planning, decision-making and management to ensure that human use does not impact on the aquatic ecosystem.

4.4 Tools available for wetland delineation

4.4.1 DWAF (2005) wetland delineation

The DWAF (2005) guidelines for “a practical field procedure for delineation of wetlands and riparian areas” are recommended in Gazette No. 19182, Notice No. 1091 of the National Water Act, 1998. This guideline explains the field indicators and methods for determining whether an area is a wetland or a riparian area, and how to find its boundaries. Although the primary driver of a wetland is water, due to its dynamic nature water is not a very useful parameter for identifying the outer boundary of a wetland. What is needed is a method of identifying the indirect indicators of prolonged saturation by water. This includes wetland plants (hydrophytes) and wetland (hydromorphic) soils. Their presence or absence implies the frequency and duration of saturation and is a satisfactory indicator to classify the area as a wetland (DWAF, 2005). In wetland delineation there are three zones which are distinguished according to a changing frequency of saturation. These are the permanent, seasonal and temporary zone. The primary objective of wetland delineation is usually to define the outer edge of the temporary zone as it marks the boundary between the wetland and the adjacent terrestrial zone. There are four important indicators that are used to define the boundaries of a wetland. The most important one is the soil wetness indicator with terrain unit, soil form and vegetation acting as confirmation. The point where wetland indicators are not present is regarded as the edge of the wetland. The permanently wet zone is characterised by dark grey, clay soil, caused by a lack of oxygen required for the oxidation of minerals such as iron in the soil. The seasonally wet zone is characterised by grey soils with lots of orange and black mottles. It is generally recommended that there should be a 100m buffer zone between the edge of the delineated temporary zone and any development. Important indicators of each zone are as follows:

Aquatic Assessment


Wetland vegetation In order to tolerate the anaerobic conditions of seasonal or permanent flooding, hydrophytes (water loving plants) have evolved a number of adaptations. Their presence can therefore indicate a moist soil habitat and thus provide a potential boundary of a wetland‟s seasonally flooded or permanent flooded zones (Macfarlane et al., 2007).

o The temporary zone of a wetland will show mainly grasses, some woody species and

some sedges. o The seasonal zone will begin to show more hydrophytic (or water loving) sedges with

tall grasses (over 1m). o The permanent zone will be noticeable by emergent reeds and sedges, bulrushes or

floating and submerged plants. Woody species will have adaptations for permanent wetness such as prop roots (Mangroves).

Wetland soils Low oxygen levels result in a reduced rate of organic matter decomposition within the soil, where sulphur tends to exist in its reduced form, hydrogen sulphide (H2S), noticeable by its tell-tale rotten-egg smell. These conditions also serve as a catalyst for the metals in the soil to become soluble and begin leaching (DWAF, 2005). The metals produce rich colours of yellow, orange and reds.

o The temporary or seasonal zone of a wetland, where there is more seasonal flooding,

produces mottling of colours, as the metals are still in the process of precipitating. These mottles occur within a grey matrix where the metals have already leached.

o The permanent zone of a wetland, where there is more permanent flooding of the soil, produces leaching of metals, with soils remaining a grey (“gleyed”) colour.

o It is recommended by DWAF (2005) that soils be sampled on the surface (0-10cm) and between 40 and 50cm.

Figure 4.3: A cross-section through a wetland, indicating how the soil wetness and vegetation indicators change as one moves along a gradient of decreasing wetness, from the middle to the edge of the wetland (DWAF, 2005).

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4.5 Impact assessment 4.5.1 Impact rating methodology To ensure a direct comparison between various specialist studies, a standard rating scale has been defined and will be used to assess and quantify the identified impacts. This is necessary since impacts have a number of parameters that need to be assessed. Five factors need to be considered when assessing the significance of impacts, namely:

Relationship of the impact to temporal scales - the temporal scale defines the significance of the impact at various time scales, as an indication of the duration of the impact.

Relationship of the impact to spatial scales - the spatial scale defines the physical extent of the impact.

The severity of the impact - the severity/beneficial scale is used in order to scientifically evaluate how severe negative impacts would be, or how beneficial positive impacts would be on a particular affected system (for ecological impacts) or a particular affected party. The severity of impacts can be evaluated with and without mitigation in order to demonstrate how serious the impact is when nothing is done about it. The word „mitigation‟ means not just „compensation‟, but also the ideas of containment and remedy. For beneficial impacts, optimization means anything that can enhance the benefits. However, mitigation or optimization must be practical, technically feasible and economically viable.

The likelihood of the impact occurring - the likelihood of impacts taking place as a result of project actions differs between potential impacts. There is no doubt that some impacts would occur (e.g. loss of vegetation), but other impacts are not as likely to occur (e.g. vehicle accident), and may or may not result from the proposed development. Although some impacts may have a severe effect, the likelihood of them occurring may affect their overall significance.

Each criterion is ranked with scores assigned as presented in the tables below to determine the overall significance of an activity. The criterion is then considered in two categories, viz. effect of the activity and the likelihood of the impact. The total scores recorded for the effect and likelihood are then read off the matrix presented in the tables below, to determine the overall significance of the impact. The overall significance is either negative or positive.

The significance scale is an attempt to evaluate the importance of a particular impact. This evaluation needs to be undertaken in the relevant context, as an impact can either be ecological or social, or both. The evaluation of the significance of an impact relies heavily on the values of the person making the judgment. For this reason, impacts of a social nature need to reflect the values of the affected society.

Cumulative Impacts Cumulative impacts affect the significance ranking of an impact because the impact is taken in consideration of both onsite and offsite sources. For example, pollution making its way into a river from a development may be within acceptable national standards. Activities in the surrounding area may also create pollution which does not exceed these standards. However, if both onsite and offsite activities take place simultaneously, the total pollution level may exceed the standards. For this reason it is important to consider impacts in terms of their cumulative nature. Seasonality Although seasonality is not considered in the ranking of the significance, if may influence the evaluation during various times of year. As seasonality will only influence certain impacts, it will only be considered for these, with management measures being imposed accordingly (i.e. dust suppression measures being implemented during the dry season).

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Table 4.1. Significance Rating Table. Temporal Scale (The duration of the impact)

Short term Less than 5 years (many construction phase impacts are of a short duration).

Medium term Between 5 and 20 years.

Long term Between 20 and 40 years (from a human perspective almost permanent).

Permanent Over 40 years or resulting in a permanent and lasting change that will always be there.

Spatial Scale (The area in which any impact will have an affect)

Individual Impacts affect an individual.

Localised Impacts affect a small area of a few hectares in extent. Often only a portion of the project area.

Project Level Impacts affect the entire project area.

Surrounding Areas Impacts that affect the area surrounding the development

Municipal Impacts affect either the Local Municipality, or any towns within them.

Regional Impacts affect the wider District Municipality or the province as a whole.

National Impacts affect the entire country.

International/Global Impacts affect other countries or have a global influence.

Degree of Confidence or Certainty (The confidence with which one has predicted the significance of an impact)

Definite More than 90% sure of a particular fact. Should have substantial supportive data.

Probable Over 70% sure of a particular fact, or of the likelihood of that impact occurring.

Possible Only over 40% sure of a particular fact, or of the likelihood of an impact occurring.

Unsure Less than 40% sure of a particular fact, or of the likelihood of an impact occurring.

