Final Draft Report - South African Heritage Resources Agency

Transcription

Final Draft Basic Assessment Report
for the Proposed Development of x2
Dwelling Units & Associated Infrastructure
On Portion 49 & 50 of the Farm Uitzicht 216, Knysna
Reference No: NEAS REF: DEA/EIA/0001554/2012
DEA REF NR. 14/12/16/3/3/1/755
December 2013
BOKAMOSO
LANDSCAPE ARCHITECTS &
ENVIRONMENTALCONSULTANTS
P.O. BOX 11375
MAROELANA
0161
TEL: (012) 346 3810
Fax: 086 570 5659
Email:[email protected]
UITZICHT 216 KNYSNA
BASIC ASSESSMENT REPORT
(For official use only)
File Reference Number:
Application Number:
Date Received:
Basic assessment report in terms of the Environmental Impact Assessment Regulations, 2010,
promulgated in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998), as
amended.
Kindly note that:
1. This basic assessment report is a standard report that may be required by a competent authority
in terms of the EIA Regulations, 2010 and is meant to streamline applications. Please make sure
that it is the report used by the particular competent authority for the activity that is being applied
for.
2. This report format is current as of 1 September 2012. It is the responsibility of the applicant to
ascertain whether subsequent versions of the form have been published or produced by the
competent authority
3. The report must be typed within the spaces provided in the form. The size of the spaces provided
is not necessarily indicative of the amount of information to be provided. The report is in the form of
a table that can extend itself as each space is filled with typing.
4. Where applicable tick the boxes that are applicable in the report.
5. An incomplete report may be returned to the applicant for revision.
6. The use of “not applicable” in the report must be done with circumspection because if it is used in
respect of material information that is required by the competent authority for assessing the
application, it may result in the rejection of the application as provided for in the regulations.
7. This report must be handed in at offices of the relevant competent authority as determined by each
authority.
8. No faxed or e-mailed reports will be accepted.
9. The signature of the EAP on the report must be an original signature.
10. The report must be compiled by an independent environmental assessment practitioner.
11. Unless protected by law, all information in the report will become public information on receipt by
the competent authority. Any interested and affected party should be provided with the information
contained in this report on request, during any stage of the application process.
12. A competent authority may require that for specified types of activities in defined situations only
parts of this report need to be completed.
13. Should a specialist report or report on a specialised process be submitted at any stage for any part
of this application, the terms of reference for such report must also be submitted.
14. Tw
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15. Shape files (.shp) for maps must be included on the electronic copy of the report submitted to the
competent authority.
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SECTION A: ACTIVITY INFORMATION
Has a specialist been consulted to assist with the completion of this section?
NO
YES
X
If YES, please complete the form entitled “Details of specialist and declaration of interest” for the
specialist appointed and attach in Appendix I.
1.
PROJECT DESCRIPTION
General Project History and Background:
Note: It is very important to read this introduction section, because it provides crucial
background information that should be taken into consideration when perusing the
remainder of this Basic Assessment Report.
The application is for two dwelling houses and associated structures and infrastructure on
Portion 49 and Portion 50 of the Farm Uitzicht 216, Knysna. A right of way servitude has been
registered from Church Street in Brenton-on-Sea to the respective properties, but no physical
vehicle access has yet been constructed to provide access to the properties. At present
there is no formal access to any of the properties and therefore the application is also for an
access road.
From a town planning point of view the owners of the properties already have the right to
construct dwelling houses, but the applicable environmental legislation and policies requires
that an EIA application process (at the National Department of Environmental Affairs) and
OSCAE Permit application process (to be submitted to the involved local authority – the
Knysna Local Authority)) be followed prior to the construction of such houses and access
road.
According to the applicants they have engaged with the relevant authorities regarding the
construction of houses and an access over a period of more than ten years and the recent
history is briefly summarised below:
The owners already formerly followed an application process for the proposed houses and
access road. The former application was lodged at the local authority before the Amended
2010 EIA Regulations came into effect on 2 August 2010. At the time when the original
applications were lodged, the proposed activities (the construction of the private homes
and an access road) did not trigger any of the activities as listed in the former ECA and
NEMA EIA Regulations and therefore it was not necessary to follow an EIA process. The former
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application only required that the applicant obtain an OSCAE permit from the local authority
and the applicant eventually managed to obtain such permit.
After the OSCAE permit was issued, the applicant still had some issues to deal with and
unfortunately the delays resulted in the unexpected expiring of the OSCAE permit that was
issued. Please note that the local authority issued an OCSAE permit for the above mentioned
project and this means that the relevant authority already supported construction of houses
and an access road (in line with the activities as described in this application) on the two
properties.
After the OSCAE permit expired, the applicant appointed Bokamoso Environmental to assist
with the way forward and it was requested that Bokamoso meet with the local authority in
order to determine whether it will be possible to revive the OSCAE permit/ to extend the
validity of such permit.
Bokamoso then had a meeting with the relevant officials at the Knysna Local Municipality
and the local authority confirmed that the OSCAE Permit had expired and that it will not be
possible to revive it/ extend its validity. The local authority furthermore indicated that there is
a possibility that the proposed activities will now trigger listed activities as listed in the
Amended 2010 EIA Regulations and the relevant official recommended that we peruse the
EIA Regulations and determine whether any listed activities are triggered prior to re-entering
into an application process for a new OSCAE Permit. The proposed construction activities
were then compared with the 2010 Listed Activities and it was eventually confirmed that a
few activities as listed in Listing Notices 1 and 3 will be triggered. The activities that will be
triggered are listed and described in this report.
Due to the fact that DEA is the delegated authority responsible for the evaluation of the EIA
application, the local authority recommended that we refrain from submitting a separate
OSCAE permit to them for consideration. According to the local authority the OSCAE permit
will automatically be granted once the EIA authorisation has been granted by the
delegated authority.
Based on the above, it was decided to attach the new OSCAE permit application as part of
the BA Application and it is required that the involved local authority consider the BAR as well
as the OSCAE permit application and that the local authority issue the new OSCAE permit as
soon as authorisation has been granted by DEA (if DEA decides to grant authorisation). Refer
to Appendix J for the new OSCAE Permit Application
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The most sensitive aspect of this application is the access road to the properties. There are
two possible access alternatives. The first option is to construct the access road to the
proposed houses on the road servitude, which stretches from Brenton-on-Sea. The owners
and the relevant authorities (The Department of Water Affairs (DWA) and the management
of the Goukamma Nature Reserve) already did a thorough site walk-about (during the
former application process) in order to determine the preferred alignment for the Brenton-onSea access road and the proposed road alignment was plotted in accordance with the GPS
waypoints as determined on site during the walking exercise. The alignment as plotted mainly
follows the road servitude with only a few minor deviations.
The second access road alternative is to obtain access through the Goukamma Nature
Reserve from the Buffelsbaai Road. There is already an access point from the Buffelsbaai
road and a large section of this proposed access road already exists as an internal road of
the Goukamma Nature Reserve. It will only be necessary to upgrade the existing road and to
construct a small portion of road to the east in order to extend the road towards the
proposed houses.
The option of the proposed access road from the Goukamma Nature Reserve has always
been on the table, but the owners were reluctant to consider this option, because the
management of the Goukamma Nature Reserve/ Cape Nature agreed to provide access
on the condition that the remainder of the owners’ properties be conserved/protected
against further development by means of a Stewardship Agreement.
The owners were not in favour of such an agreement, because they did not know what such
an agreement entailed and they did not want their valuable land to be sterilised from future
development, especially since no similar restrictions were placed on the surrounding landowners when they obtained their accesses to their properties and when they developed
their homes/facilities. The owners were also not certain about the future plans of the
Goukamma Nature Reserve (i.e. the management of the Nature Reserve can decided to
construct a large hotel on the nature reserve property (as in the case of the proposed
Malelane Hotel in the Kruger National Park)/ they can decided to sell the land off for
development purposes) and if this option is followed, the owners will most probably struggle
to sell their properties which were subjected to severe conservation restrictions imposed on
the undeveloped portions of their farms.
We compiled a First Draft Basic Assessment Report (DBAR) for discussion purposes with the
relevant authorities and with the surrounding land-owners and in this Draft Report we
motivated that the Brenton-on-Sea access road was regarded as the preferred access
alternative because:
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-The proposed access road can act as fire-fighting road and it can also act as a fire break
(as in the case of the access road of Ms Susan Campbell – one of the neighbours);
-A large section of the servitude road is covered with highly flammable exotic invaders that
increase the fire risks in the area and the construction of the access road will result in the
removal of these invaders;
-The proposed access road will act as an emergency road;
-The proposed access road will assist in the open space maintenance and management
and it will also assist with the long terms eradication of weeds and exotic invaders (the land
will be more accessible); and
-It will not be necessary for the owners to enter into a restrictive Stewardship Agreement with
the relevant authorities.
This first DBAR was discussed with the relevant parties during a focus group meeting that was
held at the Buffelsbaai Restaurant in October 2013, but most parties present, including the
management of the Goukamma Nature Reserve, disagreed with the Brenton-on Sea access
proposal.
The parties present at the meeting however indicated that they were satisfied (in principle)
with the proposed positioning of the houses and their associated outbuildings and
infrastructure, because the proposed “cluster-and-space” layout concept closer to the
beach will make fire-fighting in larger blocks easier. It will also be easier to protect the houses
and outbuildings from fire if they are situated away from the larger continuous block of land
to be burnt.
The management of the nature reserve did however not regard the proposed Brenton-onSea access road as necessary for firefighting; emergency situations or environmental
management. The management of the Goukamma Nature Reserve and the other affected
parties expressed their concerns regarding the proposed access road on the road servitude
and they were adamant that any form of access from Brenton-on-Sea had to be prevented.
The management of the Goukamma Nature Reserve indicated that they regard the
Goukamma access alternative as the preferred alternative from a social, economic,
ecological and institutional point of view and they recommended that Bokamoso arrange a
discussion meeting with the owners to discuss the various options. According to the
management of the Nature Reserve there are various levels of stewardship agreements and
they also indicated that they have now formulated the agreement options into a userfriendly document and that such options will be made available to the owners for
consideration.
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The follow-up meeting was arranged and took place in George at the offices of
Environmental Affairs on 28 October 2013. During this meeting the management of the
Goukamma Nature Rebserve (on behalf of Cape Nature) made the user-friendly
Stewardship Agreement option document available to the owners and explained the
purpose and advantages of such an agreement. They also indicated that they will afford the
owners an opportunity to consider all the possible levels of agreement before making any
decisions.
During the meeting the owners indicated that each of them currently have the right to
construct x5 dwelling houses on their farms and that they did not want to “let-go” of such
rights. It was furthermore explained that the study area has very high eco-tourism potential
and that they did not want to lose the opportunity to fulfil in such needs when the time is ripe
for tourism development in the specific area.
It was then explained by the management of the Goukamma Nature reserve that the
Stewardship Programme makes provision for the reservation of additional sections of the
larger study area for future development and such future development area will eventually
be indicated and/fixed on a development masterplan/ framework plan compiled in
conjunction with the nature reserve. The Stewardship programme also makes provision for
public-private partnerships and according to the management of the Goukamma Nature
Reserve; the only expansion option for the nature reserve is towards the east (into the
properties/farms of the owners). The owners indicated that they also want the section of the
access road (the Brenton-on-Sea access road) on their properties (which were delineated on
site and for which the GPS waypoints were specifically identified on site) to be incorporated
into the larger master plan/ development framework for the possible construction of future
private
internal
circulation
routes
(i.e.
when
future
expansions
(in
line
with
the
masterplan/development framework takes place). It was eventually decided that all possible
future facilities/ structures/ roads etc. to be developed on the farms will be discussed and
fixed during the compilation of the Stewardship Agreement.
According to the Goukamma Nature Reserve the signing of such a Stewardship Agreement
also holds other advantages to the owners (i.e. the Goukamma Nature Reserve will offer to
assist with firefighting on the properties, they will assist with the policing of the area, they will
assist with the maintenance of the fire breaks and the open spaces, they will assist with the
maintenance of the access road, they will assist with the eradication of weeds and exotic
invaders and they will assist with the rehabilitation of disturbed/ exposed areas).
It is also important to note that Ms Susan Campbell (one of the neighbours) also forwarded a
letter which confirms that they will also be willing to enter into a stewardship agreement with
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the Nature Reserve if the owners agree to sign such an agreement. This undertaking from Ms
Campbel and her family is appreciated and the owners feel strongly about the fact that the
surrounding land-owners should also sign such agreements, because it will guarantee the
future protection of the area as a whole and it will promote holistic, pro-active and
integrated planning of the entire area (including the Goukamma nature reserve, which can
only expand to the east).
Even though the management of the Goukamma Nature Reserve regarded the proposed
access road through the Goukamma Nature Reserve as the preferred access alternative,
they do not regard the current access point from the Buffelsbaai road and the existing road
alignment through the nature reserve as the long terms and final alternative. Apparently the
existing access road crosses through a small wetland area and the intention is to move the
access point away from the wetland area and to re-align the access/internal road to areas
that are less sensitive.
It was also decided that the proposed re-alignment of the internal road and the access
position will form part of future planning and due to the fact that Dr. Herman Joubert (one of
the owners) is a well-known traffic engineer, Dr. Joubert’s assistance with the proposed new
access point and re-alignment will be much appreciated.
The shorter term plan is however to utilise the existing access position and internal road in its
current position until the proposed new access road and internal road re-alignment have
been approved by the relevant authorities.
The owners perused the Stewardship Agreement options supplied to them by the
Goukamma Nature Reserve management and they have now indicated, in writing that they
are willing to sign an agreement with the government to regulate future development on
their properties. The signing of such an agreement and the provision of such an agreement
to the delegated authority must be incorporated as one of the conditions of approval (if the
delegated authority agrees to approve the proposed private development).
a)
Describe the project associated with the listed activities applied for
The Proposed construction of the following structures and infrastructure on Portion 49
and Portion 50 of the Farm Uitzicht 216, Knysna:

An access road that will serve the two Farm Portions. There are currently two road
access road alternatives.
Access Road Alternative (S1):
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This access road alternative traverses an existing registered servitude for a local
road on Portions 39, 40 and 41 of the Farm Uitzicht 216, Knysna. The alignment of
the access road on these Portions deviates from the registered servitude to avoid
sensitive vegetation and achieve a superior alignment from a road construction
point of view. It has been agreed with the owner of the property that a new
servitude will be registered. According to the interested and affected parties and
the relevant authorities, this access alternative is not the preferred alternative.
This access road traverses the Goukamma Nature Reserve, which is situated to the
west of the study area. The owners (and their workers/ guests etc.) will be entitled
to use the existing access gate from Buffelbaai Road and to drive to their farms on
an existing internal road, which cuts through the nature reserve. Only minor road
clearing and grading works will be required towards the east where the existing
road will be extended toward the proposed new dwellings.
According to the interested and affected parties and the relevant authorities, this
access alternative is not the preferred alternative.
Goukamma Nature reserve however indicated that they will only consider it to
provide access to the properties if the owners agree to enter into a Stewardship
Agreement, which will ensure the long term protection and management of the
larger area.
At this stage the owners indicated that they are willing to enter into a Stewardship
Agreement and therefore Bokamoso and the owners also regard Alternative 2 as
the preferred alternative.







The construction of outbuildings on both Farm Portions;
The installation of services (water, sewage, electricity (solar/ Eskom power)) on
both Farm Portions;
The construction of x 2 dwelling units and ancillary buildings (x1 dwelling unit on
each Farm Portion);
The construction of fire breaks;
The construction of elevated boardwalks/ pedestrian pathways (on ground level)
to provide beach access to both dwelling units;
All the activities as listed above will require some vegetation clearance;
Conservation lines/ fences will be erected to prevent damage to natural areas that
will surround the structures as listed above.
