sappi saiccor mill: proposed comrie dam expansion

SAPPI SAICCOR MILL: PROPOSED COMRIE
DAM EXPANSION
Sappi Southern Africa (Pty) Ltd
Stakeholder Engagement Report
2015/10/27
Quality Management
Issue/revision
Issue 1
Revision 1
Revision 2
Remarks
Draft SER
Final SER
Date
July 2015
October 2015
Prepared by
Bathabile Msomi
Bathabile Msomi
Carla Elliott
Carla Elliott
Hilary Konigkramer
Hilary Konigkramer
Project number
46648
46648
Report number
1
1
File reference
46648_Comrie
Dam
Expansion_Draft SER
46648_Comrie
Dam
Expansion-Final SER
Signature
Checked by
Signature
Authorised by
Signature
Project number: 46648
Dated: 2015/10/27
Revised: Klicka här för att ange text.
2
Revision 3
Sappi Saiccor Mill: Proposed Comrie Dam Expansion
Stakeholder Engagement Report
2015/10/27
Client
Sappi Southern Africa Limited
Sappi Saiccor Mill
PO Box 62
Umkomaas
4170
Consultant
WSP Environmental (Pty) Ltd
Block A, 1 on Langford
Langford Road, Westville
Durban
3629
South Africa
Tel: +27 31 240 8860
Fax: +27 31 240 8801
www.wspenvironmental.co.za
Registered Address
WSP Environmental (Pty) Ltd
1995/008790/07
WSP House, Bryanston Place, 199 Bryanston Drive,
Bryanston, 2191, South Africa
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Table of Contents
1. Introduction ................................................................................. 5
1.1 Purpose of Report ..................................................................... 5
1.2 Objective of the Stakeholder Engagement Process .................. 5
2.
2.1
2.2
2.3
2.4
Stakeholder Notification .............................................................. 5
Advertising ................................................................................ 5
Public Notices ........................................................................... 9
Written Notices ........................................................................ 11
Stakeholder Database ............................................................. 18
3.
3.1
3.2
3.3
Draft BAR Issues Trail ............................................................... 19
Draft Basic Assessment Report .............................................. 28
Comment and Response Report ............................................. 28
Final Basic Assessment Report .............................................. 28
Project number: 46648
Dated: 2015/10/27
Revised: Klicka här för att ange text.
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1.
1.1
Introduction
Purpose of Report
Sappi Southern Africa Ltd (Sappi) proposes to expand Comrie Dam by raising the dam wall height by a total of
4m. Comrie Dam is controlled and owned by Sappi and was constructed in 1978 to augment the supply of the
uMkomazi River into the Sappi Saiccor Mill (Mill). Sappi proposes to increase the capacity of the dam to ensure
water security during dry seasons for their production processes at the Mill.
The stakeholder engagement process is being undertaken in accordance with the 2014 Environmental Impact
Assessment (EIA) Regulations (GN: R982) promulgated under the National Environmental Management Act
(No. 107 of 1998) (NEMA). The process aims to ensure that the widest range of potential stakeholders are
identified and provided with an opportunity to review the details of the proposed project and to submit any issues and concerns.
1.2
Objective of the Stakeholder Engagement Process
In order to ensure compliance with the applicable national legislation, WSP undertook the stakeholder consultation process in a diligent manner at the outset of the Basic Assessment (BA) Process. The NEMA requires that
an inclusive, transparent process of stakeholder engagement. The objectives of the stakeholder engagement
process were as follows:
■
To ensure an open and transparent BA and consultation process
■
To identify and inform stakeholders of the proposed project and associated environmental authorisation
process
■
Establish an on-going line of communication between the stakeholder and the project team
■
Provide an opportunity for stakeholders to raise all issues, concerns and questions and ensure that these
are considered in the environmental authorisation process for the project
■
Ensure that stakeholders have an opportunity to make a meaningful contribution towards decision making
by all commenting authorities as well as the lead authority, and
■
Compile an issues trail of all issues, concerns and questions raised during the stakeholder engagement
process.
2.