Table 4.2 Impact Severity Rating. Impact severity (The severity of negative impacts or how beneficial positive impacts would be on a particular affected system or affected party)

Very severe Very beneficial

An irreversible and permanent change to the affected system(s) or party(ies) which cannot be mitigated. For example the permanent loss of land.

A permanent and very substantial benefit to the affected system(s) or party(ies), with no real alternative to achieving this benefit. For example the vast improvement of sewage effluent quality.

Severe Beneficial

Long term impacts on the affected system(s) or party(ies) that could be mitigated. However, this mitigation would be difficult, expensive or time consuming, or some combination of these. For example, the clearing of forest vegetation.

A long term impact and substantial benefit to the affected system(s) or party(ies). Alternative ways of achieving this benefit would be difficult, expensive or time consuming, or some combination of these. For example an increase in the local economy.

Moderately severe Moderately beneficial

Medium to long term impacts on the affected system(s) or party(ies), which could be mitigated. For example constructing the sewage treatment facility where there was vegetation with a low conservation value.

A medium to long term impact of real benefit to the affected system(s) or party(ies). Other ways of optimising the beneficial effects are equally difficult, expensive and time consuming (or some combination of these), as achieving them in this way. For example a „slight‟ improvement in sewage effluent quality.

Slight Slightly beneficial

Medium or short term impacts on the affected system(s) or party(ies). Mitigation is very easy, cheap, less time consuming or not necessary. For example a

A short to medium term impact and negligible benefit to the affected system(s) or party(ies). Other ways of optimising the beneficial effects are

Aquatic Assessment


temporary fluctuation in the water table due to water abstraction.

easier, cheaper and quicker, or some combination of these.

No effect Don‟t know/Can‟t know

The system(s) or party(ies) is not affected by the proposed development.

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

Table 4.3 Overall Significance Rating. Overall Significance (The combination of all the above criteria as an overall significance)

VERY HIGH NEGATIVE VERY BENEFICIAL

These impacts would be considered by society as constituting a major and usually permanent change to the (natural and/or social) environment, and usually result in severe or very severe effects, or beneficial or very beneficial effects. Example: The loss of a species would be viewed by informed society as being of VERY HIGH significance. Example: The establishment of a large amount of infrastructure in a rural area, which previously had very few services,

would be regarded by the affected parties as resulting in benefits with VERY HIGH significance.

HIGH NEGATIVE BENEFICIAL

These impacts will usually result in long term effects on the social and/or natural environment. Impacts rated as HIGH will need to be considered by society as constituting an important and usually long term change to the (natural and/or social) environment. Society would probably view these impacts in a serious light. Example: The loss of a diverse vegetation type, which is fairly common elsewhere, would have a significance rating of

HIGH over the long term, as the area could be rehabilitated. Example: The change to soil conditions will impact the natural system, and the impact on affected parties (such as

people growing crops in the soil) would be HIGH.

MODERATE NEGATIVE SOME BENEFITS

These impacts will usually result in medium to long term effects on the social and/or natural environment. Impacts rated as MODERATE will need to be considered by society as constituting a fairly important and usually medium term change to the (natural and/or social) environment. These impacts are real but not substantial. Example: The loss of a sparse, open vegetation type of low diversity may be regarded as MODERATELY significant.

LOW NEGATIVE FEW BENEFITS

These impacts will usually result in medium to short term effects on the social and/or natural environment. Impacts rated as LOW will need to be considered by the public and/or the specialist as constituting a fairly unimportant and usually short term change to the (natural and/or social) environment. These impacts are not substantial and are likely to have little real effect. Example: The temporary changes in the water table of a wetland habitat, as these systems are adapted to fluctuating

water levels. Example: The increased earning potential of people employed as a result of a development would only result in benefits

of LOW significance to people who live some distance away.

NO SIGNIFICANCE

There are no primary or secondary effects at all that are important to scientists or the public. Example: A change to the geology of a particular formation may be regarded as severe from a geological perspective,

but is of NO significance in the overall context.

DON‟T KNOW

In certain cases it may not be possible to determine the significance of an impact. For example, the primary or secondary impacts on the social or natural environment given the available information. Example: The effect of a particular development on people‟s psychological perspective of the environment.

Aquatic Assessment


5 DESCRIPTION OF THE BIOPHYSICAL ENVIRONMENT In terms of Appendix 6 of the Amended EIA Regulations (2017) a specialist report must contain- (f) Details of an assessment of a specific identified sensitivity of the site related to the proposed activity or

activities and its associated structures and infrastructure inclusive of a site plan identifying alternatives; (g) An identification of any areas to be avoided, including buffers; (h) A map superimposing the activity including the associated structures and infrastructure on the

environmental sensitivities of the site including areas to be avoided, including buffers;

5.1 Desktop Investigation 5.1.1 Climate (Source: World Weather Online and www.meteoblue.com, 2017) The Eastern Cape has a complex climate. There are wide variations in temperature, rainfall and wind patterns, mainly as a result of movements of air masses, altitude, mountain orientation and the proximity of the Indian Ocean. The area is subject to strong winds from the west and west-south-west (41% combined frequency) all year round, and east (15%) from October through to March. These winds occur mainly throughout the day and may generate a significant amount of fugitive dust. Diurnal variations in the wind regime occur which are due to the influence of land-sea breeze circulation on the airflow of the region. The closest town to the study area with available weather data is the small town of Alice, situated approximately 17km west of the study area. The climate in Alice is mild, and generally warm and temperate The Köppen-Geiger climate classification is Cfa (Humid subtropical climates). The average annual temperature is approximately 20.0 °C. Summers are warm (highest maximum temperature of 30°C) and winters cool (lowest minimum temperature of 5°C). Rainfall is abundant throughout the year (approximately 574 mm annually). On average, June receives the lowest amount of rainfall estimates at 21 mm while March is the wettest month reaching averages of up to 77 mm.

* Meteoblue climate diagrams are based on 30 years of hourly weather model simulations

Figure 5.1: Climate (temperature and rainfall) graphs of the Alice area (Meteoblue, 2017) 5.1.2 Topography The Eastern Cape Province contains a wide variety of landscapes, from the stark Karoo (the semi-desert region of the central interior) to mountain ranges and gentle hills rolling down to the sea. The mountainous area on the northern border forms part of the Great Escarpment. Another part of the escarpment lies just north of Bhisho, Somerset East and Graaff-Reinet. In the south of the province the Cape Folded Mountains start between East London and Port Elizabeth and continue westward into the Western Cape. Like KwaZulu-Natal, the Eastern Cape is characterised by a large number of short, deeply incised rivers flowing parallel to each other.

Aquatic Assessment


The proposed study area is situated at elevations ranging between 480 and 550 m.a.m.s.l. The average slope in the immediate study area is 3%, with the maximum slope of 7.4%, -10.4%. 5.1.3 Geology and Soils (Source: Groundwater Sensitivity Assessment, 2017) * This section of the report has largely been quoted from the Groundwater Sensitivity Assessment (Water Resource Development and Engineering Services, 2017)

Geology The study area is located within sandstones and mudstones of the Beaufort Group of rocks (Figure 5.2). Surrounding the study area the Beaufort Group is intruded by Karoo dolerite. Soils The soil within the proposed study area is classified according to the Binomial System for Southern Africa as shallow sandy soils that occur on sandstone. They have a bleached layer above the partially weathered underlying rock and are erodible. The dominant soil form identified is classified as Cartref. The alluvium adjacent to the river can reach depths of 3 m and as such has an influence on basal flow to the river. The three trial pits dug during the Groundwater Assessment, revealed the same horizons, namely an orthic A horizon on a lithocutanic horizon. They generally have shallow brown and grey brown sandy loam (8% clay) topsoil that overlies semi-weathered mudstone or sandstone. The mottled layer with iron concretions is indicative of a seasonal perched water table. These soils found in the study area are usually shallow and not highly fertile.