Refer to Figure 1 for Locality map and refer to Figure 2 for an Aerial Photograph
b)
Provide a detailed description of the listed activities associated with the project as
applied for
Listed activity as described in GN R.544, 545 and 546
Description of project activity
GN R.544 Item 9
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The construction of facilities or infrastructure
exceeding 1000 metres in length for the bulk
transportation of water, sewage or storm water(i) With an internal diameter of 0,36 metres or
more; or
(ii) With a peak throughput of 120 litres per
second or more,
Excluding where:
a. Such facilities or infrastructure are for bulk
transportation of water, sewage or storm
water or storm water drainage inside a road
reserve; or
Where such construction will occur within urban
areas but further than 32 metres from a
watercourse, measured from the edge of the
watercourse.
GN R.544 Item 11
The construction of:
(i) Canals;
(ii) Channels;
(iii) Bridges;
(iv) Dams;
(v) Weirs;
(vi) Bulk storm water outlet structures;
(vii) Marinas;
(viii) Jetties exceeding 50 square metres in size;
(ix) Slipways exceeding 50 square metres in size;
(x) Buildings exceeding 50 square metres in
size; or
(xi) Infrastructure or structures covering 50
square metres or more
Where such construction occurs within a
watercourse or within 32 metres of a watercourse,
measured from the edge of a watercourse,
excluding where such construction will occur
behind the development setback line.
The proposed residential dwelling
units
and
their
associated
outbuildings and structures on both
farm portions will require the
installation of services (on site/
municipal services).
In the case of municipal services it
will most probably be necessary to
install
pipelines
and
other
infrastructure (i.e. pump stations)
that will exceed 1 000 metres in
length. The internal diameter of
infrastructure that exceeds 1000
metres will be less than 0.36
metres.
Access to the proposed x2 dwelling
units
and
its
associated
outbuildings and infrastructure,
forms a very important part of this
application. At present there is no
vehicular access to the properties.
Two alignment alternatives for the
proposed access road to the
properties will be considered. The
alignment
alternatives
have
already been described above.
Furthermore, both farm portions
are situated within the 100m high
watermark and there is also a
strong possibility that some of the
proposed
structures
and
infrastructure will also encroach
the 100m line.
Although no evidence was found of
any watercourses during site visits,
there is also a possibility that the
proposed access road will cut
across
some
non-perennial
drainage lines.
December 2013
An
elevated/
low-impact
pedestrian walkway (at ground
level)/ boardwalk that will provide
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UITZICHT 216 KNYSNA
access to the beach will form part
of the associated structures
applied for.
During discussions, the relevant
authorities indicated that they
would prefer non-elevated beach
access (especially at the high-water
mark/after the first dune), because
elevated
boardwalks
cannot
accommodate the ever changing
dunes and water levels.
Security is also becoming an issue
in the area and therefore it will
also be necessary to implement
some form of access control.
According to the management of
the Goukamma Nature Reserve,
the existing access road through
the Goukamma Nature Reserve
traverses a watercourse/small
wetland/marshy area immediately
after the entrance into the reserve.
Some upgradings (i.e. road
widening/ the installation of a
culvert/ small bridge structure)
might be necessary in this area to
accommodate the proposed access
to the properties through the
nature reserve. Please note that
the relevant authorities regard this
access road alternative as the
preferred alternative.
GN R.544 Item 16
Construction or earth moving activities in the
sea, an estuary, or within the littoral active zone
or a distance of 100 metres Inland of the highwater mark of the sea or an estuary, whichever
is the greater, in respect of –
i.) Fixed or floating jetties and slipways;
ii.) Tidal pools;
iii.) Embankments;
iv.) Rock revetments or stabilizing structures
including stabilizing walls;
v.) Buildings of 50 square metres or moreDecember 2013
The two farm portions are situated
within 100 metres of the highwater mark and the seashore
forms the southern boundary of
the two farm portions.
Both sites slope slightly in a
southerly
direction.
The
construction and associated site
clearance on both properties (one
house with associated structures/
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But excluding
a.) If such construction or earth moving activities
will occur behind a development setback line;
or
b.) Where such construction or earth moving
activities will occur within existing ports or
harbours and the construction or earth
moving activities will not increase the
development footprint or throughput
capacity of the port or harbor;
c.) Where such construction or earth moving
activities is undertaken for purposes of
maintenance of the facilities mentioned in (i)(vi) above; or
Where such construction or earth moving activities
is related to the construction of a port or harbor, in
which case activity 24 of Notice 545 of 2010
applies.
GN R.544 Item 17
The planting of vegetation or placing of any
material on dunes and exposed sand surfaces,
within the littoral active zone for the purpose of
preventing the free movement of sand, erosion or
accretion, excluding where the planting of
vegetation or placement of material relates to
restoration and maintenance of indigenous coastal
vegetation or where such planting of vegetation or
placing of material will occur behind a
development setback line.
buildings and infrastructure on
each farm portion) will exceed 50
square metres.
The natural area can be
characterized by a thick deposit of
recent windblown (Aeolian) sand
that covers much of the site above
the high-water mark. It forms an
extensive sand dune system, which
has largely been stabilized by
vegetation (some of the vegetation
used by the authorities for the
stabilisation of the dunes are
exotics).
Two exposed sand surfaces/ dune
areas occur on Portion 50 and it is
envisaged to plant indigenous and
preferably endemic vegetation in
these areas. This will also include
the establishment of small on-site
indigenous nurseries that will
ensure the continuous provision of
onsite material to restore and
maintain the indigenous coastal
vegetation.
After the construction phase
rehabilitation will take place.
During the rehabilitation phase the
landowners wish to re-establish
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indigenous
and
endemic
vegetation on the disturbed
sections of the study area and a
long term rehabilitation plan will
also be put in place to assist with
the on-going removal of invader
species
The
land-owners
want
to
personally occupy the two houses
and they regard the protection and
rehabilitation
of
the
farm
properties involved as extremely
important.
GN R.544 Item 18
The infilling or depositing of any material of more
than 5 cubic metres into, or the dredging,
excavation, removal or moving of soil, sand,
shells, shell grit, pebbles or rock from
i) A watercourse;
ii) The sea;
iii) The seashore;
iv) The littoral active zone, an estuary or a
distance of 100 metres inland of the highwater mark of the sea or an estuary,
whichever distance is the greaterBut excluding where such infilling, depositing,
dredging, excavation, removal or moving
i)
Is for maintenance purposes undertaken in
accordance with a management plan agreed
to by the relevant environmental authority;
or
ii) Occurs behind the development setback line.
GN R.544 Item 24
The transformation of land bigger than 1000
square metres in size, to residential, retail,
commercial, industrial or institutional use, where,
at the time of the coming into effect of this
Schedule such land was zoned open space,
conservation or had an equivalent zoning.
The establishment of elevated
boardwalks/ on ground level
pedestrian walkways will most
probably trigger activity (iv) and the
possible upgrading works in and
around the watercourse area at the
proposed Goukamma Nature Reserve
access road will most probably trigger
activity (i).
The two farm portions and their
associated
outbuildings
and
structures are classified as being
part of a protected area therefore
this activity will be triggered as the
development of the dwelling units
and their associated outbuildings
and structures, services and access
road will be larger than 1 000
square metres in size.
At
December 2013
this
stage
the
estimated
13
UITZICHT 216 KNYSNA
ecological footprint for each
dwelling unit and associated
structures/ buildings is ± 2 500m²3 000m² per residential unit.
Even though the study area is
zoned agricultural, it is situated in
an area regarded as critical biodiversity area and such area is
regarded as conservation worthy.
GN R.544 Item 26
Any process or activity identified in terms of
section 53(1) of the National Environmental
Management: Biodiversity Act, 2004 (Act No. 10
of 2004).
According to the conservation plans
supplied by the involved Local
Authority, the study area is situated
in an area identified as a Critical
Biodiversity area as well as areas
with potential occurrence of
threatened species or habitat
important for supporting threatened
species.
The EMF compiled by DEA for the
area furthermore confirms that the
two farm portions are situated
within an area with high habitat
sensitivity and in an area regarded
as a Critical Biodiversity area.
Please note that the status of the
study area in terms of the BioDiversity Act is not confirmed yet,
but the delegated authority
however
recommended
that
Bokamoso incorporate such activity
in order to allow for the
incorporation of this activity if this
Listed Activity is triggered during the
application process.
It is therefore requested that the
delegated authority confirm (at the
end of the application process)
whether this activity should remain
as one of the listed activities applied
for.
If this listed activity is not included in
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the current application, a new
application would be required to
include this activity.
The inclusion of this activity was
specifically discussed with Mr. Danie
Smit from DEA and he agreed it will
be better to rather follow a cautious
approach by rather including this
activity from the start.
GN R.546 Item 4
The construction of a road wider than 4 metres
with a reserve less than 13,5 metres:
(d) in Western Cape:
i) In an estuary;
ii) All areas outside urban areas;
iii) In urban areas
(aa) Areas zoned for use as public open space
within urban areas; and
(bb) Areas designated for conservation use in
Spatial Development Frameworks adopted by
the competent authority, or zoned for a
conservation purpose.
The two farm portions and their
associated outbuildings/structures
and infrastructure fall outside the
urban area and as mentioned earlier
the construction of an access/
access roads to supply access to the
properties is inevitable.
Two potential access alternatives
will be investigated in the
application. The one alternative is to
gain access from the Goukamma
Nature Reserve (at present the
preferred alternative) and the
second alternative will be to
construct a private and narrow
access road on the alignment of a
proposed local road for which a road
servitude has been registered.
In the case of road Alternative 2, the
intention will not be to apply for the
approval of the local road, but only
for the approval of the sub-standard
private access road on the proposed
alignment of the local road and this
road will only be accessible to the
land-owners in the area and to
emergency vehicles during fire and
life threatening emergencies.
Please note that the construction of
the local road (if this is ever
planned) will require that a new EIA
application process be followed and
it will be recommended that this
December 2013
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UITZICHT 216 KNYSNA
requirement be emphasized in
conditions of approval (if
delegated authority agrees
approve the access road/
application).
the
the
to
the
At this stage the intention is to
construct an access road that is
narrower than 4m, but unforeseen
circumstances
during
the
construction and operational phases
could require that sections of the
road to be constructed are wider
than 4m (i.e. to re-align a section of
the road in order to avoid a tree/
some sensitive vegetation units/
species).
The detail design of the access road
will be made available prior to the
actual construction phase.
Also take note that the actual
construction phase could require (in
some areas) that construction
activities go above the 4m threshold
and
therefore
the
potential
construction phase requirements
could also trigger this activity.
GN R.546 Item 14
The clearance of an
area of 5 hectares or
more of vegetation
where 75% or more of
the vegetative cover
constitutes indigenous
vegetation,
except
where such removal of
vegetation is required
for:
a.) In Western Cape:
i.) All areas outside
urban areas.
The landowners have identified a
need to enhance the indigenous
fauna through after construction
rehabilitation works that will allow
for
the
re-establishment
of
indigenous/ endemic vegetation and
for the eradication of exotic species
and especially invasive species and
weeds.
(1) Purposes
of
agriculture
or
afforestation
inside
areas
identified
in
spatial
December 2013
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UITZICHT 216 KNYSNA
instruments
adopted by the
competent
authority
for
agriculture
or
afforestation
purposes;
(2) The undertaking of
a
process
or
activity included in
the list of waste
management
activities published
in terms of section
19 of the National
Environmental
Management:
Waste Act, 2008
(Act No. 59 of
2008) in which
case the activity is
regarded to be
excluded from the
list;
(3) The undertaking of
a linear activity
falling below the
thresholds
in
Notice 544 of
2010.
GN R.546 Item 16
The construction of:
(i) Jetties exceeding
10 square metres
in size;
(ii) Slipways exceeding
10 square metres
in size;
(iii) Buildings with a
footprint
exceeding
10
square meters in
size; or
(iv) Infrastructure
covering 10 square
meters or more
d) in Western Cape;
i.) All watercourses;
ii.) In an estuary:
i.)
Outside
urban
areas; in:
(aa) A protected
area identified in
terms of NEMPAA,
excluding
conservancies;
(bb)
National
December 2013
The construction of the dwelling
units and associated structures and
infrastructure (on each farm) will
most definitely trigger this activity,
because the farm portions are
situated outside the urban edge
and they are situated in close
proximity/adjacent
to
the
Goukamma Nature Reserve.
The combined footprint of the two
developments, which will also
require the implementation of
some infrastructure, will exceed
10m².
17
UITZICHT 216 KNYSNA
Where
such
construction
occurs
within a watercourse
or within 32 meters of
a
watercourse,
measured from the
edge of a watercourse,
excluding where such
construction will occur
behind
the
development setback
line.
Protected
Area
Expansion Strategy
Focus areas;
(cc) World Heritage
Sites;
(dd) Sensitive areas
as identified in an
environmental
management
framework
as
contemplated
in
chapter 5 of the Act
and as adopted by
the
competent
authority;
(ee) Sites or areas
identified in terms of
an
International
Convention;
At this stage the envisaged
ecological footprint for each unit is
± 2500 - 3000m² (including the
dwelling
units,
outbuildings,
exterior hard surfaces, boardwalks
etc.).
The proposed access road and
some of the other infrastructure
required (depending on the
availability of infrastructure) will
also require the clearance of 10m²
or more of vegetation.
Please take note that the proposed
access road will most probably cut
through areas that incorporate
non-perennial drainage lines/
watercourses.
(ff)
Critical
biodiversity areas or
ecosystem service
areas as identified in
systematic
biodiversity
plans
adopted by the
competent authority
or in bioregional
plans;
(gg) Core areas in
biosphere reserves;
(hh) Areas within 10
kilometers from
national parks or
world heritage sites or
5 kilometers from any
other protected areas.
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UITZICHT 216 KNYSNA
2.
FEASIBLE AND REASONABLE ALTERNATIVES
“alternatives”, in relation to a proposed activity, means different means of meeting the general
purpose and requirements of the activity, which may include alternatives to—
(a)
(b)
(c)
(d)
(e)
(f)
the property on which or location where it is proposed to undertake the activity;
the type of activity to be undertaken;
the design or layout of the activity;
the technology to be used in the activity;
the operational aspects of the activity; and
the option of not implementing the activity.
Describe alternatives that are considered in this application as required by Regulation 22(2)(h) of
GN R.543. Alternatives should include a consideration of all possible means by which the purpose and
need of the proposed activity (NOT PROJECT) could be accomplished in the specific instance taking
account of the interest of the applicant in the activity. The no-go alternative must in all cases be
included in the assessment phase as the baseline against which the impacts of the other alternatives
are assessed.
The determination of whether site or activity (including different processes, etc.) or both is appropriate
needs to be informed by the specific circumstances of the activity and its environment. After receipt of
this report the, competent authority may also request the applicant to assess additional alternatives that
could possibly accomplish the purpose and need of the proposed activity if it is clear that realistic
alternatives have not been considered to a reasonable extent.
The identification of alternatives should be in line with the Integrated Environmental Assessment
Guideline Series 11, published by the DEA in 2004. Should the alternatives include different locations
and lay-outs, the co-ordinates of the different alternatives must be provided. The co-ordinates should
be in degrees, minutes and seconds. The projection that must be used in all cases is the WGS84
spheroid in a national or local projection.
December 2013
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UITZICHT 216 KNYSNA
a)
Site alternatives
Note: No site alternatives were considered, because the applicants specifically purchased the
Farm Portions involved for the construction of private dwelling units. In the case of Portion
50, the family of the applicant has owned the property for approximately 50 years. The
tranquil setting, the attractive natural surroundings and the coastline, which borders the
properties, are just a few site assets that contribute to the high economic value of such
properties and both properties are much sought after for the development of lodges, guest
houses and private homes.
As already mentioned, the applicants intend to construct residential units for their personal
use on the two farm portions and the they also regard the protection and conservation of
the study area and its surroundings as a priority.
