Issues and Response Trail - Coastal and Environmental Services

Transcription

PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE
Draft Environmental impact Assessment Report
April 2015
ISSUES TRAIL
Issues submitted post Scoping Phase for inclusion in the Draft Environmental
Impact Assessment Report
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Notes on the Issues Trail:
Issues submitted are listed in alphabetical order of the surname of the person that submitted that issue.
Some issues were submitted by I&APs in PDF format and had to be retyped by Sustainable FuturesZA (SFZA). Minor typing errors may have
occurred.
For some issues, headings were added or words highlighted to make it easier for the reader to identify the focus of that issue.
The response from EAP refers to a response from the EAP team, which includes SFZA.
For the Issues Trail, issues were translated from Afrikaans to English. The original issues submitted are included in Appendix E
No.
Issue
Access for specialist studies
1.
Morning Mercia,
I contacted Frans van Rooyen at SANParks to notify that I
was coming through. He told me that I require written
permission from the community of Melkbosrant, who are the
owners of the land that SAN Parks merely manage on their
behalf as part of the reserve. SANParks will not grant me
access without this. Would you know how I would go about
doing this? I am booked to go through there tomorrow, so
would like to get this done ASAP if possible.
2.
Kind regards,
Mathew Ross (Pr Sci Nat, MSc)
From:
Frans
Van
[mailto:[email protected]]
Sent: 02/04/2015 07:52 AM
To: Lloyd Theunissen
Subject: RE: ACCESS TO THE PARK 09 APRIL 2015
Hi Lloyd,
Comments & Response Report
Rooyen
Raised by
Kind regards,
Mathew Ross (Pr
Sci Nat, MSc),
comment by email, 17 March
2015
Response from CES EIA team or Hydro SA
Good morning Frans van Rooyen
Please find attached the requested letter.
Your positive response will be highly appreciated.
Kind regards
Lloyd Theunissen, Trustee, Riemvasmaak Community
Development Trust, comment by e-mail, 17 March 2015.
Lloyd Theunissen,
Trustee,
Riemvasmaak
Community
Development
Trust, comment
by e-mail, 02
Please allow Mathew Ross and his team access to the
park, tomorrow, 18 March 2015.
From: "Lloyd Theunissen" <[email protected]>
To:
"'Frans
Van
Rooyen'"
<[email protected]>
Cc: <[email protected]>, "'Mercia Grimbeek'"
<[email protected]>, "'Niel Theron'" <[email protected]>, <[email protected]>
Subject: RE: ACCESS TO THE PARK 09 APRIL 2015
Page 1
No.
Issue
Raised by
April 2015.
I’ll need a request and you be specific where access is
needed and the reason access is needed for also the amount
of time they’ll spend.
April 2015
Date: 2 April 2015 09:38:16 GMT+2
Good morning Frans
1.
Access to the Park will need to be approved by Park
Manager.
I do not understand your e-mail.
2.
This is not the first time that access is requested
and granted.
I just need from you the OK that you give authorization to
whoever to access Melkbosrant area.
3.
Hydro-SA is in the process of applying to install a
hydro power plant in this specific area and need to do the
necessary inspections and comply with the necessary
requirements as stipulated by the relevant Governmental
Department.
Regards!
Frans
4.
As trustee of the Riemvasmaak Community
Development Trust, I, Lloyd Wilfred Theunissen, on behalf
of the trustees and the Riemvasmaak community, hereby
give authorisation to Niel Theron and his team to gain
access to the Melkbosrand area of the park on 09 April
2015. The time, gate of entry and period need for the
day, Hydro-SA will communicate directly with you and or
a designated member your team.
5.
I hope and trust that the above request is clear
and in order.
6.
Kind regards and should you be travelling over the
long weekend, please travel safely.
Lloyd Theunissen
Benefits of the Project
3.
As a community member of Riemvasmaak I have concerns.
If the the project starts, will there be job opportunities for
the people of Riemvasmaak?
Willl the hydro power station benefit tourism?
Bennie Kordom,
Marchand
Community,
comment by
comment form,
20 March 2015
The power plant will create jobs during construction and
operations. During the construction phase approximately
150 -200 jobs will be available for the local cimmunity.
This includes the Riemvasmaak community.
The hydro power plant has the potential to benefit
Page 2
No.
Issue
What are the direct benefits for the people of Riemvasmaak?
Raised by
April 2015
tourism through the Economic Development spend which
it will be obligated to spend as part of the Renewable
Energy Independent Power Producer Program(REIPPP).
The Riemvasmaak people can benefit in three ways:
 Rental Income as the Developer will lease the land
on which the power plant is to be constructed.
 Direct job creation
 Dividend Income – the community has the
opportunity to purchase between 1% and 5%
shareholding in the project. This is another
condition of the REIPPP