Figure 5.2: Geology of the study area.

Aquatic Assessment


5.1.4 Hydrogeological Two (2) types of aquifers were identified within the study area namely deep to shallow primary (porous) aquifers in the alluvial areas (Quaternary Alluvium) and deeper secondary (fractured) aquifer in the Burgersdorp Formation. The primary porous aquifer was found immediately adjacent to the river, while the deeper, main aquifer, with a permanent water table is found in the fractured sandstone or mudstones of the Burgersdorp Formation. A comprehensive Groundwater Assessment has been conducted by Water Resource Development & Engineering Services (2017) and can be consulted for further details on the current groundwater situation and impacts related to this proposed activity on the groundwater resources. 5.1.5 Surface water features 5.1.5.1 Quaternary catchment and Water Management Area There are nine (9) water management areas (WMAs) established and defined within the Government Notice No. 35517 of 27 July 2012, according to the National Water Act (NWA), 1998 (Act No. 36 of 1998) and supported by the National Environmental Management Act (NEMA), 1998 (No. 107 of 1998). The study area falls within the Mzimvubu to Tsitsikamma WMA (WMA 7), which incorporates two former Water Management Areas, namely WMA 12 - Mzimvubu to Keiskamma (referred to as the eastern half of the new WMA) and WMA 15 – Fish to Tsitsikamma (referred to as the western half of the new WMA). The Mzimvubu to Keiskamma WMA covers an area of 66 211km2 in which the mean annual precipitation ranges from 450mm in the north-western interior to more than 1 200mm along the coast in the north-east. Rainfall occurs throughout the year in the WMA, but is highest during the summer months. The north-western half of this WMA makes up 6% of the total surface area and is located within KZN, while the remaining of the surface area is situated in the Eastern Cape. Land use in the water management area is predominantly for livestock farming and subsistence agriculture. There are several irrigation developments, some of which are only partly operational, and timber is grown commercially in the higher rainfall areas (NWRS, 2004). The Keiskamma River falls within the Amatole Drainage region. The study area is located within quaternary catchment R10D (primary catchment R) (Figure 5.3). According to an assessment conducted by the Department of Water and Sanitation in 2004, this catchment area covers an area of approximately 178 km2 with a natural MAR of 61.16 million m3/a. This catchment area forms part of the Sandile Regional Water Supply Scheme. In an assessment conducted by the Department of Water Affairs in 2002, it was determined that 2.2 km2 of this catchment area is under alien vegetation infestation, approximately 6 km2 under afforestation and just over 5 km2 covered by indigenous forests.

Aquatic Assessment


Figure 5.3: Quaternary catchment locality (study area indicated on inset map by a star). 5.1.5.2 Rivers A number of non-perennial tributaries of the Keiskamma River will be affected by the proposed activity (Figure 5.4).

Aquatic Assessment


Figure 5.4. Affected rivers in the study area.

i. The National Spatial Biodiversity Assessment (2004) The National Spatial Biodiversity Assessment of 2004 is a framework document within which fine-scale conservation planning in identified priority areas should occur. The NSBA integrates terrestrial, river, marine, estuarine and wetland ecosystems using available spatial data, relevant conservation planning software and a series of expert and stakeholder workshops. It is important to note that the NSBA was conducted at a national scale (1:250 000), and thus can only provide a general context for biodiversity assessments at a local level. An important tool used in the NSBA is conservation status. Conservation status aims at identifying threatened ecosystems, and is based on the classification scheme developed by the IUCN to categorise species. Of the 120 rivers in South Africa that have been classified using this categorisation, 44 % are critically endangered, 27 % are endangered, 11 % are vulnerable and 18 % are least threatened. The Keiskamma River (west of the site) is listed as VULNERABLE (Figure 5.5), while the affected tributaries of this river have not been classified.

Aquatic Assessment


Figure 5.5: Conservation status of the affected rivers in the study area (NSBA, 2004).

ii. National Freshwater Ecosystem Priority Areas (NFEPA), 2011-2014 The National Freshwater Ecosystem Priority Areas (NFEPA) project provides strategic spatial priorities for conserving South Africa‟s freshwater ecosystems and supports sustainable use of water resources. These priority areas are called Freshwater Ecosystem Priority Areas, or „FEPAs‟.

FEPAs were identified based on:

Representation of ecosystem types and flagship free-flowing rivers

Maintenance of water supply areas in areas with high water yield

Identification of connected ecosystems

Representation of threatened and near-threatened fish species and associated migration corridors

Preferential identification of FEPAs that overlapped with: o Any free-flowing river o Priority estuaries identified in the National Biodiversity Assessment 2011 o Existing protected areas and focus areas for protected area expansion identified in the

National Protected Area Expansion Strategy. The Keiskamma River in the subquaternary catchment in which the study area falls has been classified as a Freshwater Ecosystem Priority Area. FEPAs need to be managed in a way that maintains the good condition (A or B ecological category) of the river reach. Certain reaches of the Keiskamma River east of the site is classified as a Fish Support area. FSAs include sub-quaternary catchments that are important for the migration of threatened fish species. Ideally the river condition should be improved and alien invasive fish should be removed so that these sub-quaternary catchments can maintain their fish populations.

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Figure 5.6. Freshwater Ecosystem Priority Area status of the rivers in the study area (NFEPA, 2011-2014).

iii. Present Ecological State The tables provided in Appendix A indicate the Present Ecological State (PES), Ecological Importance (EI) and Ecological Sensitivity (ES) classification of the Keiskamma river and non-perennial tributaries assessed by the DWS as part of the Desktop PESEIS (2014). The PES of the Keiskamma River is classified as D: Largely Modified (a large loss of natural habitat, biota and basic ecosystem functions have occurred), while the EI is rated as moderate and the ES is rated as high. No PES, EI or ES data is available for the non-perennial rivers. 5.1.5.3 Ecoregions South Africa is a geologically, geomorphologically, climatically and ecologically complex country, and this has resulted in a diverse range of ecosystems, including rivers. River ecoregional classification or typing allows the grouping of rivers according to similarities based on a top-down nested hierarchy. The principle of river typing is that rivers grouped together at a particular level of the typing hierarchy will be more similar to one another than rivers in other groups. Ecological regions are regions within which there is relative similarity in the mosaic of ecosystems and ecosystem components (biotic and abiotic, aquatic and terrestrial). According to Department of Water Affairs and Forestry (2005) Level 2 River Ecoregional Classification System, the study area falls within Ecoregion 16: South Eastern Uplands. This ecoregion has the following characteristics:

Mean annual precipitation: Generally high.

Coefficient of variation of annual precipitation: Mostly moderate to low.

Drainage density: Medium in the north, tending towards low in the south.

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Stream frequency: Low to medium in the south, tending towards medium high in the north.

Slopes <5%: <20% (central areas), 20-50% (northern areas) and 50-80% (southern areas).