The applica ts e e i dicated that they are illi g to joi a reside t’s foru i the area a d
that they will assist with the protecting of the area (i.e. fire management, eradication of
exotic invaders, rehabilitation of the area with indigenous/ endemic vegetation and the
conservation of the area). They will also make the private road to be constructed for their
exclusive use available for fire management and emergency situations.
During a focus- group meeting with the management of the Goukamma Nature Reserve, the
possibility of trading the existing municipal caravan park on the ridge (before one enters
Buffelsbaai) with the study area was regarded as an option to consider. This option has been
discussed with the land-owners, but they indicated that they were not interested in such a
land-swop, because they regarded their land- alues, the “e se of Place of their properties,
the uniqueness of their properties and the exclusivity of their properties as irreplaceable and
more valuable that the existing under-utilised caravan park.
Description
Alternative 1 (preferred alternative)
Lat (DDMMSS)
Long (DDMMSS)
Alternative 2
Description
Lat (DDMMSS)
Long (DDMMSS)
Lat (DDMMSS)
Long (DDMMSS)
Alternative 3
Description
December 2013
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UITZICHT 216 KNYSNA
In the case of linear activities:
Alternative:
The proposed access road, which forms part
and parcel of this application and possible
water supply / sewage supply pipelines,
represents linear activities.
Latitude (S):
Alternative S2 (preferred)
 Starting point of the activity
 Middle/Additional point of the activity
 End point of the activity
°
.52 “
° 25.93 “
°
.
“
Longitude (E):
22°56 8.69 E
22°57 49.29 E
°
.
E
Access Road Alternative S2
This alternative will require the provision
of access through the Goukamma Nature
Reserve, which is situated to the
immediate west of the study area.
Initially, Alternative S1 as described
below was regarded as the preferred
alternative. The reasons for this are set
out in the introduction and background
section of this report.
After several discussion
sessions
between the relevant authorities, the
surrounding land-owners and the
owners, it agreed to recommend
Alternative S2 as the preferred
alternative.
The implementation of this alternative
however requires that the owners enter
into a Stewardship Agreement with the
relevant
authority.
The
owners
confirmed (in writing) that they are
willing to commit themselves to such a
Stewardship Agreement.
The agreement will be finalised if the
delegated authority authorise the private
projects as proposed in this BAR.
Refer to Figure 3 for the proposed alignment
of Alternative 2
December 2013
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UITZICHT 216 KNYSNA
Alternative S1 (if any)
34°
.
“
° 7.46 “
° 31.32 “
22°
.
E
°
0.84 E
22°58 46.92 E
Access Road Alternative S1
This alternative stretches from the east
(an existing dirt road from Brenton-onSea) towards the study area (mainly on
an existing local road servitude).
The alignment for this access road is the
alignment that follows the alignment of
the existing future local road servitude.
Apparently the original purpose of this
road servitude was to link the Buffalo Bay
village with Brenton-On-Sea.
According to the relevant authorities it is
highly unlikely that this road (as a local
road) will ever be constructed, because
the topography of the area earmarked
for the road and the rehabilitation
difficulties against such steep slopes
makes it almost impossible to construct
(especially the area to the west of the
study area, which incorporates steep
sand dunes that are currently covered
with vegetation that took many years to
achieve the current vegetative coverage).
Refer to Figure 3 for figure which
indicates the existing road servitude
Alternative S3
Services Alternative SA1:
(The preferred services alternative) – The provision of on-site water through the
abstraction of groundwater and the provision of an on-site sewage treatment system
Water:
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UITZICHT 216 KNYSNA
This alternative will not require the installation of any linear pipelines/ services. The
domestic water for the two houses will be obtained from ground water resources (a
borehole/ boreholes).1 The amount of water required will not be significant (approximately
1.5kl/day for each household and some water for irrigation of the rehabilitated areas).
One or two boreholes will be drilled on the properties and the boreholes will be equipped
with the required pumps and they will be registered at the National Department of Water
Affairs. If the amount of water required for the construction and operational phases of the
development exceeds the volume for permissible use, a Section 21 (a) water license
application will be submitted to DWA for consideration. At this stage we are however of the
opinion that the applicant will only require a General Authorisation (GA) from DWA,
because the volumes of water required will most probably fall within the permissible wateruse category. This must however be confirmed by DWA. At this stage it is estimated that
each household will require approximately 4kl/ water per day. As alternative, water supply
can be obtained from the existing municipal water supply in Buffels Bay over a distance of
approximately 1000 metres.
Sewer:
This alternative will require the installation of an on-site sanitation facility for the two
houses. Due to the fact that the properties are situated adjacent to each other, it is
proposed that only one such facility be erected for both dwellings. The type of system to
install will be confirmed with the DWA and the amount of sewer that will be treated on site
will be approximately 500-600m³ per annum. The effluent treatment threshold as set in the
National Environmental Management Act (as amended on 29 November 2013) is above the
amount of effluent that will be treated on the properties and therefore it will not be
necessary to apply for this activity. It will however be necessary to apply for a General
Authorisation for the discharge of treated effluent if the treated effluent will be discharged/
irrigated on the site. At this stage we are proposing that one Lilliput system/Scarab System/
similar system be installed for the treatment of the sewer generated by both houses.
A sewer suction system was also considered, but due to the low accessibility of the study
area and the pollution potential in the case of overflowing/spillages, the usage of suction
tanks is not regarded as a viable option.
As environmental consultants we are convinced that the proposed on site treatment of
sewer (in an environmental friendly manner) is the preferred sewage alternative.
1
During the meeting with Cape nature on 28 October 2013, the management of the Goukamma Nature Reserve indicated
that they have existing boreholes in the Goukamma Nature Reserve that are suitable for domestic purposes. The borehole/s
are situated adjacent to he proposed access road and the officials indicated that they are willing to consider it to make the
borehole water available to the owners for usage. This option will be discussed with the management in more detail and
DWA will also be consulted in this regard. Detail regarding further discussions will be included as part of the Final BAR.
December 2013
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UITZICHT 216 KNYSNA
Services Alternative SA2:
(Not the preferred Services Alternative)
This alternative i ol es the i stallatio of se e a d ate li es f o the Buffels aai
village/ from Brenton-on Sea. The sewer of the two houses will then be connected to the
u i ipal se e syste i stalled i Buffels aai / Brenton-on-Sea, but will require a pump
station. The proposed water-pipeline to be installed will also be connected to the municipal
ate syste of Buffels aai / Brento-on-Sea. Where possible the proposed two pipelines
will run parallel to each other. In some areas it will not be possible for the sewer and the
water to gravitate and therefore some sewer and water pump stations will have to be
installed. Leaking sewage and water pipes could have a detrimental effect on the
environment and the excavation required for the proposed pipeline will have impacts on the
natural vegetation and fauna. In places where it will not be possible to install underground
pipes, the proposed pipelines could also have visual impacts, especially from sensitive view
sheds such as the coastline.
For route alternatives that are longer than 500m, please provide an addendum with coordinates taken every 250 meters along the route for each alternative alignment.
In the case of an area being under application, please provide the co-ordinates of the
corners of the site as indicated on the lay-out map provided in Appendix A.
b)
Lay-out alternatives
Description
Lat (DDMMSS)
Long (DDMMSS)
°
.52 “
° 30.59 “
22°56 8.69 E
22°58 29.65 E
The proposed construction of the following structures
and infrastructure on Portion 49 and Portion 50 of the
Farm Uitzicht 216, Knysna:
•
•
•
•
•
•
•
An access road that will serve the two Farm Portions.
At this stage the preferred access road alternative is
the road that traverses the Goukamma Nature
Reserve;
The construction of associated outbuildings on both
Farm Portions;
The installation of services (water, sewage,
electricity (solar/ Eskom power) on both Farm
Portions – note on-site services will be provided to
prevent damage to the natural vegetation;
The construction of x 2 dwelling units (x1 dwelling
unit on each Farm Portion);
The construction of elevated boardwalks to provide
beach access to both dwelling units;
All the activities as listed above will require some
vegetation clearance;
Co se atio li es/ fe es ill e e e ted to p e e t
December 2013
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UITZICHT 216 KNYSNA
damage to natural areas that will surround the
structures as listed above. Fire breaks will need to be
implemented if Alternative 2 is not followed.
Note: A luste -a d spa e layout o ept as follo ed
and the proposed houses and associated outbuildings
and infrastructure were strategically positioned to:
- Provide easy beach access (for recreational and
emergency purposes);
- To limit the visual impacts;
- To limit damage to the existing vegetation; and
- To allow for effective fire management (the
management of the nature reserve recommended
that the structures be located closer to the beach
(away from the larger continuous block of vegetation
in the northern portions of the farms), because they
prefer burning exercises that involve larger
continuous blocks. The burning of smaller
fragmented blocks with structures in between
requires more fire breaks and more intensive fire
management procedures.
Refer to Figure 3
Alternative 2
Description
Lat (DDMMSS)
Long (DDMMSS)
Alternative two is similar to that of the preferred 34°
.
“
Alternative 1. The only difference lies in the access road
° 31.32 “
proposals. For this second alternative, the proposed
access road follows a registered right-of way servitude
from Church Street extension to the Campbell access
road plus Campbell access road – access via right-of-way
across Portions 39, 40 and 41, and then a new private
access via Portion 49 and Portion 50 to the position of the
residential dwellings position that straddles the boundary
between Portion 49 and Portion 50, some 150 metres
from the shore line.
22°
.
E
22°58 46.92 E
This route has been optimized by means of inspections by
all relevant authorities, inspection and local adjustment
by the road engineer and guidance from the botanist to
avoid sensitive plant species.
Please note that the evaluation of the road alternatives
already commenced more than 5 years ago. During the
initial investigations various departments (including
DWA) and a suitable qualified fauna and flora specialist
walked the site (with the owners) and confirmed that the
December 2013
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UITZICHT 216 KNYSNA
proposed alignment as indicated on the plans, are
suitable for the proposed access road.
During those initial walk-about exercises DWA even went
as far as to provide GPS waypoints for the preferred road
alignment in sensitive areas. The same route as formerly
determined on the site (which included the specific
waypoints determined) were again trailed, tested and
investigated during the most recent fauna and flora
exercises (beginning of 2013) and according to the fauna
and flora specialist, the alignment as proposed is
regarded as this alternative for the private access road to
the two properties.
If approved, this access road will be used and managed as
a private access road that will only be accessible to the
applicant, visitors of the applicant, surrounding landowners (on request) and emergency vehicles.
The intention is not at all to construct the local road as
envisaged by the local authority. A separate EIA
application will be required for the implementation of the
proposed local link road. According to the various
authorities it is highly unlikely that this road will ever be
constructed.
Even though the owners regard this access alternative
as a viable alternative, the surrounding land-owners and
the authorities are not in support of this access
alternative.
Alternative 3
Description
c)
Lat (DDMMSS)
Long (DDMMSS)
Technology alternatives
Technology alternatives considered include the following:
Sewer:
For purpose of the proposed on-site sanitation system the following alternatives are
considered:
A suction system, which involves the usage of suction pipes to empty the sewage,
which will be stored in sealed underground tanks. The sewage will then be discharged at
the municipal treatment works away from the study area;
Due to the sites accessibility problem, this alternative is not regarded as the preferred
alternative.
December 2013
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UITZICHT 216 KNYSNA
A septic tank system: Septic tanks are no longer supported by DWA, because it can
cause ground water pollution. This system is therefore not regarded as the preferred
system;
A Lilliput system or a system (acceptable to DWA) will be used and the water to be
released into the surrounding environment will comply with Special Standards. Refer to
Appendix K for more detail regarding the proposed on-site sanitation system.
Note: We are not specifically applying for EIA authorisation for the proposed on-site
sewage treatment system, because it does not trigger any activity as listed in the 2010
Amended NEMA EIA Regulations (also not listed in the NEMA EIA Regulations or NEMWA
as Amended on 29 November 2013).
Electricity:
At present the land-owners are considering the implementation of solar systems and
wind turbines, but the possibility of an Eskom connection as power supply/ back-up
power supply will also be investigated. The Western Cape has low radiation levels and
unpredictable wind patterns and this could reduce the effectiveness of Solar and Wind
Power as the only sources of electricity/ energy. Gas stoves and geysers are also
commonly used in the area and the applicants agreed to consider the usage of gas for
heating and cooking purposes.
Water:
As already explained, the applicants will use water from boreholes for their domestic
water supply. The ground water levels in the area are high and it is anticipated that
sufficient ground water will be available for the two houses. In order to reduce the
ground water abstracted for domestic usage, rain water tanks for the capturing of roof
water will also be installed at each house.
Alternative 2
Alternative 3
d)
Other alternatives (e.g. scheduling, demand, input, scale and design alternatives)
Alternative 2
Alternative 3
e)
No-go alternative
The no-go option entails that the development area stay in the current state.
Presently no sensitive features such as ridges, wetlands, nor any protected fauna and flora
species are present on site.
December 2013
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UITZICHT 216 KNYSNA
According to the fauna and flora specialist the vegetation of the study area is currently
disturbed by the occurrence of invasive species.
The construction of residential dwellings on the property, which will also include an ongoing rehabilitation plan, will in the longer terms assist with the eradication of invasive
species and the controlled replacement of such invaders with indigenous/ endemic
vegetation.
The applicants/ owners also confirmed that they are planning to retire on the properties
and that they regard the conservation, management and protection of the study area as
extremely important. The owners/ applicants ag eed to e o e pa t of a eside t s fo u
and they will assist with fire management and other environmental related actions
required to ensure the on-going protection and conservation of the area.
The rehabilitation plan to be implemented by the applicant will also involve the
establishment of a small on-site indigenous nursery and the plants cultivated in the nursery
will be used for purpose of the rehabilitation works envisaged in the area.
The proposed construction/ scraping of an access road towards the two properties will
make the surrounding and densely vegetated area more accessible for fire fighting and
other emergency situations. It will also supply easier access to the areas already invaded by
exotics and weeds and it will eventually allow for more effective rehabilitation of the areas,
environmental management and monitoring.
At present the vehicular road from Brenton-on Sea towards the study area terminates at a
point and the recent fauna and flora investigation (conducted for purpose of this
application) was conducted on foot and it was necessary to prune back vegetation to allow
for movement through the area.
Paragraphs 3 – 13 below should be completed for each alternative.
3.
PHYSICAL SIZE OF THE ACTIVITY
a)
Indicate the physical size of the preferred activity/technology as well as alternative
activities/technologies (footprints):
Alternative:
Alternative A12 (preferred activity alternative –
there is only one site/ locality alternative)
Alternative A3 (if any)
6 000m² (2 500m² –
3 000m² per dwelling
unit) excluding the
access road
m2
or, for linear activities:
2
“Alternative A..” refer to activity, process, technology or other alternatives.
December 2013
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UITZICHT 216 KNYSNA
Alternative:
Alternative S2 (preferred activity alternative –
through the Goukamma Nature Reserve)
Alternative S1 (second access road alternative
- linear/ the access road from Brenton-on-Sea)
Alternative S3 (if any)
b)
Length of the activity:
3 110m – (According
to the available
information this road
has no servitude) –
the size of the
proposed road will be
±10 500m² - please
note that a large
section of this road
will however follow
an existing road and
therefore the area to
be transformed will
be smaller than the
area to be
transformed for the
implementation of
Alternative S2
2 850m – (the
proposed access road
will be a single lane
road with a few (± 34) wider areas for
vehicles to pass each
other – the size of the
servitude is
±0.0114km² and size
of the proposed road
within the servitude is
± 9000m² - 10 000m²
m
Indicate the size of the alternative sites or servitudes (within which the above footprints
will occur):
Alternative:
Alternative A1 and S1 (preferred activity
alternative)
A1 – Activities on the two farm properties
Size of the site/servitude:
Activity A1 – The
extent of the
proposed activities
on the two farm
portions:
Portion 49:
50.7721 ha – the
development
footprint will occupy
December 2013
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UITZICHT 216 KNYSNA
less than 2% of the
total land area
Portion 50:
51.1 ha – in this case
the development
footprint will also
occupy less than 2%
of the total land area
Activity S2:
Alignment for the
access road – through
the Goukamma
Nature Reserve
3 110m – (According
to the available
information this road
has no servitude) –
the size of the
proposed road will be
±10 500m² - please
note that a large
section of this road
will however follow
an existing road and
therefore the area to
be transformed will
be smaller than the
area to be
transformed for the
implementation of
Alternative S1
Alternative A2 and S2 (if any)
There is no
alternative A2
Activity S1: Second
alternative access
road
2 850m – (the
proposed access road
will be a single lane
road with a few (± 34) wider areas for
December 2013
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UITZICHT 216 KNYSNA
vehicles to pass each
other – the size of the
servitude is
±0.0114km² and size
of the proposed road
within the servitude is
± 9000m² - 10 000m²
m2
Alternative A3 (if any)
4.