2.1
Stakeholder Notification
Advertising
The NEMA EIA Regulations 2014 require that an advertisement be placed in a local newspaper and a national
newspaper as the proposed activity extends beyond the boundaries of the district municipality. An English advert was published in the Mercury (Figure 1) and East Griqualand Fever (Figure 2) on 29 May 2015. A Zulu
advert (Figure 3) was published in the Isolezwe newspaper on 29 May 2015. The advertisements formally announced the commencement of the EIA, gave notice in terms of the EIA Regulations for the proposed project
and requested stakeholders to register their interest with the Environmental Assessment Practitioner (EAP),
WSP Environmental (Pty) Ltd. (WSP).
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Figure 1: Proof of English advert placement - Mercury Newspaper
Project number: 46648
Dated: 2015/10/27
Revised: Klicka här för att ange text.
6
Figure 2: Proof of English advert placement – East Griqualand Fever Newspaper
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Figure 3: Proof of isiZulu advert placement - Isolezwe Newspaper
Project number: 46648
Dated: 2015/10/27
Revised: Klicka här för att ange text.
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2.2
Public Notices
The NEMA EIA Regulations 2014 require that site notices be fixed at places conspicuous to the public at the
boundary or on the fence of the site where the activity (to which the application relates) is to be undertaken, as
well as at any alternative sites. Posters, conforming to the size specifications of the EIA Regulations, were
placed in English and isiZulu outside the Contractors Village adjacent the Comrie Dam and (Figures 4 and 5)
as well as on the Ingwe Local Municipality Notice Board, Creighton Post Office and Library, and Donnybrook
Spar. These posters (Figures 5 - 8) were placed on 15 May 2015.
Figure 4: Site notice location map
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Figure 5: Public notice placed outside entrance
gate to Compound area/ Contractors Village.
Figure 6: Public notices placed outside Ingwe
Local Municipality.
Figure 8: Public notice Place at Ingwe Local
Municipality notice boards
Figure 7: Public notice placed on
Donnybrook Spar glass window
Project number: 46648
Dated: 2015/10/27
Revised: Klicka här för att ange text.
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2.3
Written Notices
Section 41 of the GN. R982 of the NEMA EIA Regulations states that written notices must be given to the
following stakeholders (Table 1):
Table 1: Interested and Affected Parties
(i)the owner or person in control of that land if the
applicant is not the owner or person in control of the
land
Not applicable – Sappi is the land owner.
(ii) the occupiers of the site where the activity is
or is to be undertaken or to any alternative site
where the activity is to be undertaken
Five Star Contractors (Scott Nicholson and Mthembu)
were notified via email (Figure 12) and telephonic
communication. Site notices were also placed outside
the entrance gate of the compound area.
(iii) owners and occupiers of land adjacent to the site
where the activity is or is to be undertaken or to
any alternative site where the activity is to be
undertaken
Charles Anderson and Clive Mingay were notified via
email (Figure 11 & 12), Charles Anderson is situated
downstream from dam and Clive Mingay’s land is
situated on the headland area – proposed Class A
road will be located on a portion of his land. .
(iv) the municipal councillor of the ward in which
the site or alternative site is situated and any
organisation
of ratepayers that represent the
community in the area
The Municipal Councillor Mr Ngubo, was notified via
email and handed a written notice.
(v)the municipality which has jurisdiction in the area
Ingwe Municipality were notified via email and handed
written notice (Figure 10 & 13).
(vi) any organ of state having
respect of any aspect of the activity
jurisdiction
in
The Harry Gwala District Municipality and Department
of Water and Sanitation (DWS) were notified via email
(Error! Reference source not found. 10).
(vii) any other party as required by the competent
authority.
Additional stakeholders in the Creighton area were
notified by email (Error! Reference source not found.),
namely:
■
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Provincial authorities
Figure 9: Written notice handed to surrounding landowners and Local Municipal officials
Project number: 46648
Dated: 2015/10/27
Revised: Klicka här för att ange text.
12
Figure 10: Written notice distributed to stakeholders via email
13
Figure 11: Written notice distributed to Mr Anderson via email
Project number: 46648
Dated: 2015/10/27
Revised: Klicka här för att ange text.
14
Figure 12: Written notice distributed to Mr Mingay via email
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Figure 13: Written notice distributed via email to contractor on site
Project number: 46648
Dated: 2015/10/27
Revised: Klicka här för att ange text.