Median annual simulated runoff: Moderate to high.

Mean annual temperature: Moderate to moderately high.

Table 5.1. Main attributes of the South Eastern Uplands MAIN ATTRIBUTES SOUTH EASTERN UPLANDS

Terrain Morphology: Broad division (dominant types in bold) (Primary)

Plain Low Relief (limited); Plains moderate Relief; Lowlands; Hills and Mountains; Moderate and High Relief; Open Hills; Lowlands; Mountains; Moderate to High Relief; Closed Hills; Mountains; Moderate and High Relief

Vegetation types (dominant types in bold) (Primary)

Coast Hinterland Bushveld; Eastern Thorn Bushveld; Subarid Thorn Bushveld (very limited); Short Mistbelt Grassland; North Eastern Mountain Grassland; Moist Upland Grassland; Coastal Grassland (very limited); South Eastern Mountain Grassland (very limited); AltiMountain Grassland (very limited); Patches Afromontane Forest

Altitude (m a.m.s.l) (secondary) 300-500 (limited), 500-1700, 1700-2300 (limited)

MAP (mm) (modifying) 500 - 1000

Coefficient of Variation (% of annual precipitation)

<20 to 30

Rainfall concentration index 15 to 60

Rainfall seasonality Early to very late summer

Mean annual temp. (°C) 10 to 22

Mean daily max. temp. (°C): February 20 to 30

Mean daily max. temp. (°C): July 12 to 24

Mean daily min. temp. (°C): February 8 to 20

Mean daily min temp. (°C): July 0 to 10

Median annual simulated runoff (mm) for quaternary catchment

40 to >250

5.1.5.4 Wetlands Wetlands in South Africa have been mapped on a broad-scale by various stakeholders and have been included in the National Freshwater Ecosystem Priority Assessment (NFEPA, 2011-2014). Due to the broad-scale nature of the NFEPA map it is not spatially accurate and therefore some error is expected. The location of NFEPA wetlands was derived from the National Land Cover 2000 (Van Den Berg et al., 2008) and inland water features from the Department of Land Affairs‟ Chief Directorate: Surveys and Mapping (DLA-CDSM). All wetlands are classified as either „natural‟ or „artificial‟ water bodies. The NFEPA wetland map identifies important or sensitive wetlands and wetland clusters. A wetland cluster is a group of wetlands all within 1 km of each other and which are surrounded by relatively natural vegetation. Figure 5.7 below and Table 5.2 indicate the wetlands listed in the inventory surrounding the study area. According to Mucina and Rutherford (2006-2012) the vegetation in the study area is classified as Buffels Thicket and Bhisho Thornveld. The conservation status of these vegetation types is classified as “Vulnerable” and “Least threatened”, respectively.

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Figure 5.7: Affected wetlands and rivers.

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Figure 5.8 Wetlands located within 500 m of the infrastructure upgrades Table 5.2. Wetland classification for the wetlands within the study area (Nel et al., 2011). Wetlands Level 3:

Landscape Unit

Level 4: HGM Unit

Landscape setting

HGM Type Wetland Type Natural/ Artificial

NFEPA wetland condition (if available)

Wetland 1 Bench Flat Sub-Escarpment Savanna Flat

Artificial Z3 – Heavily to critically modified

Wetland 2 Bench Flat Sub-Escarpment Savanna Flat


Wetland 3 Valley floor Channelled valley-bottom

Sub-Escarpment Savanna Chanelled valley-bottom



Sub-Escarpment Savanna Chanelled valley-bottom


Wetland 5 Valley floor Unchannelled valley-bottom

Sub-Escarpment Savanna Unchannelled valley-bottom


Wetland 6 Valley floor Unchannelled valley-bottom

Sub-Escarpment Savanna

Artificial Z3 – Heavily to critically

Oxidation ponds

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Unchannelled valley-bottom

modified


Sub-Escarpment Savanna Channelled valley-bottom


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5.2 Site survey The PES, Ecosystem Functions and EIS are not normally assessed for artificial wetlands, as these habitats are not considered to be priority wetlands or wetlands with high biodiversity value. Standard practice is to conduct these assessments if the wetland habitat is considered important. However, over time an artificially created wetland could become an integral part of a new hydrological scheme while providing some valuable ecosystem services. In this instance, all wetlands on site where identified as storage dams and as such the PES was not rated for these systems. Dams on site:

GPS coordinates: 32°47'7.65"S, 27° 1'44.01"E

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Rivers:

Keiskamma River south west of the site (GPS coordinates: 32°47'18.98"S, 27° 1'0.93"E)

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Non-perennial stream (GPS coordinates: 32°46'57.97"S, 27° 1'42.71"E)

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Existing oxidation ponds:


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6 SITE SENSITIVITY In terms of Appendix 6 of the Amended EIA Regulations (2017) a specialist report must contain- (f) Details of an assessment of a specific identified sensitivity of the site related to the proposed activity or

activities and its associated structures and infrastructure inclusive of a site plan identifying alternatives; (g) An identification of any areas to be avoided, including buffers; (h) A map superimposing the activity including the associated structures and infrastructure on the

environmental sensitivities of the site including areas to be avoided, including buffers;

A sensitivity map (Figure 6.1 below) was developed based on desktop and site information gathered, and was classified into areas of high, moderate and low sensitivity. High Sensitivity

All rivers and tributaries of the Rivers affected by the activity All activities within high sensitivity areas must be closely monitored by a qualified ECO to ensure that all proposed mitigation measures are implemented to manage and minimize potential impacts on the watercourse. Moderate Sensitivity

All artificial wetlands. In this instance all artificial wetlands are also storage dams and as such has little to no conservation value.

Within 50 m of the 1:100 floodline (if this has been determined) or within 50 m of the centreline of a river/stream/drainage system.

Moderate sensitivity areas act as buffers for the high sensitivity areas. Activities that may have an indirect impact on high sensitivity areas are not to occur within these buffer areas. Such activities would include:

Stockpiling of topsoil, subsoil, etc.

Temporary ablution facilities

Site camp establishment

Temporary laydown areas for equipment/materials

Overnight parking of heavy machinery/vehicles.

Concrete batching Low Sensitivity

500 m safe buffer placed around wetlands (regulated by DWS)

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Figure 6.1 Sensitivity map of the study area.

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7 MANNER IN WHICH THE ENVIRONMENT MAY BE AFFECTED In terms of Appendix 6 of the NEMA EIA Regulations (2014) a specialist report must contain- (cB) A description of the existing impacts on the site, cumulative impacts of the proposed development

and levels of acceptable change; (j) A description of the findings and potential implications of such findings on the impact of the proposed

activity or activities; (k) Any mitigation measures for inclusion in the EMPr;

Impacts that could be a direct or indirect result of the proposed activity, were identified for the Planning and Design, Construction and Operation Phase. These included the consideration of direct, indirect and cumulative impacts that may occur and also considers the no-go or existing impacts. Table 7.1 below provides a summary of the potential risks identified and their applicability to each phase of the proposed activity. Table 7.1 Potential risks identified that could result from the proposed activity.

THEME APPLICABILITY TO EACH PHASE

PLANNING AND DESIGN CONSTRUCTION OPERATION

Legal and policy compliance

YES Non-compliance with the laws and policies of South Africa as they pertain to the aquatic environment.