SITE ACCESS
Does ready access to the site exist?
YES
If NO, what is the distance over which a new access road will be built
NO
x
2 850m or 3 110m –
depending what
access road will be
constructed
(Alternative S1 or
Alternative S2)
Describe the type of access road planned:
This access road traverses the Goukamma Nature Reserve, which is situated to the west of
the study area. The owners (and their workers/ guests etc.) will be entitled to use the
existing access gate from Buffelbaai Road and to drive to their farms on an existing
internal road, which cuts through the nature reserve. Only minor road clearing and
grading works will be required towards the east where the existing road will be extended
toward the proposed new dwellings.
According to the interested and affected parties and the relevant authorities, this access
alternative is not the preferred alternative.
After a meeting with Cape Nature regarding the alternative access roads, it was
established that the access road for Portions 49 and 50 via the Goukamma Nature Reserve
is supported by Cape Nature rather than Alternative 2 (as described below). The owners of
Portions 49 and 50 have agreed to enter into a Biodiversity Stewardship Programme with
Cape Nature in order to protect the natural heritage of the area. The proposed access will
be constructed within a width of 3 metres and will be no wider than 4 (four) metres.
This access road alternative traverses an existing registered servitude for a local road on
Portions 39, 40 and 41 of the Farm Uitzicht 216, Knysna. The alignment of the access road
on these Portions deviates from the registered servitude to avoid sensitive vegetation and
December 2013
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UITZICHT 216 KNYSNA
achieve a superior alignment from a road construction point of view.3 It has been agreed
with the owner of the property that a new servitude will be registered. According to the
interested and affected parties and the relevant authorities, this access alternative is
not the preferred alternative.
Include the position of the access road on the site plan and required map, as well as an indication of the
road in relation to the site.
5.
LOCALITY MAP
An A3 locality map must be attached to the back of this document, as Appendix A. The scale of the
locality map must be relevant to the size of the development (at least 1:50 000. For linear activities of
more than 25 kilometres, a smaller scale e.g. 1:250 000 can be used. The scale must be indicated on
the map.). The map must indicate the following:









an accurate indication of the project site position as well as the positions of the alternative sites, if
any;
indication of all the alternatives identified;
closest town(s;)
road access from all major roads in the area;
road names or numbers of all major roads as well as the roads that provide access to the site(s);
all roads within a 1km radius of the site or alternative sites; and
a north arrow;
a legend; and
locality GPS co-ordinates (Indicate the position of the activity using the latitude and longitude of the
centre point of the site for each alternative site. The co-ordinates should be in degrees and decimal
minutes. The minutes should have at least three decimals to ensure adequate accuracy. The
projection that must be used in all cases is the WGS84 spheroid in a national or local projection).
3
An access road has already been constructed on Portions 39 of the farm Uitzicht within the right-of-way servitude. The
access to Portions 49 and 50 will traverse portions of Portions 39, 40 and 41 within the registered servitude. From Portion
41 the proposed access deviates from the registered servitude to avoid the dune crossing on Portion 49, avoid sensitive
plant species and achieve a better alignment from a road construction point of view.
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UITZICHT 216 KNYSNA
Figure 1 – Locality Map
Figure 2 – Aerial Map
6.
LAYOUT/ROUTE PLAN
A detailed site or route plan(s) must be prepared for each alternative site or alternative activity. It must
be attached as Appendix A to this document.
The site or route plans must indicate the following:







the property boundaries and numbers of all the properties within 50 metres of the site;
the current land use as well as the land use zoning of the site;
the current land use as well as the land use zoning each of the properties adjoining the site or sites;
the exact position of each listed activity applied for (including alternatives);
servitude(s) indicating the purpose of the servitude;
a legend; and
a north arrow.
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7.
SENSITIVITY MAP
The layout/route plan as indicated above must be overlain with a sensitivity map that indicates all the
sensitive areas associated with the site, including, but not limited to:






watercourses;
the 1:100 year flood line (where available or where it is required by DWA);
ridges;
cultural and historical features;
areas with indigenous vegetation (even if it is degraded or infested with alien species); and
critical biodiversity areas.
The sensitivity map must also cover areas within 100m of the site and must be attached in Appendix A.
8.
SITE PHOTOGRAPHS
Colour photographs from the centre of the site must be taken in at least the eight major compass
directions with a description of each photograph. Photographs must be attached under Appendix B to
this report. It must be supplemented with additional photographs of relevant features on the site, if
applicable.
9.
FACILITY ILLUSTRATION
A detailed illustration of the activity must be provided at a scale of at least 1:200 as Appendix C for
activities that include structures. The illustrations must be to scale and must represent a realistic image
of the planned activity. The illustration must give a representative view of the activity.
10.
ACTIVITY MOTIVATION
Motivate and explain the need and desirability of the activity (including demand for the activity):
1. Is the activity permitted in terms of the property’s existing
land use rights?
YES
X
NO
Even though the two land-owners have the right to construct private dwellings on their
properties, the proposed low impact development activities and the proposed access road
require an EIA authorisation in terms of the 2010 NEMA EIA Regulations from DEA and an
OSCAE permit from the involved local authority. The land use rights (zoning) permits the
construction of the dwelling units and ancillary buildings, while a registered servitude
provides for the access road.
2. Will the activity be in line with the following?
(a) Provincial Spatial Development Framework (PSDF)
YES
X
NO
Please explain
The proposed construction of private dwellings on farmland is in line with the PSDF. The
proposed activities cannot be regarded as an urban development and due to the low
impact/ small size of the proposed structures; it will be possible to provide on-site services
and infrastructure. It will not be necessary to connect the two houses to municipal
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UITZICHT 216 KNYSNA
services. The zoning and uses of the properties will not change; the properties will remain
farmland and will be conserved.
The introduction of the new private access road and the two dwelling units will promote
improved environmental management and monitoring on the sensitive areas (i.e. better
accessibility will make it easier to remove exotic invaders on a regular basis, fire
management will be more effective, security will be better).
(b) Urban edge / Edge of Built environment for the area
YES
X
NO Please explain
The proposed activities will include a low density rural development on farm portions (in
line with the surrounding private homes in farm portions). Owners of farm portions have
the right to construct private dwellings and associated outbuildings on their properties.
The proposed development will not be services and cannot be regarded as an urban
development.
(c) Integrated Development Plan (IDP) and Spatial
Development Framework (SDF) of the Local Municipality
(e.g. would the approval of this application compromise
the integrity of the existing approved and credible
municipal IDP and SDF?).
YES
X
NO
Please explain
No rezoning application will be required for the construction of the two houses and the
access road. The two houses will be developed as private farm houses and the proposed
access road will be constructed through the Goukamma Nature Reserve (Alternative S2) or
within existing road servitude (Alternative S1).
The proposed private and low scale development will be in line with the IDP. It is also
important to note that the involved local authority already (in a former application
process) approved the construction of the proposed access road and the private
dwellings4. An OSCAE permit has been issued, but unfortunately it lapsed and therefore
the applicant had to re-apply.
(d) Approved Structure Plan of the Municipality
YES
X
NO
Please explain
The proposed development will not require any rezonings and the proposed development
will be a rural-residential development, in line with the land-use as indicated on the
structure plan. As already mentioned, the town planning division of the local authority
support the construction of the proposed private dwellings.
(e) An Environmental Management Framework (EMF)
adopted by the Department (e.g. Would the approval of
YES NO
this application compromise the integrity of the existing
X Please explain
environmental management priorities for the area and if
so, can it be justified in terms of sustainability
considerations?)
If the environmental management guidelines as supplied in the EMP/ Rehabilitation Plan
are applied, the approval of the application will not compromise the integrity of the
existing environmental management priorities for the area. In fact, we are of the opinion
4
The existing rights allow for the construction of x5 houses on each farm portion
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UITZICHT 216 KNYSNA
that these proposed activities will assist with the more effective implementation of the
environmental management goals set for the area. At present the study area incorporates
some highly flammable exotic invaders that urgently need to be removed and replaced
with suitable indigenous/ endemic vegetation. This will only be possible if the area is
accessible and if the removal of these plants takes place in an on-going basis.
The vegetation on and around the study area currently creates high fire risks and the area
is not accessible for fire management. The proposed new private access road can also be
implemented to act as a fire break and as access route for fire trucks/ fire fighters during
fire conditions.
The two owners already confirmed their commitment to assist with the conservation and
protection of the surrounding area and they also offered to establish an on-site nursery
specifically for the rehabilitation of the area.
(f) Any other Plans (e.g. Guide Plan)
YES
X
NO
Please explain
As already mentioned, the proposed construction of the private farm houses will not
require a rezoning or a guide plan amendment. The proposed facilities will be in line with
the existing land-use for the area.
3. Is the land use (associated with the activity being applied for)
considered within the timeframe intended by the existing
approved SDF agreed to by the relevant environmental
authority (i.e. is the proposed development in line with the
projects and programmes identified as priorities within the
credible IDP)?
YES
X
NO
Please explain
The proposed construction of farm houses will not have an impact on any projects and
programmes identified as priorities within the credible IDP. The proposed facilities are a
low impact, private development and (as in the case of the surrounding farms) the landowners have the right to construct their private homes on the farm portions.
4. Does the community/area need the activity and the associated
land use concerned (is it a societal priority)? (This refers to
the strategic as well as local level (e.g. development is a
national priority, but within a specific local context it could be
inappropriate.)
YES
NO
Please explain
X
The community will not directly benefit from the implementation of the development. The
proposed access road will however make the surrounding and densely vegetated area
accessible for rehabilitation, the removal of exotic invaders and for fire fighting/ fire
prevention purposes. According to the fauna and flora specialist the fire risks on the study
area and its surroundings are high. The facilities will contribute to job creation, which is a
national priority.
5. Are the necessary services with adequate capacity currently
available (at the time of application), or must additional
capacity be created to cater for the development?
(Confirmation by the relevant Municipality in this regard must
be attached to the final Basic Assessment Report as
Appendix I.)
YES
NO
X
Please explain
Services will only be required for two private dwelling houses and the potential
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UITZICHT 216 KNYSNA
environmental damage of lengthy services pipelines for municipal sewer and water
connections will cause more damage than environmental friendly on-site services
solutions. The other houses on the surrounding farms also have on-site services. Electricity
is available to surrounding properties.
The proposed on-site sanitation system will be a DWA approved system and it will not
cause any ground water pollution. The domestic water will be abstracted from boreholes
and as already mentioned, the water demand for the two properties are very low. The
borehole/s will however be registered at DWA and a General Authorisation Application/
S21 WULA will be submitted to DWA for such boreholes.
6. Is this development provided for in the infrastructure
planning of the municipality, and if not what will the
implication be on the infrastructure planning of the
municipality (priority and placement of services and
opportunity costs)? (Comment by the relevant Municipality in
this regard must be attached to the final Basic Assessment
Report as Appendix I.)
YES
NO
X
Please explain
No implication, because the applicants will provide their own services, except for
electricity. It is however recommended that the involved local authority also supply
comments regarding this matter.
7. Is this project part of a national programme to address an
issue of national concern or importance?
YES
NO
X
Please explain
This is a private development.
8. Do location factors favour this land use (associated with the
activity applied for) at this place? (This relates to the
contextualisation of the proposed land use on this site within
its broader context.)
YES
X
NO
Please explain
The study area is situated in a rural area and the only two urban areas in close proximity
a e Buffels aai a d B e to -on-Sea. The study area is situated in an area which
incorporates low impact development (mainly single residential dwelling units on
farmland) and the proposed development fits into the broader context. The study area
and its surroundings are mainly covered with natural vegetation and it is linked to the
Goukamma Nature Reserve. The proposed dwelling units will cover less than 2% of the
properties and if well planned and managed, the proposed dwelling units will not have a
detrimental impact on the visual qualities of the area.
9. Is the development the best practicable environmental option
for this land/site?
YES
X
NO
Please explain
The proposed two private dwellings will have a low impact on the surrounding fauna and
flora and the implementation of the narrow private access road will have a dual purpose.
It will supply access to the two properties and it will open up the area for rehabilitation
purposes and for fire fighting and other emergency situations. The invasion of alien plant
species will be controlled.
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10. Will the benefits of the proposed land use/development
outweigh the negative impacts of it?
YES
NO
X
Please explain
At present the owners cannot reach their properties and they cannot develop their
dwellings for which they already have the rights. In exchange for the proposed low impact
development with an ecological footprint of approximately 3 000m² per dwelling unit, the
owners will provide an access road for rehabilitation, weed control, fire fighting and more
effective environmental management and monitoring. The security of the area will also be
improved.
11. Will the proposed land use/development set a precedent for
similar activities in the area (local municipality)?
YES
NO
X
Please explain
No, there proposed development will only be for private dwellings and there are already
some private dwelling units (in line with the proposed development) on the surrounding
farm portions. The proposed activities are in line with current land use rights and use of
surrounding properties is known by the relevant landowners.
12. Will any person’s rights be negatively affected by the
proposed activity/ies?
YES
NO
X
Please explain
The o e s ights to de elop eside tial d elli gs o thei p ope ties ill e egati ely
affected if the development proposal is rejected/ refused. The impact on adjoining
properties is within the existing rights.
13. Will the proposed activity/ies compromise the “urban edge”
as defined by the local municipality?
YES
NO
X
Please explain
The proposed development is not regarded as an urban development and it will therefore
not have any negative effect on the current urban edge.
14. Will the proposed activity/ies contribute to any of the 17
Strategic Integrated Projects (SIPS)?
YES
NO
X
Please explain
15. What will the benefits be to society in general and to the local Please explain
communities?
The proposed facilities will create a number of employment opportunities in an area with
high levels of unemployment, but not generate definite benefits towards the society as it
is a private residential development. An open property adjacent to the beach is subject to
temporary informal settlements and therefore the proposed development poses a safety
benefit as it will eliminate this occurrence on the property. The proposed development
will also assist with the eradication of invasive species and the reduction of fire risks.
16. Any other need and desirability considerations related to the proposed Please explain
activity?
The need to develop and utilize the property lies with the applicant. The proposed
development will consist of 2 houses with their associated outbuildings and infrastructure.
The site has been the property of the applicant for more than fifty years. The owners want
to make use of the properties and they are in favour of the protection and conservation of
the area, which is linked to the Goukamma Nature Reserve. The aim is to rehabilitate the
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UITZICHT 216 KNYSNA
properties and to manage the properties as an extension of the Goukamma Nature
Reserve, which is situated to the west of the study area. The owners are willing to cooperate with authorities and surrounding property owners to develop the potential of the
area for eco-tourism, conservation and environmental education.
17. How does the project fit into the National Development Plan for 2030?
Please explain
The proposed activities promotes sustainable development and the conservation of our
natural resources.
18. Please describe how the general objectives of Integrated Environmental Management as
set out in section 23 of NEMA have been taken into account.