16
Figure 14: Proof of receipt of written notification by Ingwe Municipality representatives
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2.4
Stakeholder Database
Stakeholders with an interest in the project were identified at the project outset, and continue to be identified throughout
the environmental process. Specific attention was paid to local and district government departments. The stakeholder
database is maintained throughout the BA process. The database (Table 2) contains the details of known
stakeholders. It is noted that to date no persons registered any interest in the project as a result of the notification
process (i.e. through distribution of written notices, and posters, and the publication of advertisements).
Table 2: Stakeholder Database
NAME
ORGANISATION
Provincial Authority Department
Department of Agriculture, Forestry and Fisheries (DAFF)
Ayanda Mnyungula
Department of Economic Development, Tourism and
Environmental Affairs (EDTEA)
Mavis Padayachee
DEDTEA (Harry Gwala District)
Ndumiso Masuku
Department of Water and Sanitation
Ivor Hoareau
Department of Water and Sanitation
Sbusiso Mathonsi
Amafa
Weziwe Tshabalala
Ezemvelo Wildlife KZN
Dominic Wieners
Local Authority Department
Harry Gwala District Municipality
Nandi Dlamini
Harry Gwala District Municipality
Mr Biyase
Harry Gwala District Municipality
Mr Ngcobo
Ingwe Municipality
Mr Jili
Ingwe Municipality
Nkosiyezwe Vezi
Ingwe Municipality
Zwelethu Dlamini
Ingwe Municipality
Joseph Nyide
Ingwe Municipality
Simon Skipa Ngubo
Creighton Library
Sihle Bekwa
Surrounding Landusers
Compound / Contractor’s Village Nduna
Mr Mthembu
Five Star (Contractors)
Scott Nicholson
Landowner
Clive Mingay
Landowner
Charles Anderson/ Phillip Anderson
Project number: 46648
Dated: 2015/10/27
Revised: Klicka här för att ange text.
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3.
Draft BAR Issues Trail
Comments were received from the following stakeholders (Figures 12- 14)
Department of Agriculture, Forestry and Fisheries (DAFF)
Charles Anderson
Amafa
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Figure 12: Comments received from DAFF (02 September 2015)
Project number: 46648
Dated: 2015/10/27
Revised: Klicka här för att ange text.
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Figure 13 Comments received from Charles Anderson (18 September 2015)
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Project number: 46648
Dated: 2015/10/27
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23
Figure 14: Comments received from Amafa (08 October 2015)
Project number: 46648
Dated: 2015/10/27
Revised: Klicka här för att ange text.
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Comments received in response to the draft BAR have been addressed below in the issues trail (Table 3). The Issues Trail outlines the comments received from the
stakeholders and responses provided by the applicant and EAP for consideration by the lead authority DEDTEA.
Table 3: Comment and Response Table
No.
Issue or Concern
■
Department of Agriculture, Forestry and Fisheries
■
Received via email: 02 September 2015
1.
Response
The Department of Agriculture, Forestry and Fisheries (DAFF) appreciates the
opportunity given to review and comment on the Draft Basic Assessment Report
(DBAR) for the above mentioned project.
Comment noted.
With regards to the document received on the 25/08/21015 (dated 25/08/2015),
the proposed site consists of plantations (Pine and Eucalyptus) as well a stand
of trees which consist of alien poplar species with the presence of few
indigenous trees such as Cussonia spicata, salix cf. muconata and Buddleja
salvifolia. Therefore, DAFF has no objection towards the proposed dam as there
are no natural forests or protected tree species that will be impacted upon in
terms of section 7 and section 15 of the National Forests Act 84 of 1998.
This letter does not exempt you from considering other environmental legislation.
Should any further information be required, please do not hesitate to contact this
office.
■
Charles Anderson
■
Received via email: 18 September 2015
2.
What will the minimum flow be while the dam is filling up?
Minimum flow will always be above the minimum flow rate
(ecological reserve) stipulated for each month in the reserve
determination. This will include the construction period.
3.
How will the water be released for Saiccor? i.e flood or steady flow over a few
months?
When Sappi Saiccor requires the water it will be released
continuously until the volume required is met. However, the flow
will not be allowed to exceed maximum limits set in the reserve
which will minimise the risk of unexpected flood events.