N/A N/A

Scheduling of construction

YES Inappropriate construction scheduling

N/A N/A

Stormwater management

YES Inappropriate design of stormwater structures.

YES Inappropriate routing of stormwater runoff.

YES Inadequate/ineffective stormwater infrastructure.

Invasion of alien species

YES Failure to plan for the removal and management of alien vegetation

YES Failure to monitor alien vegetation during construction.

N/A

Design of infrastructure

YES Inappropriate design and placement of associated infrastructure

N/A

N/A

Material stockpiling

N/A YES Stockpiling of construction material within 50 m of a watercourse can lead to erosion and sedimentation.

YES Failure to remove excess stockpiling material from site can lead to sedimentation and erosion of river systems.

Water Quality YES Failure to plan for monitoring of treated waste water quality

YES

Accidental contamination of wet concrete

Accidental chemical

YES

Re-use of poor quality treated waste water

Accidental sewage spills

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THEME APPLICABILITY TO EACH PHASE

PLANNING AND DESIGN CONSTRUCTION OPERATION

or other spills in the vicinity of watercourses/drainage lines.

Impact on dams N/A YES Inappropriate construction activities/ encroachment into dam areas.

N/A

Maintenance N/A N/A YES Inadequate maintenance of infrastructure can lead to sewage leaks, water leaks etc.

Table 7.2 to Table 7.4 provides the impacts and rating scales according to the various phases of the proposed activity.

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Table 7.2: Impacts and mitigation measures for the Planning and Design Phase.

PLANNING AND DESIGN PHASE

ISSUE/RISK DESCRIPTION OF IMPACT NATURE OF

IMPACT

SPATIAL SCALE

(EXTENT)

TEMPORAL SCALE (DURATION)

CERTAINTY SCALE

(LIKELIHOOD)

SEVERITY/ BENEFICIAL

SCALE

SIGNIFICANCE PRE-

MITIGATION

MITIGATION MEASURES

SIGNIFICANCE POST-

MITIGATION

Legal and policy compliance

During the planning and design phase non-compliance with the legal requirements and policies of South Africa as they pertain to the aquatic environment could lead to damage to the aquatic environment, unnecessary delays in construction activities, and potentially criminal cases, based on the severity of the non-compliance, being brought against the proponent and his/her contractors.

DIRECT Study area Short term Probable Moderately severe

MODERATE NEGATIVE

All legal matters pertaining to permitting must be completed prior to any construction activity.

In particular, all necessary Water Use Authorisations must be in order for any construction activities within the 1:100 year floodline, (or within 100 m of a watercourse), within 500 m of a wetland or where infrastructure will traverse rivers or drainage lines.

LOW NEGATIVE

Scheduling of construction

During the planning and design phase inappropriate construction scheduling that does not take into account the seasonal requirements of the aquatic environment, e.g. allowing for unimpeded flood events, could lead to short-term (and potentially long-term) impacts on the aquatic environment such as excessive sediment mobilization, etc.

INDIRECT Study area Medium term Possible Moderately severe

LOW NEGATIVE

Wherever possible, construction activities should be undertaken during the driest part of the year to minimize downstream sedimentation due to excavation, etc.

When not possible, suitable stream diversion structures (if necessary) must be used to ensure non-perennial river tributaries and the nearby river are not negatively impacted by construction activity.

LOW NEGATIVE


During the planning and design phase the inappropriate design of

DIRECT Study area Long-term Possible Severe HIGH NEGATIVE

During the planning and design phase

MODERATE NEGATIVE

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stormwater structures and associated infrastructure may result in increased levels of erosion, sedimentation and pollution of the watercourses.

appropriate stormwater structures must be designed to minimise erosion and sedimentation of watercourses.

Invasion of alien species

During the planning and design phase, failure to plan for the removal and management of alien vegetation could result in the invasion of alien vegetation in riparian and wetland areas during the construction and operation phase. This would have an adverse impact on the aquatic ecosystem.

INDIRECT Study area Long-term Probable Moderately severe

MODERATE NEGATIVE

During the planning and design phase a Rehabilitation and Alien Vegetation Management Plan must be designed to reduce the establishment and spread of undesirable alien plant species.

LOW NEGATIVE

Water quality During the planning and design phase failure to plan for monitoring of the quality of final treated waste water could result in ground/surface water pollution during operation of the WWTW.

DIRECT INDIRECT

Study area, downstream

Long-term Possible Severe HIGH NEGATIVE

During the planning and design phase an effective water quality (surface and groundwater) monitoring programme must be developed to ensure that the quality of treated waste water (discharged to land/irrigated) during operation is suitable.

LOW NEGATIVE

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Table 7.3: Impacts and mitigation measures for the Construction Phase.

ISSUE/RISK IMPACT NATURE OF IMPACT

SPATIAL SCALE

(EXTENT)

TEMPORAL SCALE

(DURATION)

CERTAINTY SCALE

(LIKELIHOOD)


SCALE

SIGNIFICANCE PRE-

MITIGATION

MITIGATION MEASURES SIGNIFICANCE POST-

MITIGATION

Material Stockpiling

During the construction phase, stockpiling of construction materials within 50 m of a watercourse could result in erosion and mobilisation of the materials into the nearby watercourse, resulting in sedimentation and a decrease in water quality and aquatic habitat.

DIRECT INDIRECT CUMULATIVE

Study area, downstream of water courses

Medium-term Possible Moderately negative

MODERATE NEGATIVE

During the construction phase no construction material must be stored within 50 m of a watercourse.

Stockpiles should not be placed within 50 m of watercourses.

Stockpiles within 100 m of watercourses must be monitored for erosion and mobilisation of materials towards watercourses. If this is noted by an ECO, suitable cut-off drains or berms must be placed between the stockpile area and the nearest watercourse.

Stockpiles should not exceed 1.5 m in height.

Stockpiles should be covered during periods of gale force winds.

LOW NEGATIVE

Water Quality During the construction phase, accidental contamination of wet concrete (highly alkaline) in the rivers/drainage lines could result in flash kills of macro-invertebrates and fish species in the vicinity (see appendix B).

DIRECT CUMULATIVE

Study area Short-term Possible Moderately severe

MODERATENEGATIVE

During the construction phase no concrete mixing must take place within 50 m of any river bank or drainage line.

All concrete mixing must occur on impermeable surfaces.

A serviced fire extinguisher (to neutralise pH levels if a spill occurs) must be available on site in the event that wet concrete is accidentally spilled into a river.

The mitigation measures in Appendix

LOW NEGATIVE

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B must be used in conjunction with this report.

During the construction phase, accidental chemical spills or other spills (sewage, etc.) in the vicinity of the rivers/drainage lines will result in water pollution, adversely affecting the aquatic ecosystem.

DIRECT CUMULATIVE

Study area, downstream of watercourses

Short-term Possible Moderately severe

MODERATENEGATIVE

During the construction phase no machinery must be parked overnight within 50 m of any waterbody.

All stationary machinery must be equipped with a drip tray to retain any oil leaks.

Chemicals used for construction must be stored safely on bunded surfaces in the construction site camp and not within 50 m of the river/drainage lines.

Emergency plans must be in place in case of spillages.

No ablution facilities should be located within 50 m of any river or the wetland.

Chemical toilets must be regularly maintained/ serviced to prevent ground or surface water pollution.