The proposed activities will promote sustainable development. The land-owners are more
than willing to become part of a forum responsible for the conservation, protection and
on-going environmental management and monitoring of the study area and its
surroundings. The owners also indicated that they are more than willing to enter into a
public-private partnership with Cape Nature/ the management of the Nature Reserve and
the owners indicated that they will have no objection against the development of ecotourism focused facilities such as hiking trails, low impact tented camps, an environmental
education centre, offices for Cape Nature on their properties. They are willing to assist in
the planning and management of such facilities.
The owners are furthermore planning to implement an on-going rehabilitation plan and
weed removal programme. The eradication of exotic invaders will also be regarded as an
on-going environmental responsibility.
19. Please describe how the principles of environmental management as set out in section 2
of NEMA have been taken into account.
The app oa h is to i ple e t a luste -and-spa e de elop e t that ill allo fo the
provision of larger and continuous open spaces that will be easier to maintain and
manage.
The private development project will promote conservation and a long-term rehabilitation
plan will be implemented to ensure the ongoing eradication of exotic weeds and invaders
and the stabilisation of the sensitive dunes.
A public-private partnership (through the Stewardship Programme/ any other mechanism
as determined by the parties) will be established between Cape Nature, the owners and if
possible, the surrounding land-owners to ensure the long-term conservation, protection,
management and rehabilitation of this valuable area.
This integrated and holistic planning approach will also promote sustainable
development.
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11.
APPLICABLE LEGISLATION, POLICIES AND/OR GUIDELINES
List all legislation, policies and/or guidelines of any sphere of government that are applicable to the
application as contemplated in the EIA regulations, if applicable:
Title of legislation, policy Applicability to the project
or guideline
Administering
authority
Date
National Environmental
Management Act No. 107
of 1998
National
27
November
1998
See below
The NEMA is primarily an enabling Act in that it provides for the development of
environmental implementation plans and environmental management plans. The
principles listed in the act serve as a general framework within which environmental
management and implementation plans must be formulated.
Environmental Impact
Assessment Regulations
in terms of Chapter 5 of
the National
Environmental
Management Act, 1998
(Act No 107 of 1998)
See below
National
2010
The Minister of Environmental Affairs passed (in June 2010) the Amended Environmental
Impact Assessment Regulations in terms of Chapter 5 of the National Environmental
Management Act, 1998 (Act 107 of 1998) (NEMA).
The Amended Regulations came into effect on 2 August 2010, and therefore all new
applications must be made in terms of the Amended NEMA regulations and not in terms of
the 2006 NEMA Regulations or the New Regulations of the ECA. The purpose of this
process is to determine the possible negative and positive impacts of the proposed
development on the surrounding environment and to provide measures for the mitigation
of negative impacts and to maximize positive impacts.
Notice No. R 544, R 545 and R 546 of the Amended Regulations list the activities that
indicate the process to be followed. The activities listed in Notice No. R 544 requires that a
Basic Assessment process be followed and the Activities listed in terms of Notice No. R 545
requires that the Scoping and EIA process be followed. Notice No. 546 has been
introduced to make provision for Activities in certain geographical and sensitive areas.
Implications for the development
Significant– The application for the proposed development consists of activities listed
under Notice R. 544 (Listing No. 1) and R. 546 (Listing No. 3) and therefore a Basic
Assessment Report will be submitted to DEA for consideration.
National Water Act, 1998
(Act No. 36 of 1998)
See below
National &
Provincial
20 August
1998
The pu pose of this A t is to e su e that the atio s ate esou es are protected, used,
developed, conserved, managed and controlled in ways that take into account, amongst
December 2013
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UITZICHT 216 KNYSNA
other factors, the following:






Meeting the basic human needs of present and future generations;
Promoting equitable access to water;
Promoting the efficient, sustainable and beneficial use of water in the public
interest;
Reducing and preventing pollution and degradation of water resources;
Facilitating social and economic development; and
Providing for the growing demand for water use.
In terms of the section 21 of the National Water Act, the developer must obtain water use
licenses if the following activities are taking place:
a)
b)
c)
d)
e)
f)
g)
h)
i)
j)
k)
Taking water from a water resource;
Storing water;
Impeding or diverting the flow of water in a water course;
Engaging in a stream flow reduction activity contemplated in section 36;
Engaging in a controlled activity identified as such in section 37(1) or declared
under section 38(1);
Discharging waste or water containing waste into a water resource through a
pipeline, canal, sewer, sea outfall or other conduit;
Disposing of waste in a manner which may detrimentally impact on a water
resource;
Disposing in any manner which contains waste from or which has been heated in
any industrial or power generation process;
Altering the bed, banks, course or disposing of water found underground if it is
necessary for the safety of people;
Removing, discharging, or disposing of water found underground if ti is necessary
for the efficient continuation of an activity or for the safety of people; and
Using water for recreational purposes.
The National Water Act also requires that (where applicable) the 1:50 and 1:100 year flood
line be indicated on all the development drawings (even the drawings for the external
services) that are submitted for approval.
The proposed facilities are not subjected to flood lines of any perennial streams or water
course within an expected frequency of 1:50 and 1:100 years. The nearest perennial
stream is the Goukamma River and estuary and its inlet into the ocean is more than 1.5 km
of the nearest boundary of the site. In terms of Section 21 of the National Water Act, the
developer will not need any water licenses for the proposed development.
According to Cape nature the first section of the proposed access road through Goukamma
Nature Reserve (Note: there is already an existing road that follows the proposed access
road alignment) cuts through a watercourse/ marshy area. Some upgrading might require
a Section 21 WUL. The implications and requirements will be confirmed in the FBAR.
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Management: Air Quality
Act, 2004 (Act 39 of 2004)
See below
National &
2004
Provincial
The NEMA: AQA serves to repeal the Atmospheric Pollution Prevention Act (45 of 1965)
and various other laws dealing with air pollution and it provides a more comprehensive
framework within which the critical question of air quality can be addressed.
The purpose of the Act is to set norms and standards that relate to:





Institutional frameworks, roles and responsibilities
Air quality management planning
Air quality monitoring and information management
Air quality management measures
General compliance and enforcement.
Amongst other things, it is intended that the setting of norms and standards will achieve
the following:



The protection, restoration and enhancement of air quality in South Africa
Increased public participation in the protection of air quality and improved public
access to relevant and meaningful information about air quality.
The reduction of risks to human health and the prevention of the degradation of air
quality.
The Act describes various regulatory tools that should be developed to ensure the
implementation and enforcement of air quality management plans. These include:





P io ity A eas, hi h a e ai pollutio hot spots .
Listed A ti ities, hi h a e p o le
p o esses that e ui e a At osphe i
Emission Licence.
Co t olled E itte s, hi h i ludes the setti g of e issio sta da ds fo lasses of
emitters, such as motor vehicles, incinerators, etc.
Control of Noise.
Control of Odours.
During the construction phase, dust and the generation of noise can become a significant
factor, especially to the surrounding landowners. Activity will be limited to small scale
construction and closest dwellings 700 metres away (Buffels Bay). However if the
development is well planned and the mitigating measures are successfully implemented
the p oposed de elop e t s o t i utio to ai pollutio a d the ge e atio of ai
pollution can become less significant.
National Heritage
Resources Act, 1999 (Act
No. 45 of 1965 (NHRA)
See below
National &
Provincial
April 1965
The National Heritage Resources Act legislates the necessity and heritage impact
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UITZICHT 216 KNYSNA
assessment in areas earmarked for development, which exceed 0.5ha. The Act makes
provision for the potential destruction to existing sites, pending the archaeologist s
recommendations through permitting procedures. Permits are administered by the South
African Heritage Resources Agency (SAHRA).
There was no need for a heritage assessment on the proposed construction site, if any
such features are discovered during construction activities and clearing of the application
site, the o e t p o edu es fo a E i o e tal i ide t (at the end of EMP, Appendix
H) must be followed.
Management Protected
Areas Act, 2003 (Act No.
57 of 2003)
See below
National
2003
The purpose of this Act is to provide for the protection, conservation and management of
ecologically viable areas representative of “outh Af i a s iologi al iodi e sity a d its
natural landscapes.
A small section of the western side of Portion 50 of the Farm Uitzicht 216, Knysna RD falls
within the Protected area as indicated in the Protected Areas Act. However, considering
the position of the proposed activity this Act will not be applicable as the area of
construction falls outside the borders of the Protected area.
See below
Management:
Biodiversity Act, 2004 (Act
10 of 2004)
National
2004
The Biodiversity Act, provides for the management and protection of the count y s
biodiversity within the framework established by NEMA. It provides for the protection of
species and ecosystems in need of protection, sustainable use of indigenous biological
resources, equity and bioprospecting, and the establishment of a regulatory body on
biodiversity- South African National Biodiversity Institute.
Objectives of the Act:
(a) With the framework of the National Environmental Management Act, to provide for:
(i) The management and conservation of biological diversity within the Republic and of
the components of such biological diversity:
(ii) The use of indigenous biological resources in a sustainable manner; and
(iii) The fair and equitable sharing among stakeholders of benefits arising from bioprospecting involving indigenous biological resources;
(b) To give effect to ratified international agreements relating to biodiversity which are
binding on the republic;
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UITZICHT 216 KNYSNA
(c) To provide for co-operative governance in biodiversity management and
conservation; and
(d) To provide for a South African National Biodiversity Institute to assist in achieving
the objectives of this Act.
The proposed study area is classified as a Critical Biodiversity Area (CBA) as it is an area
with potential occurrence of threatened species or habitat that is important for supporting
threatened species. Considering the Botanical and Ecological study it is deemed necessary
to develop an access road through the site to the proposed houses as it would provide
access to manage alien and invasive plant species on the site as well. The layout of the
preferred alternative traverses through areas that are considered not to be sensitive and
which will have the least negative impact on the surrounding environment.
Conservation of
Agricultural Resources
Act, 1983 (Act No. 43 of
1983)
See below
National
1 June
1983
This act provides for control over the utilization of natural agricultural resources of South
Africa in order to promote the conservation of soil, water sources and the vegetation as
well as the combating of weeds and invader plants; and for matters connecting therewith.
The proposed development will be contributing to conservation of the site as an alien and
invasive species management programme will be implemented. An OSCAE permit have
been obtained by the applicant for development of residences and an access road within
an area proclaimed in terms of the Act, only limited activity is authorized.
Management: Waste Act
(Act 59 of 2009)
See below
National
11 June
2010
This Act came into effect on 11 June 2010. It aims to consolidate waste management in
South Africa, and contains a number of commendable provisions, including:
 The establishment of a national waste management strategy, and national and
provincial norms and standards, for amongst other, the classification of waste,
waste service delivery, and tariffs for such waste services;
 Addressing reduction, reuse, recycling and recovery of waste;
 The requirements for industry and local government to prepare integrated waste
management plans;
 The establishment of control over contaminated land;
 Identifying waste management activities that requires a license, which currently
include facilities for the storage, transfer, recycling, recovery, treatment and
disposal of waste on land;
 Co-operative governance in issuing licenses for waste management facilities, by
means of which a licensing authority can issue an integrated or consolidated license
jointly with other organs of state that has legislative control over the activity; and
 The establishment of a national waste information system.
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UITZICHT 216 KNYSNA
Not Significant :
Treated effluent is no longer listed as an activity in NEMWA. The amendments came into
effect on 29 November 2013.
No waste management license will be required during the construction or operational
phases of the proposed access road and residences. Due to the fact that a limited amount
of solid construction waste will be stored and handled on the site, before it is hauled away
and dumped at the nearest registered landfill site.
Management Act:
Integrated Coastal
Management Act, 2008
(Act 24 of 2008)
See below
National
2008
This legislation promotes the conservation of coastal areas as well as estuarine
environments. It encourages developments that are ecologically sustainable and socially
and economically justifiable. This Act defined coastal buffer areas as well as a coastal
protected zone where certain activities will require a permit. Some of these activities that
might be applicable to the proposed development include:
a) The erection, construction, placing, or any significant alteration or extension of a
building or structure;
b) The construction or any significant alteration or extension of a road;
c) The clearing of indigenous vegetation other than cultivated indigenous vegetation;
d) The stabilization or destabilization of dunes.
Significant – The study area falls within an area that relates to this act and the activities will
include the construction of two residential units and their outbuildings as well as an access
road which will involve the clearing of indigenous vegetation. However, the impact of the
proposed development will be low as its only for purposes of two residential houses that
will only be utilized on an ad-hoc basis.
Land Use Planning
Ordinance, 1995.
(Ordinance 15 of 1985)
Applications for
subdivision, township
developments and/or
rezoning as the existing
land use changes.
Ribbon Road
Development Act, 1940
(Act 21 of 1940)
As the access road will be
linked to a District Road a
Provincial Road Engineer is
required to approve any
application for the change
of land use rights.
Subdivision of
Agricultural Land Act,
1970 (Act 70 of 1970)
The property is excluded
from the urban edge and
therefore it is unlikely that
December 2013
Provincial
1985
1940
National
1970
45
UITZICHT 216 KNYSNA
the subdivision of land will
be approved. The size of
the surrounding land units
might also contribute to
such approval.
Western Cape Provincial
SDF (2009)
See below
Provincial
2009
The Western Cape Provincial SDF (WCPSDF) encourages new developments to be within
existing urban areas in order to minimise the impact on the rural and natural environment
and rather conserve it.
According to the SDF, the development of resorts and chalet type accommodation facilities
are encouraged rather than freehold tenure due to services such as water and energy. This
does not seem applicable for the proposed private residence as they will promote
environmentally friendly products and the water and electricity in a single house on a site
will never meet those demands in a resort. The proposed residence will ultimately be a
vacation house that will even lower the water and electricity demands. (Note: No land use
change, all activities within existing rights and Common Law)
Knysna SDF (2008)
See below
Municipal
2008
The proposed development site is located in a Core Conservation Area according to the
Knysna Spatial Development Framework. Such Area is described as the coastal dune areas
and its associated sensitive indigenous vegetation. The conservation of these areas is of
importance and those areas that are of low yield, in terms of forestry, should be
rehabilitated from the Western Head through to the Goukamma Nature Reserve, known as
the coastal green belt.
As the property falls within the Core Conservation Area, the private property should be of
low environmental and visual impact. This includes the dwelling house, associated
outbuildings and access road. The facilities should be located in the area with the least
impact on the environment.
12.
WASTE, EFFLUENT, EMISSION AND NOISE MANAGEMENT
a)
Solid waste management
Will the activity produce solid construction waste during the construction/initiation
YES
NO
phase?
X
If YES, what estimated quantity will be produced per month?
The information
is currently
unavailable, but
will be
submitted on
availability.
How will the construction solid waste be disposed of (describe)?
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UITZICHT 216 KNYSNA
During the construction phase the disposal of solid waste will be the responsibility of the
landowner. The solid waste will be delivered to a collection point in Knysna/ to a
registered landfill site.
Where will the construction solid waste be disposed of (describe)?
All construction solid waste will be transported to the solid waste disposal site of the
Knysna Municipality.
Will the activity produce solid waste during its operational phase?
YES
NO
X
Approximately
4m³/ month
How will the solid waste be disposed of (describe)?
The solid waste will be collected in bins on the application site and then dumped at the
nearest registered landfill site on a weekly basis. All materials that are suitable for
recycling will be separated and delivered to a collection point in Knysna. Organic waste will
be used for composting.
If the solid waste will be disposed of into a municipal waste stream, indicate which registered landfill
site will be used.
Local authority to provide information
Where will the solid waste be disposed of if it does not feed into a municipal waste stream (describe)?
The solid waste will be disposed of into the municipal waste stream.
If the solid waste (construction or operational phases) will not be disposed of in a registered landfill site
or be taken up in a municipal waste stream, then the applicant should consult with the competent
authority to determine whether it is necessary to change to an application for scoping and EIA.
Can any part of the solid waste be classified as hazardous in terms of the NEM:WA?
NO
X
If YES, inform the competent authority and request a change to an application for scoping and EIA. An
application for a waste permit in terms of the NEM:WA must also be submitted with this application.
Is the activity that is being applied for a solid waste handling or treatment facility?