4.
After the dam has been emptied, will some flow remain while refilling?
At no stage will the dam be completely emptied. Sappi is
required to allow flow entering the dam to leave the dam. The
Ecological Reserve Determination (Appendix D2) concluded
that the maintenance low flow for the system is 0.345m3/s (i.e.
August). It is recommended that the release discharge from the
dam be maintained at a rate of 0.455m3/s which is calculated
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from the average Maintenance Low Flows for the dry season
(i.e. April through September).
During drought conditions (i.e. low inflow rates), it is
recommended in the Water Use License Motivation Report
that the release discharge from the dam be maintained at
a rate of 0.018m3/s which is calculated from the average
Drought Low Flows for the dry season (i.e. April through
September).
The amount of water in the dam and flowing through the
dam downstream is dependent on the natural flow of the
system. During periods of drought where inflow is limited,
motivation will need to be placed with the DWS for
changing discharge rates from average Maintenance Low
Flows to average Drought Low Flows.
■
AMAFA
■
Received 08 October 2015
5.
A study of the Basic Assessment Report submitted in support of this application
shows that there is presence of small patches of natural / indigenous vegetation
between plantations and cultivated land. While we are aware that eThembeni
conducted a foot survey on 15 May 2015, the developer should note that these
patches could be associated with unmarked graves. The developer should take
cognisance of the possibility of encountering sub-surface finds and informal or
unmarked graves during site clearance and earth-moving activities. For this
reason, the developer should ensure that the construction team is on the lookout for any possible stone-age and iron age resources during the entire process
of construction of the dam.
Noted.
6.
Amafa, the KwaZulu Natal Heritage Authority has considered the reasons put
forward by eThembeni and has no objection to the development provided that
Amafa is provided with evidence of community consultative process around
issues of graves / burial ground in the area to be inundated before any
construction activities commence.
Sappi will work together with the ward councillor to identify and
consult potential relevant community leaders.
7.
You are also required to adhere to the below-mentioned standard conditions:
Conditions are noted and will be adhered to avoid heritage
impacts.
■
1. Amafa should be contacted if any heritage objects are identified during
earthmoving activities and all development should cease until further notice.
■
2. No structures older than sixty years or parts thereof are allowed to be
Project number: 46648
Dated: 2015/10/27
Revised: Klicka här för att ange text.
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demolished altered or extended without a permit from Amafa.
■
3. No activities are allowed within 50m of a site, which contains rock art.
4. Sources of all natural materials (including topsoil, sands, natural gravels,
crushed stone, asphalt, etc.) must be obtained in a sustainable manner and in
compliance with the heritage legislation.
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3.1
Draft Basic Assessment Report
All registered stakeholders were notified of the availability of the draft BAR and provided with a 30 day comment period.
Stakeholders were provided with EAP contact details to request a copy of the report (electronically only) and informed
of a copy being available through the means outlined below:
A hardcopy of the draft BAR was made available for viewing at the Creighton Public Library.
Electronic copies of the report were available at:
http://www.wspgroup.com/en/WSP-Africa/What-we-do/Services/All-Services-A-Z/Technical-Reports/
In addition, hard copies of the report were provided to the key stakeholders / relevant regulatory authorities.
3.2
Comment and Response Report
The comments and response report (Table 3) reflects the key issues and concerns of stakeholders following
distribution of the draft BAR, as well as the applicant and EAPs’ responses.
3.3
Final Basic Assessment Report
The final BAR will be submitted to EDTEA within which the Department must either accept or reject the final BAR within
60 days of acknowledging receipt of the report. Stakeholders will be notified on the submission of the final BAR to the
EDTEA and provided with further opportunity to submit comments within a stipulated reasonable comment period (21
days). Stakeholders will be requested, in terms of the NEMA 2014 EIA regulations to submit any further comments
directly to the EDTEA and provide a copy to the EAP.
Project number: 46648
Dated: 2015/10/27
Revised: Klicka här för att ange text.
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WSP Environmental (Pty) Ltd
Block A, 1 on Langford
Langford Road, Westville
Durban
3629
South Africa
Tel: +27 31 240 8860
Fax: +27 31 240 8801
www.wspenvironmental.co.za
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