During the upgrades of the oxidation ponds careful care must be taken when moving sludge from one pond to another. No sewage sludge must be left on the ground or outside the ponds. Removal of any sludge from the ponds and off site may require waste licencing in terms of the National Environmental Management: Waste

LOW NEGATIVE

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Act.


During the construction phase the inappropriate routing of stormwater runoff will lead to stream sedimentation, adversely affecting the aquatic environment.

DIRECT Study area, downstream of water courses

Long-term Probable Moderately severe

MODERATE NEGATIVE

During the construction phase stormwater must be managed effectively to minimize the ingress of sediment-laden stormwater into the rivers/ wetlands.

LOW NEGATIVE

Alien vegetation

The removal of existing vegetation creates „open‟ habitats that will inevitably be colonised by pioneer plant species. While this is part of a natural process of regeneration, which would ultimately lead to the re-establishment of a secondary vegetation cover, it also favours the establishment of undesirable species in the area. These species colonise areas of disturbance and once established, they are typically very difficult to eradicate and can pose a threat to the ecosystem. Failure to monitor alien vegetation during construction could lead to infestations.

INDIRECT Study area Long-term Probable Moderately severe

LOW NEGATIVE

Vehicles and machinery should not encroach into areas outside/surrounding the planned project footprint.

Implement an Alien Management Plan during the construction phase.

Eradicate alien plants from the impacted area as they appear; and

Monitor the project area for any new growth of invasive plants until completion of construction.

Short-term monitoring for a period of 12 months after construction has been completed should be conducted.

LOW NEGATIVE

Impacts on the Dams (Artificial wetlands)

During the construction phase inappropriate activities/ encroachment into dam (artificial wetland) areas could affect the water

DIRECT INDIRECT

Study area Medium-term Possible Moderately severe

MODERATE NEGATIVE

During the construction phase no stockpiles should be placed within the 50 m dam buffer.

No ablution facilities must be located within

LOW NEGATIVE

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quality and integrity of the dams.

the 50 m dam buffer.

There should be no destruction of dam walls or excavation within the 50 m dam buffer.

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Table 7.4: Impacts and mitigation measures for the Operational Phase.

ISSUE IMPACT NATURE OF IMPACT

SPATIAL SCALE

(EXTENT)

TEMPORAL SCALE

(DURATION)

CERTAINTY SCALE

(LIKELIHOOD)


SCALE

SIGNIFICANCE PRE-

MITIGATION

MITIGATION MEASURES

SIGNIFICANCE POST-

MITIGATION

Stormwater runoff

During the operational phase stormwater infrastructure might not be adequate or effective and may result in soil erosion and sedimentation of watercourses.

DIRECT CUMULATIVE

Localised, downstream

Long-term Possible Moderately severe

MODERATE NEGATIVE

During the operational phase, stormwater management measures such as attenuation structures, channels, etc. must be properly maintained and monitored.

If the stormwater management measures put in place is deemed insufficient, a qualified engineer must be approached to assist with additional storm water attenuation mechanisms and remediation.

LOW NEGATIVE

Maintenance of sewage infrastructure

During the operational phase if the sewage infrastructure (WWTW, pump stations, pipelines) is not regularly maintained and checked for leaks or leaks are not repaired timeously this could lead to sewage polluting the aquatic environment.

INDIRECT CUMULATIVE

Localised Long-term Possible Moderately severe

MODERATE NEGATIVE

During the operation phase sewage infrastructure must be maintained and pipelines checked for leaks on a regular basis.

If leaks are identified or reported by the public, immediate actions must be taken to repair these leaks.

LOW NEGATIVE

Water quality During the operational phase the re-use of treated waste water for irrigation that is of a poor quality could result in ground and surface water pollution.

DIRECT INDIRECT



During the operation phase the quality of treated waste water must be continuously monitored.

The use of treated waste water for irrigation must conform to guidelines provided in the Department of Health‟s publication – Guide: Permissible Utilisation and

LOW NEGATIVE

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Disposal of Treated Sewage Effluent.

During the operational phase accidental spills from the WWTW, sewage pipelines or pump station could result in ground and surface water pollution.

DIRECT INDIRECT



During the operation phase sewage infrastructure must be regularly monitored for leaks. If any leaks or spills occur immediate actions must be taken to fix the leaks and remedy the spill.

LOW NEGATIVE

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8 IMPACT STATEMENT, CONCLUSION & RECOMMENDATIONS In terms of Appendix 6 of the Amended EIA Regulations (2017) a specialist report must contain-

(I) Any conditions for inclusion in the environmental authorisation; (m) Any monitoring requirements for inclusion in the EMPr or environmental authorisation; (n) A reasoned opinion- (i) whether the proposed activity, activities or portions thereof should be authorised; and (iA) regarding the acceptability of the proposed activity or activities, and (ii) If the opinion is that the proposed activity, activities or portions thereof should be authorised, any avoidance, management and mitigation measures that should be included in the EMPr, and where applicable, the closure plan; (q) Any other information requested by the competent authority.

8.1 Conclusions Lukhozi Consulting Engineers (LCE) have been appointed by Fort Cox College to undertake the design for the upgrading of water and wastewater infrastructure at the college near Alice in the Eastern Cape. EOH Coastal and Environmental Services (EOH CES) was appointed to conduct an assessment on the ecological importance of the aquatic environment affected by the proposed activity. This report provides input into the Draft Basic Assessment Report (DBAR) and Water Use Authorisations (WUAs) for the project. A number of non-perennial tributaries of the Keiskamma River and a number of artificial wetlands (storage dams) are located within the study area. A comparison of impacts in terms of the number of impacts per phase is illustrated in Table 8.1 below. HIGH pre-mitigation impacts relate to design of stormwater management, and water quality. All HIGH pre-mitigation impacts can be mitigated to MODERATE or LOW post-mitigation impacts by the application of appropriate mitigations as indicated in the EMPr. Table 8.1: Assessment of pre- and post-mitigation impact significance.

PRE-MITIGATION POST-MITIGATION

LOW - MOD - HIGH - VERY HIGH -

LOW - MOD - HIGH - VERY HIGH -

Planning and Design

1 2 2 0 4 1 0 0

Construction 1 5 0 0 6 0 0 0

Operation 0 2 2 0 4 0 0 0

TOTAL 2 9 4 0 14 1 0 0

8.2 Water Use Authorisation A Water Use Authorisation is required for any construction activity within the extent of a watercourse (i.e. riparian and instream habitat (or within 100 m of the watercourse) or the 1:100 year floodline; whichever is the greatest) or within 500 m of a wetland as well as for irrigation with treated waste water in terms of the following triggers from the National Water Act (No. 36 of 1998):

Sec 21 (c) - impeding or diverting the flow of water in a watercourse

Sect 21 (e) – engaging in a controlled activity: irrigation of land with waste or water containing waste

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Sec 21 (i) - altering the bed, banks, course or characteristics of a watercourse. The relevant WUAs must be obtained from the Department of Water and Sanitation prior to commencement of construction.

8.3 Recommendations for the proposed activity All the mitigation measures provided below are to be implemented in the Planning and Design, Construction and Operation Phases of the proposed activity. 8.3.1 Planning and Design

All legal matters pertaining to permitting must be completed prior to any construction activity.

In particular, all necessary Water Use Authorisations must be in order for any construction activities within the 1:100 year floodline, within 100 m of a watercourse, within 500 m of a wetland or where infrastructure will traverse any waterbody.