YES
NO
X
If YES, then the applicant should consult with the competent authority to determine whether it is
necessary to change to an application for scoping and EIA. An application for a waste permit in terms
of the NEM:WA must also be submitted with this application.
b)
YES
Liquid effluent
Will the activity produce effluent, other than normal sewage, that will be disposed of
in a municipal sewage system?
Will the activity produce any effluent that will be treated and/or disposed of on site?
December 2013
YES
YES
NO
X
m3
NO
X
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UITZICHT 216 KNYSNA
If YES, the applicant should consult with the competent authority to determine whether it is necessary
to change to an application for scoping and EIA.
Will the activity produce effluent that will be treated and/or disposed of at another
facility?
If YES, provide the particulars of the facility:
Facility name:
Contact
person:
Postal
address:
Postal code:
Telephone:
Cell:
E-mail:
Fax:
YES
NO
X
Describe the measures that will be taken to ensure the optimal reuse or recycling of waste water, if any:
c)
Emissions into the atmosphere
Will the activity release emissions into the atmosphere other that exhaust emissions
and dust associated with construction phase activities?
If YES, is it controlled by any legislation of any sphere of government?
YES
NO
X
YES
NO
X
If YES, the applicant must consult with the competent authority to determine whether it is necessary to
change to an application for scoping and EIA.
If NO, describe the emissions in terms of type and concentration:
d)
Waste permit
Will any aspect of the activity produce waste that will require a waste permit in terms
of the NEM:WA?
YES
NO
X
If YES, please submit evidence that an application for a waste permit has been submitted to the
competent authority
e)
Generation of noise
Will the activity generate noise?
NO
YES Temporary
during the
construction
phase
X
If YES, is it controlled by any legislation of any sphere of government?
YES
NO
X
If YES, the applicant should consult with the competent authority to determine whether it is necessary
to change to an application for scoping and EIA.
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UITZICHT 216 KNYSNA
If NO, describe the noise in terms of type and level:
Noise will be temporarily generated during the construction phase of this project, but will
be low as the construction activities will be of small scale. Noise will not be regarded as an
issue during the operational phase, because the proposed application is only for two
private residents.
13.
WATER USE
Please indicate the source(s) of water that will be used for the activity by ticking the appropriate
box(es):
River, stream,
The activity will
Other
dam or lake
not use water
Investigations indicate that it would be possible to rely on local water supply, including
roof water collected and stored in underground tanks and ground water extraction from a
number of small well points in alluvial unconsolidated sand in the vicinity of the proposed
structures. This method has successfully been used in the Sedgefield area and elsewhere
in the Western Cape. Solar panels will be used to provide water supply to the dwelling
units and ancillary buildings. The Civil Engineer also indicated that it would be possible to
obtain water supply from the Municipality.
Municipal
Water board
Groundwater
If water is to be extracted from groundwater, river, stream, dam, lake or any other Not available
natural feature, please indicate the volume that will be extracted per month:
but will be
provided as
soon as it is
known.
Does the activity require a water use authorisation (general authorisation or water
NO
YES
use license) from the Department of Water Affairs?
X
If YES, please provide proof that the application has been submitted to the Department of Water
Affairs.
14.
ENERGY EFFICIENCY
Describe the design measures, if any, that have been taken to ensure that the activity is energy
efficient:
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The design of any structure will be done in a way to minimize energy consumption for
heating, cooling and lighting. Maximum use will be made of renewable energy sources and
electricity usage will be minimized. As a minimum, solar panels and solar geysers will be
installed, but if feasible, solar energy will be augmented by mini wind turbines. All
equipment will be installed where it will have a minimum visual impact.
Equipment for renewable energy generation will be designed according to the most recent
greenhouse technology and according to the SANS requirements. Renewable energy
sources will be connected to battery back-up and used primarily for water heating, lights
and small appliances and will be connected to a proposed underground cable reticulation
system from the main energy source.
The following could be considered:
 Where possible energy saving light bulbs must be used in all the units as well as
outside
 Time switches may be used for outdoor lighting
 Geysers must be fitted with insulation blankets
 Solar panels can be used to heat the water and geysers and for outdoor lighting.
Describe how alternative energy sources have been taken into account or been built into the design of
the activity, if any:
The EMP for the development will encourage each property owner to use solar power as
alternative energy source, even if this alternative source only supplies a fraction of the
energy required. However the applicant is determined to use renewable/alternative
sources for a large proportion of the total energy consumption.
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SECTION B: SITE/AREA/PROPERTY DESCRIPTION
Important notes:
1. For linear activities (pipelines, etc) as well as activities that cover very large sites, it may be
necessary to complete this section for each part of the site that has a significantly different
environment. In such cases please complete copies of Section B and indicate the area, which is
covered by each copy No. on the Site Plan.
Section B Copy No. (e.g. A):
2.
Paragraphs 1 - 6 below must be completed for each alternative.
3. Has a specialist been consulted to assist with the completion of this section?
YES
NO
If YES, please complete the form entitled “Details of specialist and declaration of interest” for each
specialist thus appointed and attach it in Appendix I. All specialist reports must be contained in
Appendix D.
Property
description/physi
cal address:
Province
District
Municipality
Local Municipality
Ward Number(s)
Farm name and
number
Portion number
Western Cape
Knysna Municipality – Town Planning and
Environmental Department
Knysna
Uitzicht 216
49 and 50
SG Code
C03900000000021600049
C0390000000 0021600050
C03900000000021600039
C03900000000021600040
C03900000000021600041
Where a large number of properties are involved (e.g. linear activities), please
attach a full list to this application including the same information as indicated
above.
Current land-use
zoning as per
local municipality
IDP/records:
Agriculture
In instances where there is more than one current land-use zoning, please
attach a list of current land use zonings that also indicate which portions each
use pertains to, to this application.
Is a change of land-use or a consent use application required?
December 2013
YES
NO
X
51
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3
9
0
0
3
9
0
0
3
9
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1.
GRADIENT OF THE SITE
Indicate the general gradient of the site.
Alternative S1: It depends on the specific location due to the dunes
Flat
1:50 – 1:20
1:20 – 1:15
1:15 – 1:10 1:10 – 1:7,5 1:7,5 – 1:5
10%
10%
10%
10%
Steeper
than 1:5
10%
40%
10%
Alternative S2 (if any):
Flat
1:50 – 1:20
1:20 – 1:15
1:15 – 1:10
1:10 – 1:7,5 1:7,5 – 1:5
Steeper
than 1:5
Alternative S3 (if any):
Flat
1:50 – 1:20
1:20 – 1:15
1:15 – 1:10
1:10 – 1:7,5 1:7,5 – 1:5
Steeper
than 1:5
2.
LOCATION IN LANDSCAPE
Indicate the landform(s) that best describes the site:
2.1 Ridgeline
2.2 Plateau
2.3 Side slope of hill/mountain
3.
2.4 Closed valley
2.5 Open valley
2.6 Plain
2.7 Undulating plain / low hills
2.8 Dune
2.9 Seafront
X
GROUNDWATER, SOIL AND GEOLOGICAL STABILITY OF THE SITE
Is the site(s) located on any of the following?
Alternative S1:
Shallow water table (less than 1.5m deep)
Dolomite, sinkhole or doline areas
Seasonally wet soils (often close to water
bodies)
Unstable rocky slopes or steep slopes with
loose soil
Dispersive soils (soils that dissolve in water)
Soils with high clay content (clay fraction more
than 40%)
Any other unstable soil or geological feature
An area sensitive to erosion
Alternative S2
(if any):
YES
NO
YES
NO
Alternative S3
(if any):
YES
NO
YES
NO
YES
YES
NO
NO
YES
NO
YES
NO
YES
NO
YES
NO
YES
NO
YES
NO
YES
NO
YES
NO
YES
NO
YES
NO
YES
NO
YES
NO
YES
YES
NO
NO
YES
YES
NO
NO
YES
YES
NO
NO
If you are unsure about any of the above or if you are concerned that any of the above aspects may be
an issue of concern in the application, an appropriate specialist should be appointed to assist in the
completion of this section. Information in respect of the above will often be available as part of the
project information or at the planning sections of local authorities. Where it exists, the 1:50 000 scale
Regional Geotechnical Maps prepared by the Council for Geo Science may also be consulted.
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UITZICHT 216 KNYSNA
4.
GROUNDCOVER
Indicate the types of groundcover present on the site. The location of all identified rare or endangered
species or other elements should be accurately indicated on the site plan(s).
Natural
veld Natural veld with
Natural veld Veld dominated
with
scattered
heavy
alien
Gardens
by alien speciesE
good conditionE
E
E
infestation
aliens
Building or other
Sport field
Cultivated land
Paved surface
Bare soil
structure
If any of the boxes marked with an “E “is ticked, please consult an appropriate specialist to assist in the
completion of this section if the environmental assessment practitioner doesn’t have the necessary
expertise.
5.
SURFACE WATER
Indicate the surface water present on and or adjacent to the site and alternative sites?
Perennial River
Non-Perennial River
Permanent Wetland
Seasonal Wetland
Artificial Wetland
Estuarine / Lagoonal wetland
YES
YES
YES
YES
YES
YES
NO
NO
NO
NO
NO
NO
UNSURE
UNSURE
UNSURE
UNSURE
UNSURE
UNSURE
If any of the boxes marked YES or UNSURE is ticked, please provide a description of the relevant
watercourse.
The only water body that is situated in close proximity of the study area is the ocean,
which is situated to the south-east of the study area.
6.
LAND USE CHARACTER OF SURROUNDING AREA
Indicate land uses and/or prominent features that currently occur within a 500m radius of the site and
give description of how this influences the application or may be impacted upon by the application:
Natural area
Low density residential
Medium density residential
High density residential
Informal residentialA
Retail commercial & warehousing
Light industrial
Medium industrial AN
Dam or reservoir
Hospital/medical centre
School
Tertiary education facility
Church
Old age home
Sewage treatment plantA
Train station or shunting yard N
December 2013
Polo fields
Filling station H
Landfill or waste treatment site
Plantation
Agriculture
River, stream or wetland
Nature conservation area
Mountain, koppie or ridge
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UITZICHT 216 KNYSNA
Heavy industrial AN
Power station
Office/consulting room
Military or police
base/station/compound
Spoil heap or slimes damA
Quarry, sand or borrow pit
Railway line N
Major road (4 lanes or more) N
Airport N
Museum
Historical building
Protected Area
Harbour
Graveyard
Sport facilities
Golf course
Archaeological site
Other land uses (describe)
Beach
Sand Dunes
If any of the boxes marked with an “N “are ticked, how will this impact / be impacted upon by the
proposed activity?
If any of the boxes marked with an "An" are ticked, how will this impact / be impacted upon by the
proposed activity? Specify and explain:
If any of the boxes marked with an "H" are ticked, how will this impact / be impacted upon by the
proposed activity? Specify and explain:
Does the proposed site (including any alternative sites) fall within any of the following:
Critical Biodiversity Area (as per provincial conservation plan)
Core area of a protected area?
Buffer area of a protected area?
Planned expansion area of an existing protected area?
Existing offset area associated with a previous Environmental Authorisation?
Buffer area of the SKA?
YES
YES
YES
YES
YES
YES
NO
NO
NO
NO
NO
NO
If the answer to any of these questions was YES, a map indicating the affected area must be included
in Appendix A.
7.
CULTURAL/HISTORICAL FEATURES
Are there any signs of culturally or historically significant elements, as defined in
section 2 of the National Heritage Resources Act, 1999, (Act No. 25 of 1999),
including Archaeological or paleontological sites, on or close (within 20m) to the
site? If YES, explain:
YES
NO
X
Uncertain
If uncertain, conduct a specialist investigation by a recognised specialist in the field (archaeology or
palaeontology) to establish whether there is such a feature(s) present on or close to the site. Briefly
explain the findings of the specialist:
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UITZICHT 216 KNYSNA
Will any building or structure older than 60 years be affected in any way?
NO
X
Is it necessary to apply for a permit in terms of the National Heritage Resources
NO
YES
Act, 1999 (Act 25 of 1999)?
X
If YES, please provide proof that this permit application has been submitted to SAHRA or the relevant
provincial authority.
8.
SOCIO-ECONOMIC CHARACTER
a)
Local Municipality
YES
Please provide details on the socio-economic character of the local municipality in which the proposed
site(s) are situated.
Level of unemployment:
The Knysna Municipality has an unemployment rate of 24.8% in 2011 which improved
since 2001 when it was 28.3%. This decrease in unemployment is highly unlikely due to the
closure of a number of businesses and the loss of job opportunities. This unemployment
rate excludes individuals younger than 15 and older than 65. 75.2% of the population is
employed in the formal or informal markets. A large component of the unemployed
section of the population is the youth that does not seem to have access to job
opportunities.
Economic profile of local municipality:
The wealth distribution of the Knysna Municipality is similar to what is experienced
nationally. 16.4% of households within the Municipality earn no income. The middle and
high income groups have increased since 2001. The last fifteen years the economy of
Knysna showed positive growth, however since the boom in 2005 the growth has slowed
down.
Level of education:
Within the Knysna Municipality there are fourteen Primary schools, four High schools and
four other Educational Institutions. A majority of the population, 93.5%, received primary
education but only 28.6% of the population have passed Matric and 2.5% have not
attended any form of schooling. There is a big concern within the municipality as more
individuals are passing Matric but less obtained a form of higher education (tertiary
qualification) as only 8% received higher education in 2011.
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b)
Socio-economic value of the activity
What is the expected capital value of the activity on completion?
±R 19 000,000.00
What is the expected yearly income that will be generated by or as a result of the Not significant.
activity?
Will the activity contribute to service infrastructure?
YES
NO
X
Is the activity a public amenity?
NO
YES
X
How many new employment opportunities will be created in the development and Approximately
construction phase of the activity/ies?
16 jobs
What is the expected value of the employment opportunities during the Approximately
development and construction phase?
R 2 million
What percentage of this will accrue to previously disadvantaged individuals?
Approximately
40%
How many permanent new employment opportunities will be created during the Approximately
operational phase of the activity?
6 jobs
What is the expected current value of the employment opportunities during the Approximately
first 10 years?
R 2 million
What percentage of this will accrue to previously disadvantaged individuals?
±95%
9.
BIODIVERSITY
Please note: The Department may request specialist input/studies depending on the nature of the
biodiversity occurring on the site and potential impact(s) of the proposed activity/ies. To assist with the
identification of the biodiversity occurring on site and the ecosystem status consult http://bgis.sanbi.org
or [email protected]. Information is also available on compact disc (cd) from the Biodiversity-GIS
Unit, Ph (021) 799 8698. This information may be updated from time to time and it is the applicant/
EAP’s responsibility to ensure that the latest version is used. A map of the relevant biodiversity
information (including an indication of the habitat conditions as per (b) below) and must be provided as
an overlay map to the property/site plan as Appendix D to this report.
a)
Indicate the applicable biodiversity planning categories of all areas on site and indicate
the reason(s) provided in the biodiversity plan for the selection of the specific area as
part of the specific category)
If CBA or ESA, indicate the reason(s) for its
selection in biodiversity plan
It is an area with potential occurrence of
threatened species or habitat that is
No Natural
important for supporting threatened
Area
species.
Remaining
(NNR)
Systematic Biodiversity Planning Category
Critical
Biodiversity
Area (CBA)
Ecological
Support
Area
(ESA)
Other
Natural
Area
(ONA)
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b)
Indicate and describe the habitat condition on site
Habitat Condition
Percentage of
habitat
condition
class (adding
up to 100%)
Natural
90%
Near Natural
(includes areas with
low to moderate level
of alien invasive
plants)
Degraded
(includes areas
heavily invaded by
alien plants)
Transformed
(includes cultivation,
dams, urban,
plantation, roads, etc)
c)
Description and additional Comments and
Observations
(including additional insight into condition, e.g. poor
land management practises, presence of quarries,
grazing, harvesting regimes etc).
%
10%
%
Complete the table to indicate:
(i)
the type of vegetation, including its ecosystem status, present on the site; and
(ii) whether an aquatic ecosystem is present on site.
Aquatic Ecosystems
Terrestrial Ecosystems
Ecosystem threat
status as per the
National
Environmental
Management:
Biodiversity Act (Act
No. 10 of 2004)
d)
Critical
Endangered
Vulnerable
Least
Threatened
Wetland (including rivers,
depressions, channelled and
unchanneled wetlands, flats,
seeps pans, and artificial
wetlands)
YES
NO
UNSURE
Estuary
YES
NO
Coastline
YES
NO
Please provide a description of the vegetation type and/or aquatic ecosystem present on
site, including any important biodiversity features/information identified on site (e.g.
threatened species and special habitats)
The proposed study area borders the coastal line in the south, a plantation to the north
and existing and proposed urban developments to the east and west. The vegetation of
the area is identified as South Cape Dune Fynbos and 20% of this vegetation type is under
formal conservation, the vegetation is regarded as Coastal Fynbos.
The area is considered to be in a pristine condition with some areas with severe invasion
of exotic trees, especially on the front dunes. The invader species have changed the soil
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UITZICHT 216 KNYSNA
characteristics and conditions in such a way that nothing but these trees can grow there.
The densely grown exotic trees are a great fire risk and will be difficult to control as it is a
high amount of fuel for a veld fire.
On the study area there are two very high scalloping sand dunes that differ in age,
succession and species composition. The older (and higher) dune has acid and nutrient
poor soils as a result of the red data plant species Erica glandulosa subspecies fourcadei
have settled.
In the low lying areas that is more even, the common Blombosse (Metalasia muricata) and
Turpentine Boegoes (Agathosma apiculata) occur in very dense stands. These plant
species contains strong smelling volatile oils that could become a great fire risk as these
oils are highly flammable. The areas next to the beach where the younger dunes area
situated is where a number of indigenous plant species are present. The large shrubs are
the stronger pioneer species such as Crysanthemoides monilifera, Passerina species and
Phylica species. Phylica littoralis, a red data plant species, occur on the bare soil patches in
this area. Four new red data plant species have been identified on the study area.
Access Road Alternatives:
The original alignment for Alternative S1 (no longer the preferred alternative) has changed
after a qualified traffic engineer and botanist investigated the study area. The revised
alignment avoids the rare Erica species that occurs on the higher dunes.
This proposed alignment runs through the common Blombosse and Turpentine Boegoes
and this road will serve as a fire break and fire escape road between these highly
flammable plants. The road also excludes the high and steep dunes and the lower lying
areas. Phylica littoralis that occur in the sensitive areas have been avoided in the new
alignment. The very rare grass species, Pentaschistus barbatus subspecies orientalis, was
totally excluded from the new proposed alignment.
The proposed alignment was planned in such a way that the older dunes are excluded
from the alignment as well as all red data plant species and sensitive communities as
prescribed by the OSCAE Permits issued by the Knysna Municipality. The owners of the
study area are well aware of the conservation value of the property and its associated
biodiversity. They have protected and preserved it for almost fifty years and it is their
intention to continue conserving it and therefore the access road will be necessary for
management.
The proposed ultimate access road alignment that was originally marked out by the
botanist and engineers as well as the alternative route through the adjacent reserve will
have a positive impact on the conservation strategies of the local biodiversity. The
botanist stated that both or any one of these proposed road accesses should be allowed
to proceed as it can contribute to the upliftment of the local biodiversity towards the
sustainable development and conservation. This conservation of the local biodiversity can
link up with the local Garden Route Initiatives under the protection of OSCAE.
However, the Goukamma route (Alternative S2) follows an existing track and would
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UITZICHT 216 KNYSNA
drastically reduce environmental impact.
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SECTION C: PUBLIC PARTICIPATION
1.
ADVERTISEMENT AND NOTICE
Publication name
Date published
Site notice position
Date placed
NOTICE OF BASIC ASSESSMENT PROCESS
Thursday, 20 December 2012
Latitude
Longitude
34° 4'36.09"S
22°58'48.74"E
34° 3'55.55"S
23° 0'31.86"E
20 December 2012 – 28 February 2013 (excluding 15 December – 7
January)
Include proof of the placement of the relevant advertisements and notices in Appendix E1.
2.
DETERMINATION OF APPROPRIATE MEASURES
Provide details of the measures taken to include all potential I&APs as required by Regulation 54(2)(e)
and 54(7) of GN R.543.
Key stakeholders (other than organs of state) identified in terms of Regulation 54(2)(b) of GN R.543:
Title, Name and
Surname
Bulelwa Nkwateni
Magda Williams
Georlene Wolmarans
Affiliation/
key
stakeholder status
Council Geo-Science
Heritage Western Cape
ESKOM
SANRAL
Gautrans
Randwater
Transnet
DA Councillor Roads
Ward Councillor
Ward Councillor
Contact details (tel number or e-mail
address)
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
Include proof that the key stakeholder received written notification of the proposed activities as
Appendix E2. This proof may include any of the following:





e-mail delivery reports;
registered mail receipts;
courier waybills;
signed acknowledgements of receipt; and/or
or any other proof as agreed upon by the competent authority.
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3.
ISSUES RAISED BY INTERESTED AND AFFECTED PARTIES
Summary of main issues raised by I&APs
Summary of response from EAP
This only highlights the main issues, a complete Comments and Issues Report is attached
as Appendix E3
The proposed development is situated The proposed development is located on
within a Critical Biodiversity Area and areas that will have the least negative
adjacent to a Protected Area.
impact on the environment. The
development is on a low scale.
The applicability of the National Waste Act As EAPs we are of the opinion that the
proposed development will not require a
Section 21 Water-Use License. DWA must
however still confirm our interpretation of
the matter.
4.
COMMENTS AND RESPONSE REPORT
The practitioner must record all comments received from I&APs and respond to each comment before
the Draft BAR is submitted. The comments and responses must be captured in a comments and
response report as prescribed in the EIA regulations and be attached to the Final BAR as Appendix E3.
5.
AUTHORITY PARTICIPATION
Authorities and organs of state identified as key stakeholders:
Authority/Organ
of State
Contact
Tel No
person (Title,
Name and
Surname)
DWA
Susan Steyn
Municipality
Mr. Mabula
Knysna
DEADP - George Danie
Swanepoel
DEA - Pretoria Danie Smit
Fax
No
e-mail
082 808 2720
044 302 6300
[email protected]
[email protected]
044 805 8600
[email protected]
012 310 3268
[email protected]
Postal
address
Include proof that the Authorities and Organs of State received written notification of the proposed
activities as appendix E4.
In the case of renewable energy projects, Eskom and the SKA Project Office must be included in the list
of Organs of State.
6.
CONSULTATION WITH OTHER STAKEHOLDERS
Note that, for any activities (linear or other) where deviation from the public participation requirements
may be appropriate, the person conducting the public participation process may deviate from the
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requirements of that sub-regulation to the extent and in the manner as may be agreed to by the
competent authority.
Proof of any such agreement must be provided, where applicable. Application for any deviation from
the regulations relating to the public participation process must be submitted prior to the
commencement of the public participation process.
A list of registered I&APs must be included as appendix E5.
Copies of any correspondence and minutes of any meetings held must be included in Appendix E6.
SECTION D: IMPACT ASSESSMENT
The assessment of impacts must adhere to the minimum requirements in the EIA Regulations, 2010,
and should take applicable official guidelines into account. The issues raised by interested and affected
parties should also be addressed in the assessment of impacts.
1.
IMPACTS THAT MAY RESULT FROM THE PLANNING AND DESIGN, CONSTRUCTION,
OPERATIONAL, DECOMMISSIONING AND CLOSURE PHASES AS WELL AS PROPOSED
MANAGEMENT OF IDENTIFIED IMPACTS AND PROPOSED MITIGATION MEASURES
Provide a summary and anticipated significance of the potential direct, indirect and cumulative impacts
that are likely to occur as a result of the planning and design phase, construction phase, operational
phase, decommissioning and closure phase, including impacts relating to the choice of
site/activity/technology alternatives as well as the mitigation measures that may eliminate or reduce the
potential impacts listed. This impact assessment must be applied to all the identified alternatives to the
activities identified in Section A(2) of this report.
1.1 Impacts during the construction phase:
Alternative 1 (preferred alternative) – LAYOUT ALTERNATIVE
The application sites are currently vacant and consist of natural vegetation that has been
disturbed in certain areas.
The Access Road:
Due to the fact that it will be necessary for construction workers, consultants, owners, vehicles
and equipment etc. to reach the development property, it will be necessary to first
construct/formalise the access road.
At this stage the preferred alternative is the proposed access road that traverses the
Goukamma Nature Reserve. The access road will mainly follow the alignment of an existing
internal road and it will only be extended towards the east to provide access to the two
private houses.
It will be necessary to discuss the upgradings required to the existing road through the Nature
Reserve with the management of the nature reserve and the parties responsible for the
upgradings to the road and maintenance of the road during the construction phase must
also be determined.
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The area close to the access point (where the wetland/marshy area is present) must receive
special attention and the mitigation measures to be applied to protect the integrity of the
watercourse must be determined and specified.
Photographs must be taken of the access road prior to the construction phase (for record
keeping purposes) and damage to the road must be prepared by the contractors/owners
during/after the construction phase.
The Development of the Houses:
For purpose of the development of the housing units and the associated outbuildings and
infrastructure, only the areas to be developed will be disturbed. The specific development
areas will be earmarked (on site) prior to the construction phase.
Indigenous plant species that can be transplanted and temporarily stored (i.e. in a
temporary in-situ nursery) must be identified prior to the construction phase by a suitably
qualified specialist. These plant species must be re-used for rehabilitation purposes after the
construction works have been completed.
In order to prevent the disturbance of the surrounding area (areas not earmarked for
development) a conservation fence/ line will be erected around the development cluster.
No disturbance will be allowed to occur beyond the conservation line. It is proposed that fire
breaks be implemented along the conservation line and this fire break must also be
maintained during the operational phase. Cape Nature offered to assist with the
establishment and maintenance of the fire breaks and it is therefore recommended that
Cape Nature also be involved in the determination of the conservation line prior to the
construction phase.
Note: No mitigation measures will be supplied for the positive impacts, because it is not
necessary to mitigate positive impacts. Where possible mitigation measures to prevent or
restrict negative impacts will be supplied when the negative impacts are listed. These
mitigation measures will be incorporated as part of the EMP. Refer to Appendix H.
Direct Impacts: Impact directly caused by the development.
Indirect Impacts:
identifiable
Impacts caused by development impacts – not directly noticeable or
Activity
Impact summary
Significance
Alternative A1 and S2 (preferred alternative)
The
Direct impacts (Construction
development Phase):
of 2 houses
(one on each Positive:
portion),
 Prevent
informal
associated
settlement from taking
outbuildings
place on the site;
and an
 Prevent Illegal dumping
access road.
from taking place
 Improved
environmental
management
and
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Proposed mitigation
 Construction site plan to
be drawn up clearly
indicating
the
construction site and
construction areas.
 No
unnecessary
vegetation clearance.
 The construction of the
new access road to be
completed prior to the
construction of the
dwelling units
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Activity
Impact summary
Significance
monitoring
 Eradication of invasive
species
Negative:
 Visual
impacts
associated
with
construction
 Short term impacts on
the Sense of place
 Availability
of
Municipal services
 If municipal services
are
the
preferred
option, the excavations
for the pipelines will
have
short
term
impacts on the visual
quality of the area and
short and long term
impacts on the natural
vegetation and in some
areas on the dune
stability
(not
the
preferred option)
 Noise Pollution caused
by
construction
equipment
and
construction workers
 Damage to local access
roads by construction
machinery and vehicles
 Accessibility of the
sites
for
the
construction of the
houses
 Erosion
 Soil contamination
 Dust
during
construction phase
 Construction rubble
 Waste management
 Safety and security
risks
 Fire risks due to the
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Proposed mitigation
 The new access road will
be the only access to the
study area
 Fence (with a temporary
conservation fence) the
beach area in order to
prevent access from the
beach
and
security
problems on the beach
 No fires will be allowed
for cooking and heating
purposes
 Appoint a 24 hour
security guard to ensure
that nobody resides o
the study area during the
construction phase and
for the monitoring of the
security on the beach
and along the access
road
 Install on-site services
and such services must
be
environmental
friendly and approved/
supported
by
the
relevant authorities
 In area that are not
accessible
to
construction
vehicles
and equipment, manual
measures
must
be
implanted to prevent
damage
to
the
environment. Such areas
must be identified by the
ECO prior to the
commencement
with
construction
 Erect
conservation
fence/
delineate
a
conservation line prior to
the construction phase
in order to protect the
surrounding
natural
areas
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Activity
Impact summary
Significance
use of fire for cooking
and heating purposes
 Removal of indigenous
vegetation
 Snaring and hunting of
fauna species
 Development in a
sensitive area
 Possible damage to the
coastline
 Security
risks
associated
with
that secretly sleeps on
the beach and in the
densely
vegetated
areas
Proposed mitigation
 All disturbed areas to be
re-vegetated as soon as
possible
 Dust
suppression
methods to be employed
during the dry season or
under
circumstances
with extreme dust.
 Temporary
chemical
toilets to be provided for
 Determine storage areas
for equipment/ site
camp prior to the
construction phase. The
proposed construction
camp must be situated in
close proximity of the
construction access and
it must preferably be
screened in order to
reduce the construction
related visual impacts
 During the site clearing
exercises exotic invaders
in close proximity must
be removed
Indirect impacts:
Positive:
 Job creation
Cumulative impacts:
 Additional
vehicular
and pedestrian access
roads
due
to
construction activities
Direct impacts (Operational
Phase):
Positive impacts:
 Prevent
informal
place on the site;
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 Waste
management
procedures
to
be
addressed and resolved
prior to the construction
phase
 Waste
management
agreements to be in
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Activity
Impact summary
Significance
from taking place
 Improve environmental
management
and
monitoring
 Fire management and
prevention
 Eradication of exotic
invaders and weeds
 Improved surveillance
and security
 Possible eco-tourism
linkage
between
nature reserve and the
other natural areas
 Emergency access
 Increased bio-diversity
 Creation of habitats
Negative:
 Visual impacts
 Impacts on the Sense
of Place
sensitive
area
of
national
and
international
importance
 Risks of the applicant
developing a larger
development that will
not be for private use
 Risks
of
the
formalisation of the
proposed local road on
the existing servitude
 No waste management
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Proposed mitigation
place
 Architect to do detailed
designs with elevations
in order to illustrate
visual
impacts
of
facades, finishing and
general appearance
 Architectural
presentation to the local
authority to include
visual impact assessment
 The
environmental
features/ assets on the
areas
identified
for
transformation
must
preferably be preserved
and the development
(including the access
road must be designed)
to avoid such features.
The final layout to be
presented
to
the
involved local authority
must supply proof that
such features/ assets
were conserved/ taken
into consideration.
 No thatch roofs
 The access road will at all
times remain a private
road.
The
owner/
applicant to compile a
list of people that will be
allowed to utilize the
access road. If necessary
a removable obstruction
(i.e. removable bollard/
boom/gate etc) should
be placed on the private
road and this obstruction
must prevent public
access to the road. Only
the selected parties will
be furnished with keys to
the removable element
to be placed on the road.
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Activity
Impact summary
Significance
Indirect impacts:
Positive:
 Job creation
 Eco-tourism potential
Negative:
 Improved access to the
area from the beach
 Impact of lighting on
the evening sky
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Proposed mitigation
 On-going rehabilitation
and eradication of exotic
invasives. Rehabilitation
plan with maintenance
intervals to be submitted
to the local authority
and DEA for approval
prior to construction
re-vegetated.