Wherever possible, construction activities should be undertaken during the driest part of the year to minimize downstream sedimentation due to excavation, etc.

When not possible, suitable stream diversion structures (if necessary) must be used to ensure the non-perennial river tributaries are not negatively impacted by construction activity.

During the planning and design phase appropriate stormwater structures must be designed to minimise erosion and sedimentation of watercourses.

During the planning and design phase a Rehabilitation and Alien Vegetation Management Plan must be designed to reduce the establishment and spread of undesirable alien plant species.

During the planning and design phase an effective water quality (surface and groundwater) monitoring programme must be developed to ensure that the quality of treated waste water (discharged to land/irrigated) during operation is suitable.

During the planning and design phase the infrastructure should be designed in such a manner that it does not obstruct the natural runoff patterns across the study area.

The pump stations and oxidation ponds must have sufficient pumping and storage capacity in order to minimise any potential contamination of surface or ground water or potential for overflows.

A generator must be in place in case of electricity outages.

An appropriate non-permeable overflow facility (at least 24 hour capacity) must be designed in case of a pump station failure.

Appropriate sealing and lining materials should be considered for the oxidation ponds. 8.3.2 Construction

During the construction phase no construction material must be stored within 50 m of a watercourse.

Stockpiles should not be placed within 50 m of watercourses.

Stockpiles within 100 m of watercourses must be monitored for erosion and mobilisation of materials towards watercourses. If this is noted by an ECO, suitable cut-off drains or berms must be placed between the stockpile area and the nearest watercourse.

Stockpiles should not exceed 1.5m in height.

Stockpiles should be covered during periods of gale force winds.

During the construction phase no concrete mixing must take place within 50 m of any river bank or the wetland.

A serviced fire extinguisher (to neutralise pH levels if a spill occurs) must be available on site in the event that wet concrete is accidentally spilled into a river.

The mitigation measures in Appendix B must be used in conjunction with this report.

During the construction phase no machinery must be parked overnight within 50 m of the rivers/wetland.

Aquatic Assessment


All stationary machinery must be equipped with a drip tray to retain any oil leaks.

Chemicals used for construction must be stored safely on bunded surfaces in the construction site camp.

No ablution facilities should be located within 50 m of any river or the wetland.

Chemical toilets must be regularly maintained/ serviced to prevent ground or surface water pollution.

During the upgrades of the oxidation ponds careful care must be taken when moving sludge from one pond to another. No sewage sludge must be left on the ground or outside the ponds. Removal of any sludge from the ponds and off site may require waste licencing in terms of the National Environmental Management: Waste Act.

During the construction phase stormwater must be managed effectively to minimize the ingress of sediment-laden stormwater into the rivers/ wetlands.

During the construction phase sensitive vegetation (if any) must not be impacted /removed.

Removal of alien invasive vegetation should be prioritised.

All no-go areas (if any) should be demarcated and marked as such.

Vehicles and machinery should not encroach into areas outside/surrounding the planned project footprint.

A Spill Contingency or Emergency Response Plan must be prepared prior to the commencement of the operation.

There should be no destruction of dam walls or excavation within the 50 m dam buffer

Monitor the project area for any new growth of invasive plants until completion of construction.

Short-term monitoring for a period of 12 months after construction has been completed should be conducted.

8.3.3 Operation

A pressure test must be performed prior to commissioning of the facility to ensure that there are no leaks in the reticulation.

During the operation phase, stormwater management measures such as attenuation structures, channels, etc. must be properly maintained and monitored.

If the stormwater management measures put in place is deemed insufficient, a qualified engineer must be approached to assist with additional storm water attenuation mechanisms and remediation.

The integrity of the sewerage system and associated infrastructure should be routinely monitored to identify any cracks or areas that could result in a leak. Any such incidents must be reported to the Waste management authority immediately.

If leaks are identified or reported by the public, immediate actions must be taken to repair these leaks.

During the operation phase the quality of treated waste water must be continuously monitored.

The use of treated waste water for irrigation must conform to guidelines provided in the Department of Health‟s publication – Guide: Permissible Utilisation and Disposal of Treated Sewage Effluent and regular compliance audits should be conducted.

8.4 Environmental statement and Opinion of the Specialist The aquatic impacts of all aspects for the proposed water and sanitation upgrades were assessed and considered to be acceptable, provided that the mitigation measures provided in this report are implemented. All impacts are rated as MODERATE to HIGH pre-mitigation, therefore implementation of recommended mitigation measures coupled with comprehensive rehabilitation and monitoring in terms of re-vegetation and restoration is an important element of the mitigation strategy. Implementing the recommended mitigations measures will reduce impacts to MODERATE and LOW.

Aquatic Assessment


9 REFERENCES Berliner D and Desmet P. Eastern Cape Biodiversity Conservation Plan, (2007). Department of Water Affairs and Forestry Project No. 2005-012. Buckley, D.J., (1997). The GIS primer. SANBI. Assessed online at: http://planet.botany.uwc.ac.za/nisl/bgis/GIS_primer/page_01.htm Department of Water and Sanitation, (2014). A Desktop Assessment of the Present Ecological State, Ecological Importance and Ecological Sensitivity per Sub Quaternary Reaches for Secondary Catchments in South Africa. Department of Water Affairs and Forestry (DWAF), South Africa. (2005). Mzimvubu to Keiskamma Water Management Area. Department of Water Affairs and Forestry (2005). A level 1 and 2 Ecoregional Classification System for South Africa, Lesotho and Swaziland. Guide: Permissible Utilisation and Disposal of Treated Sewage Effluent (1978). Kleynhans, C.J. (1996). A qualitative procedure for the assessment of the habitat integrity status of the Luvuvhu River. Journal of Aquatic Ecosystem Health 5: 41 - 54. Kleynhans, C.J. (1999). A procedure for the determination of the ecological reserve for the purposes of the national water balance model for South African Rivers. Institute for Water Quality Studies. Department of Water Affairs and Forestry, Pretoria. Lukhozi Consulting Engineers (2017). Preliminary Design report for the renovations/upgrading to the water services, water treatment plant, sanitation services and wastewater treatment works at fort cox college. Macfarlane, D.M., Kotze D.C., Ellery, W.N., Walters, D., Koopman, V., Goodman, P., Goge, C., (2007).WET-Health: A technique for rapidly assessing wetland health. WRC Report TT 340/08, Water Research Commission, Pretoria Mucina, L. & Rutherford, M.C. (eds) 2006. The vegetation of South Africa, Lesotho and Swaziland. Strelitzia 19. South African National Biodiversity Institute, Pretoria. National Water Resource Strategy, Department of Water Affairs (2013). Second Edition. National Environmental Management Act (No 107 of 1998) as amended. National Environmental Management: Biodiversity Act (No 10 of 2004). National Spatial Biodiversity Assessment (2004). National Water Act (No 36 of 1998) as amended. NFEPA Atlas, 2011 – 2014. SANBI (2009). Further Development of a Proposed National Wetland Classification System for South Africa. Primary Project Report. Prepared by the Freshwater Consulting Group (FCG) for the South African National Biodiversity Institute (SANBI). SANBI (bgis.sanbi.org). Technical Report for the National Freshwater Ecosystem Priority Areas project.

http://planet.botany.uwc.ac.za/nisl/bgis/GIS_primer/page_01.htm

Aquatic Assessment


The Constitution Act (108 of 1996). Water Resource Development and Engineering Services (2017). Groundwater Impact Assessment for the renovations/upgrading to the water services, water treatment plant, sanitation services and wastewater treatment works at Fort Cox College. Eastern Cape.

Aquatic Assessment


APPENDIX A Present Ecological State, Ecological Importance and Sensitivity of the Keiskamma River and associated tributaries in the affected subquaternary catchment river reaches. SELECT SQ REACH

SQR NAME LENGTH km STREAM ORDER PES ASSESSED BY XPERTS? (IF TRUE="Y")

REASONS NOT ASSESSED

PES CATEGORY DESCRIPTION

PES CATEGORY BASED ON MEDIAN OF METRICS

R10B-07640 Cata 26.44 1 Y LARGELY MODIFIED

D

MEAN EI CLASS MEAN ES CLASS

DEFAULT ECOLOGICAL CATEGORY (DEC)

RECOMMENDED ECOLOGICAL CATEGORY (REC)

MODERATE HIGH B 0.00

Present Ecological State, Ecological Importance and Sensitivity of the Keiskamma River. PRESENT ECOLOGICAL STATE ECOLOGICAL IMPORTANCE ECOLOGICAL SENSITIVITY

INSTREAM HABITAT CONTINUITY MOD

SERIOUS FISH SPP/SQ 6.00 INVERT TAXA/SQ

44.00 FISH PHYS- CHEM SENS DESCRIPTION

VERY HIGH

RIP/WETLAND ZONE CONTINUITY MOD

LARGE FISH: AVERAGE CONFIDENCE

2.33 INVERT AVERAGE CONFIDENCE

2.82 FISH NO-FLOW SENSITIVITY DESCRIPTION

HIGH

POTENTIAL INSTREAM HABITAT MOD ACT.

MODERATE FISH REPRESENTIVITY PER SECONDARY: CLASS

MODERATE INVERT REPRESENTIVITY PER SECONDARY, CLASS

VERY HIGH INVERT PHYS- CHEM SENS DESCRIPTION

VERY HIGH

RIPARIAN-WETLAND ZONE MOD

LARGE FISH REPRESENTIVITY PER SECONDARY: CLASS

MODERATE INVERT RARITY PER SECONDARY: CLASS

VERY HIGH INVERTS VELOCITY SENSITIVITY

VERY HIGH

POTENTIAL FLOW MOD ACT.

LARGE FISH RARITY PER SECONDARY: CLASS

MODERATE ECOLOGICAL IMPORTANCE: RIPARIAN-WETLAND-INSTREAM VERTEBRATES (EX FISH) RATING

LOW RIPARIAN-WETLAND-INSTREAM VERTEBRATES (EX FISH) INTOLERANCE WATER LEVEL/FLOW CHANGES DESCRIPTION

LOW

POTENTIAL PHYSICO-CHEMICAL MOD ACTIVITIES

MODERATE ECOLOGICAL IMPORTANCE: RIPARIAN-WETLAND-INSTREAM VERTEBRATES (EX FISH) RATING

LOW HABITAT DIVERSITY CLASS

MODERATE STREAM SIZE SENSITIVITY TO MODIFIED FLOW/WATER LEVEL CHANGES DESCRIPTION

HIGH

Aquatic Assessment


RIPARIAN-WETLAND NATURAL VEG RATING BASED ON % NATURAL VEG IN 500m (100%=5)

MODERATE HABITAT SIZE (LENGTH) CLASS

MODERATE RIPARIAN-WETLAND VEG INTOLERANCE TO WATER LEVEL CHANGES DESCRIPTION

LOW

RIPARIAN-WETLAND NATURAL VEG IMPORTANCE BASED ON EXPERT RATING

LOW INSTREAM MIGRATION LINK CLASS

LOW

RIPARIAN-WETLAND ZONE MIGRATION LINK

MODERATE

RIPARIAN-WETLAND ZONE HABITAT INTEGRITY CLASS

MODERATE

INSTREAM HABITAT INTEGRITY CLASS

HIGH

Aquatic Assessment


Concrete Works – Information and Mitigation Background Concrete, cement, mortars, grouts and other Portland cement or lime-containing construction materials are basic or alkaline materials. They are highly toxic to fish and must only be used near water with extreme care. What are acceptable pH ranges? A pH level around 7 is typical for most watercourses, and this neutral pH is required for the survival of aquatic organisms. Should the pH rise or drop out of this range, fish and other aquatic organisms will become stressed and may die. Complete isolation of the work area is needed to ensure that pH value in the surrounding waterbody does not rise (become more alkaline) during works. The Ministry of Water, Land, and Air Protection‟s British Columbia Approved Water Quality Criteria for pH sets the range for acceptable pH change with respect to fresh water aquatic life between 6.5 and 9.0. However, any increase in pH noted in conjunction with concrete works should be monitored and emergency protection measures implemented in accordance with the best practices below. Objectives The objective of this set of best practices is to ensure no concrete materials or leachates enter any watercourses. Operational or Construction-related Best Practices To ensure your works meet the requirements of applicable legislation: Concrete Works

Use pre-cast concrete structures whenever possible.

As concrete leachate is alkaline and highly toxic to fish and other aquatic life, ensure that all works involving the use of concrete, cement, mortars, and other Portland cement or lime containing construction materials (concrete) will not deposit, directly or indirectly, sediments, debris, concrete, concrete fines, wash or contact water into or about any watercourse.

Concrete materials cast in place must remain inside formed structures.

Keep a carbon dioxide (CO2) tank with regulator, hose and gas diffuser readily available during concrete work. Use it to release carbon dioxide gas into the affected area to neutralize pH levels should a spill occur. Train workers to use the tank.

Provide containment facilities for the wash-down water from concrete delivery trucks, concrete pumping equipment, and other tools and equipment.

Report immediately any spills of sediments, debris, concrete fines, wash or contact water. Implement emergency mitigation and clean-up measures immediately.

Completely isolate all concrete work from any water within or entering into any watercourse or stormwater system.

Monitor the pH frequently in the watercourse immediately downstream of the isolated worksite until completion of the works. Emergency measures will be implemented if downstream pH has changed more than 1.0 pH unit, measured to an accuracy of +/- 0.2 pH units from the background level, or is recorded to be below 6.0 or above 9.0 pH units.

Prevent any water that contacts uncured or partly cured concrete during activities like exposed aggregate wash-off, wet curing, or equipment washing from directly or indirectly entering any watercourse or stormwater system.

Maintain complete isolation of all cast-in-place concrete and grouting from fish-bearing waters for a minimum of 48 hours if ambient air temperature is above 0°C and for a minimum of 72 hours if ambient air temperature is below 0°C.

Aquatic Assessment


Isolate and hold any water that contacts uncured or partly cured concrete until the pH is between 6.5 and 8.0 pH units, and the turbidity is less than 25 nephelometric turbidity units (NTU), measured to an accuracy of +/- 2 NTU.

For further information regarding the safe use of concrete materials, refer to the following websites: Cement and Concrete: Environmental Considerations http://www.buildinggreen.com/features/cem/cementconc.html Carbon Dioxide for Concrete Wash Water Treatment http://www.praxair.com/Praxair.nsf/d63afe71c771b0d785256519006c5ea1/78b5b272ccfbcd88852565550069e32d?OpenDocument

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