 Public-private
partnership negotiations
in order to ensure the
long term protection and
management of the
areas
 The establishment of a
conservancy/ residents
forum
with
the
Goukamma
Nature
reserve as member in
order to ensure the long
term conservation and
protection of the area
 Operational phase ECO
reports to be submitted
to DEA on a yearly basis
in order to report back
on the progress with the
environmental
rehabilitation and the
eradication of invasive
species
 The access points to
and from the beach
must
also
be
monitored/ designed to
restrict
uncontrolled
access to the natural
areas. Such measures
must also form part of
the presentation to be
made by the architect
at the local authority
after the finalisation of
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Activity
Impact summary
Significance
Cumulative impacts:
 Sense of place
Direct
impacts
(Decommissioning / Closure
Phase):
Positive:
 Prevent
informal
place on the site;
from taking place
Negative:
 High visibility
 Sense of place
 Noise Pollution
 Erosion
 Soil contamination
 Dust
 Waste management
 Safety and security risk
 Removal of indigenous
vegetation
natural protected area
Proposed mitigation
the detailed layout for
the facility
 Use exterior lighting
that
will
not
compromise the dark
sky
currently
experienced in that
area (especially if one
takes the qualities of
the Goukamma nature
reserve
into
consideration)
 If well planned and
managed the proposed
development can assist
with the enhancement
of the Sense of Place
 No
unnecessary
vegetation clearance.
re-vegetated as soon as
possible.
 Dust
suppression
methods to be employed
during the dry season or
under
circumstances
with extreme dust.
 Toilet facilities to be
provided
to
casual
labourers
 No development close to
surface water allowed.
Indirect impacts:
Positive:
 Job creation
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Activity
Impact summary
Significance Proposed mitigation
Cumulative impacts:
 Noise
Alternative A1 and S1
The anticipated impact for this alternative will be similar that the impacts listed for
Alternative A1 & S2.
The only difference lies in the potential impacts associated with the construction of the
two access roads. Access road S1 will have a larger impact during the construction phase
(short term), because it will require the permanent removal of some sensitive vegetation
and the stability of dune ecological system will be negatively affected.
Access road S2 will mainly follow an existing road on the nature reserve and therefore less
vegetation will have to be removed. The vegetation adjacent to the existing road is also
subject to edge effects in will in general not be as sensitive as areas without any major
human intervention.
No-go option
The long term impacts of the no-go option, both direct and indirect, will be higher than the
implementation of the proposed alternatives (only if well planned and managed).
A complete impact assessment in terms of Regulation 22(2)(i) of GN R.543 must be included as
Appendix F.
2.
ENVIRONMENTAL IMPACT STATEMENT
Taking the assessment of potential impacts into account, please provide an environmental impact
statement that summarises the impact that the proposed activity and its alternatives may have on the
environment after the management and mitigation of impacts have been taken into account, with
specific reference to types of impact, duration of impacts, likelihood of potential impacts actually
occurring and the significance of impacts.
Alternative A1 and S2 (preferred alternative)
Two similar alternatives were taken into consideration for this development. The only
difference between the two alternatives is the access road towards the two properties,
which are situated immediately adjacent to each other.
Alternative A1 represents the specific facility applied for, which includes the two private
dwellings with their associated outbuildings and infrastructure and Alternative S2
represents the proposed access road through the Goukamma Nature Reserve.
The most significant impacts associated with this alternative are:
- The ecological impacts associated with development within the pre-determined
ecological footprint area. The short term ecological impact of this option is regarded as
less severe than the ecological impact of the proposed access road through Portions 39,
40, 41, 49 and 50 (Alternative S2).
- The visual impacts of the dwellings and their associated structures and infrastructure;
and
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-
The availability and installation of services.
The proposed localities for the two houses and the proposed alignment of the access road
(Alternative S1) have been identified by means of two walkabout exercises.5 During such
walkabout exercises the GPS waypoints for the road alignments and the proposed position
of the two dwellings were identified and indicated on plans. The purpose of this walkabout
was to identify sensitive ecological and other features that should be avoided and to
amend the conceptual road alignment and position for the houses to avoid such sensitive
features.
During the second walkabout exercise, which was undertaken by the fauna and flora
specialist in 2013, the specialist re-evaluated the access road formerly determined (mainly
from an ecological point of view) and confirmed that the access road as identified is still
regarded as a workable alternative. The updated fauna and flora report attached as
Appendix D supplies a detailed description of the status quo of the study area and its
surroundings and the proposed road alignment.
Alignment Alternative S1 was Initially regarded as the preferred access road alternative
and the reasons for this original viewpoint is set out in the introduction and background
included at the beginning of this BAR.
Alternative S2 is now regarded as the preferred access road alignment alternative and the
reasons for this change are also discussed in this report.
The proposal is that an ecological footprint of approximately 3 000m² (less than 2% of the
total size of the farm portion) be approved for each dwelling unit development and the
footprints must be located in the vicinity of the GPS positions already determined.
During the design of the detailed layout of the facility (i.e. position of houses, outbuildings,
paved areas, boardwalks towards the beach etc.), the specific site conditions (i.e.
ecological features and species, slope, views, visibility etc.) will be regarded as the form
giving element and the layout will be adapted (where possible) to accommodate such
features. The detailed layout of the facility will then be submitted to the local authority for
approval.
The design of all structures will be done in a way to minimize energy consumption for
heating, cooling and lighting. Maximum use will be made of renewable energy sources and
electricity usage will be minimized. As a minimum, solar panels and solar geysers will be
installed, but if feasible, solar energy will be augmented by mini wind turbines. All
equipment will be installed where it will have a minimum visual impact.
It is also proposed that the appointed architect do elevations of the two dwelling houses
and their associated structures and infrastructure (especially impacts to be experienced
from sensitive view sheds such as the beach and the nature reserve) and that the visual
impacts of the facility (if any) be illustrated and where possible mitigated.
DWA and Cape Nature were present during the first walkabout exercise and the involved DWA official assisted with
the determination of the waypoints for the proposed access road from Brenton-on-Sea.
5
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From former experience it is recommended that the roofs of the dwellings and associated
structures be a charcoal colour and that the colour of the walls blend-in with the natural
mosaic of colours of the surrounding natural environment. The colours grey, charcoal and
brown are regarded as the most suitable for a development that will be viewed from a
distance.
The designer must also avoid the proposal of large monotonous structures that will appear
out of context. The facades must rather be broken-up and the development must
preferable be scattered across the proposed development footprint area.
The owners/ applicants are fully aware of the fact that the study area is regarded as being
situated within an area of special conservation value and their intention is to protect and
preserve the natural vegetation and characteristics of the study area as far as possible.
Equipment for renewable energy generation will be designed according to the most recent
greenhouse technology and according to the SANS requirements. Renewable energy
sources will be connected to battery back-up and used primarily for water heating, lights
and small appliances and will be connected to a proposed underground cable reticulation
system from the main energy source.
Even though municipal water and sewage will be available (most probably from
Buffels aai , it ill e e essa y to i stall le gthy pipeli es a d pu p statio s ith
pollution risks along the sewer pipeline and at the pump station) for the achievement of
such municipal connections.
As EAP we recommend that the owners rather install environmental friendly on-site
services, because the environmental impacts for the implementation of such services will
be lower that the anticipated impacts associated with the installation of the pipelines
across the sensitive sand dunes. The proposed development is very small and we are
convinced that it will be possible to provide the development with good quality domestic
water (to be abstracted from a borehole/ boreholes and through the on-site collection of
rain water in rain water tanks) and there are a number of on-site sanitation systems that
are environmental friendly and supported by DWA. The applicants will install a system that
is approved/ supported by DWA and the involved local authority.
Due to the access restrictions of the development, waste management can be regarded as
a problem. The local authority could indicate that it will be difficult to reach the properties
with waste removal trucks and request that the domestic waste be placed at a more
accessible collection point. The waste collection detail must be discussed with the involved
local authority and such detail must be incorporated in a services agreement between the
owners and the local authority. If no waste collection services are available from the local
authority, the owners must appoint a waste removal contractor and the details of such
contractor must be supplied to DEA and the involved local authority prior to the
commencement of construction.
The area is considered to be in a pristine condition with some areas with severe invasion
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of exotic trees, especially on the front dunes. The invader species have changed the soil
characteristics and conditions in such a way that nothing but these trees can grow there.
The densely grown exotic trees are a great fire risk and fires will be difficult to control as
some of the invaders contain high amount of flammable fuel. The Ecologist and the
Engineer provided certain mitigation measures that will reduce the impacts on the biodiversity. The aim (during and after the development) will rather be to eradicate the exotic
invaders and weeds and to assist with the creation of habitats and the increase of the
biodiversity on and around the study area.
The applicants are also against the construction of a formal local road (within the
servitude) that will link Brenton-on-“ea ith Buffels aai , e ause the isual a d
ecological impacts of such a road eventually destroy the ecological and aesthetical value
and potential of the natural area. The applicants therefore indicated that they will form
part and parcel of a campaign against the link road if such a road ever becomes an option.
The owners of the study area are well aware of the conservation value of the property and
its associated biodiversity. They have protected and preserved it for almost fifty years and
it is their intention to continue conserving it and therefore the access road will be
necessary for management.
This conservation of the local biodiversity can link up with the local Garden Route
Initiatives under the protection of OSCAE. The impact on the environment via human
impacts is considered insignificant as the road will strictly be used by the owners on adhoc basis.
Access road S2 (the preferred alternative) will be a single road that will link up with the
existing access road via the Goukamma Nature Reserve and is considered as the most
suitable alignment from an environmental management point of view as it will have a
positive impact on the conservation strategies of the local biodiversity.
The proposed access road is suggested to run through the Goukamma Nature Reserve.
This route mainly follows an existing track (which stretches from an existing access on the
Buffelsbaai Road) through the Goukamma Nature Reserve. For this proposed alternative
two options are considered:
 Option1: Utilisation of the existing management track up to +- 100m from
boundary of Portion 50. This route includes a number of sections that are not
comfortably trafficable by two wheel drive vehicles (regarded as the short term
option); and
 Option 2: The diversion of the existing track to achieve a superior route from a
road design point of view and rehabilitation of the existing track (regarded as the
longer term option )
Some of the other impacts that may be experienced by this development are related to
the socio-economic impacts during the operational phase related to visual and sense of
place. However, this can be mitigated through architectural designs to ensure the
residences are aesthetically pleasing to fit into the natural environment.
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After careful mitigation measures and recommendations on the potential impacts, the
proposed development should not pose such a significant impact on the environment. A
development of such a small scale on the proposed study area should not detrimentally
affect the environment in such a way that it should not be approved.
Alternative A1 and S1 (Alternative 2)
The impacts of Alternative A1 & S1 are regarded as similar when one considers the
proposed two dwelling houses and their associated structures and infrastructure.
The impacts (especially the short term impacts) of the alternative access road (Alternative
S1) across portions 39, 40 and 41 are much higher than the preferred alternative. This
alignment was planned in such a way that the older dunes are excluded from the
alignment as well as all red data plant species and sensitive communities as prescribed by
the OSCAE Permits issued by the Knysna Municipality.
The road excludes the high and steep dunes and the lower lying areas. Phylica littoralis
that occur in the sensitive areas have been avoided in the new alignment. The very rare
grass species, Pentaschistus barbatus subspecies orientalis, was totally excluded from the
new proposed alignment. The proposed ultimate access road alignment that was originally
marked out by the botanist and engineers.
Due to the fact that the access road is via a registered servitude and solely for private use
by the owners of Portion 49 and 50 and not for the public, it is regarded to have a low
impact. The impact on the environment via human impacts is considered insignificant as
the road will strictly be used by the owners on ad-hoc basis. The Ecologist motivated that
the access road will be environmentally friendly and enhances conservation. Some of the
other impacts that may be experienced by this development are related to the socioeconomic impacts during the operational phase related to visual and sense of place.
However, this can be mitigated through architectural designs to ensure the residences are
aesthetically pleasing to fit into the natural environment.
Alternative C
No-go alternative (compulsory)
If the study area remains in its current state the alien invasive plant species present on
and around the study area will continue to spread and invade the sensitive natural areas,
which currently have high ecological and/or conservation potential.
The alien invasive plant species poses high fire risks and it also poses a risk to the adjacent
protected area and with no human intervention, this occurrence can eventually disturb/
destroy the indigenous dune vegetation. The proposed development will initiate an alien
invasive management programme to control / reduce these alien plant species and it will
also assist with the establishment of a fire breaks and a fire management plan.
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Based on the above, the no-go alternative is not regarded as being the desired option. The
development is of such small scale that the impacts of the construction phase will
outweigh the anticipated long term negative impacts of the no-go option.
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SECTION E. RECOMMENDATION OF PRACTITIONER
Is the information contained in this report and the documentation attached hereto
sufficient to make a decision in respect of the activity applied for (in the view of the
environmental assessment practitioner)?
YES
X
NO
If “NO”, indicate the aspects that should be assessed further as part of a Scoping and EIA process
before a decision can be made (list the aspects that require further assessment).
If “YES”, please list any recommended conditions, including mitigation measures that should be
considered for inclusion in any authorisation that may be granted by the competent authority in respect
of the application.
As a result of the above mentioned information, Bokamoso request that the above
development be approved subject to the following conditions:
 All mitigation measures and recommendations as part of the attached Botanical Survey
must be adhered to;
 The EMP must be adhered to at all times and the appointed ECO must ensure the
developer comply with the EMP;
 A comprehensive rehabilitation plan, which will address and mitigate the anticipated
short term construction related impacts and the long term impacts associated with the
exotic invaders must be compiled and submitted to DEA and the local authority for
approval;
 Confirmation of the availability of services (especially water) must be supplied to DEA
prior to the commencement of construction;
 The services agreement between the applicants and the local authority must be
supplied to DEA prior to construction;
 Proof of positive feedback from DWA regarding the proposed on-site sanitation system;
 Confirmation of the waste management arrangements (whether the local authority will
assist with the waste management, where waste will be collected and if the local
authority cannot assist with waste management, the name of the waste contractor that
will be used during the construction and operational phase must be supplied);
 The detailed layout plan and elevations, which illustrate and mitigate the anticipated
visual impact must be submitted to the involved local authority for approval prior to the
commencement with construction;
 After the finalisation of the layout plan, a suitably qualified heritage consultant must be
appointed to determine the cultural and historical impact of the proposed layout on the
environment and on possible cultural and historical features on the site. At this stage
we are of the opinion that there are no cultural and historical features on the study
area, but this must however be confirmed at layout plan stage;
 Detail regarding the finishing proposed for the facility must also be submitted to the
involved local authority for approval prior to construction. The specifications must
amongst others address the paint colours, types of finishing materials, roof colours and
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finishings etc.;
 A detailed layout plan of the proposed and approved access road alternative
(including detailed vertical and horizontal alignment) must be submitted to DEA for
approval; and
 Proof of the new OSCAE permit as issued by the involved local authority must be
submitted to DEA prior to the commencement of construction.
YES
X
Is an EMPr attached?
NO
The EMPr must be attached as Appendix G.
The details of the EAP who compiled the BAR and the expertise of the EAP to perform the Basic
Assessment process must be included as Appendix H.
If any specialist reports were used during the compilation of this BAR, please attach the declaration of
interest for each specialist in Appendix I.
Any other information relevant to this application and not previously included must be attached in
Appendix J.
Lizelle Gregory
________________________________________
NAME OF EAP
________________________________________
SIGNATURE OF EAP
December 2013
_________________
DATE
76
UITZICHT 216 KNYSNA
SECTION F: APPENDIXES
The following appendixes must be attached:
Appendix A: Maps
Appendix B: Photographs
Appendix C: Facility illustration(s)
Appendix D: Specialist reports (including terms of reference)
Appendix E: Public Participation
Appendix F: Impact Assessment
Appendix G: Environmental Management Programme (EMPr)
Appendix H: Details of EAP and expertise
Appendix I: Specialist’s declaration of interest
Appendix J: Additional Information
December 2013
77

Final Draft Report - South African Heritage Resources Agency

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