General
4.
Hi Shawn,
I would like to renew my status as I&AP
Regards
Nardus du Plessis
Section Ranger
SANParks: Augrabies Falls National Park
Nardus du Plessis
Section Ranger
SANParks:
Augrabies Falls
National Park,
2015
Dear Nardus,
Thank you for your e-mail regarding the proposed
Riemvasmaak Hydro Power environmental impact
assessment. Nardus you and all of the key SANPArks staff
at Augrabies National Park, SANParks Regional, SANParks
Head Office and SANParks Planning have been registered
as interested and affected parties. My team is currently
updating the database of all interested and affected
parties.
I hereby confirm that you have been registered as a
interested and affected party. If there are any additional
persons who would like to register please feel free to send
me their contact details.
5.
WESSA in the Northern Cape is not able to deal with these
matters.
Please do not send faxes or hard copies of documents to us.
They will be destroyed.
Wildlife and
Environmental
Society of South
Africa, Northern
Cape Branch,
Sincerely,
Shawn Johnston
Comment noted.
Page 3
No.
Issue
Registered mail will NOT be collected.
6.
Please consult the website for other WESSA contact details,
or
direct
your
e-mail
to
[email protected]
or
[email protected]
We thank you for showing interest in one of our amazing
adventures. Our office will be in contact shortly to discuss
your booking.
Raised by
2015
April 2015
The Kalahari
Team, comment
by e-mail, 13
March 2015
Comment noted.
Luel Culwick,
Sidale Energy
Solutions,
2015
Owen Peters,
Eskom, comment
by e-mail, 19
March 2015.
Ramon Odendal,
Eskom Land and
Rights, comment
by e-mail, 25
March 2015
Dear Luel,
Thank you for your e-mail.
interested and affected party.
Please note we have recently moved servers and upgraded
our website. If you have not had a response within 24 hours
please contact us directly on +27 (0)54 453 0001 or +27
(0)82
476
8213,
alternatively
[email protected]
7.
We look forward to seeing in the Green Kalahari.
Kind Regards
The Kalahari Team.
Hi Shawn
I am already an IAP. I assume I don’t need to register again?
Luel Culwick,
Sidale Energy Solutions
8.
Eskom’s rights and infrastructure affected by the proposal.
9.
Please register me as an interested and affected party.
Eskom representative.
You
are
a
registered
Sincerely,
Shawn Johnston
Dear Owen Peters,
You have been registered as an interested and affected
party and your comment has been noted. Sincerely,
Shawn Johnston.
Dear Ramon,
Thank you for registering as an interested and affected
party. Our team will keep you informed regarding the
availability of the DEIR.
Sincerely,
Shawn Johnston
Page 4
No.
10.
11.
Issue
The weir is extremely close to my property and I live on the
island adjacent to the proposed weir.
Hi Shawn,
Please register or re-register as per attached the 4 persons
from SANParks side as I&EP. With any communications
please send to all 4 of these persons.
Also find attached previous comments/concerns document of
SANParks.
Raised by
Gert Heese,
Orleans Boerdery,
Groot Vaalkop
Eiland, comment
by e-mail, 15
March 2015
Frans van
Rooyen,
Park Manager:
Augrabies Falls
National Park,
2015
Regards!
Frans van Rooyen
Park Manager: Augrabies Falls National Park
April 2015
Dear Mr. Gert Heese,
Thank you for your e-mail. You have been registered as
an affected party on the project database. I’m forwarding
your comments onto the environmental team and will
convene a meeting with you shortly. Sincerely, Shawn
Johnston.
Dear Mr. Frans van Rooyen,
Thank you for your e-mail. I hereby acknowledge
receiving your e-mail and registration of the following
persons:
1.
2.
3.
4.
Howard Hendricks;
Andre Riley;
Frans van Rooyen; and,
Lucius Moolman.
I hereby confirm that the above mentioned person have
been registered as interested and affected parties (I&APs)
for the proposed Riemvasmaak Hydro-Power Station EIA.
Mr. Frans van Rooyen, I acknowledge receiving your five
page document and will forward it to Ted Avis and Bill
Rowlston (of EOH CES, the project EAP).
12.
Information on the social, labour and plans. Communication
and public sector meetings.
Alfred Tieties,
Director Technical
Services, Z.F.
Mgcawu District
Municipality –
Upington,
comment by
comment form,
19 March 2015
Sincerely,
Shawn Johnston
Comment noted.
Presentation was scheduled to be made to the ZF Mgawu
District Municipality on Friday 17 April to provide more
detail about the proposed project.
Unfortunately the ZFM District Municipality cancelled and
we are awaiting confirmation of a new date.
Page 5
April 2015
No.
Issue
Raised by
Department of Environmental Affairs, SANParks & Hydro SA Meeting/Site Visit 23 October 2014
13.
Hi Niel and Mercia,
Department of
The attendance register, notes, and SANParks Position
Environmental
Paper are recorded as a record of the meeting and
Below are my notes from the recent meeting with DEA and Affairs, SANParks
included into environmental impact assessment process.
SANParks, focusing on the questions raised.
& Hydro SA
meeting and site
The South African National Parks Position Paper, August
1. During culvert construction will game still have access to visit, 23 October
2014, 7 page document is hereby appended as part of the
the river? Will need to allow for this. Is it possible to also 2014. Notes
record of the notes of the National Department of
provide watering holes along pipeline. Will need to map recorded by Dr.
Environmental Affairs, SANParks and Hydro SA meeting
game paths and ensure access during construction.
Ted Avis, CES
and site visit.
2. Pipeline to follow existing road/track. Disturbances during
construction to be rehabilitated.
3. The small drainage lines to Orange river will need to
continue functioning so pipeline cannot block these. A storm
water management plan approved by DWA will be required.
Where these drainage lines occur culverts may need to be
deeper to avoid the pipeline been exposed.
4.
Road width will be 6m and servitude about 20m wide.
5.
Danie- have approved many renewable energy
projects. Third time they have been engaged with this
project and have great concern about the falls. Whether
activity takes place outside park the effect will be on the
park. EIA needs to deal with this and must have guarantee
that falls and national park cannot be compromised. It’s a
Schedule 1 protected area. Mitigation is easy but the
fundamental issue that there must be measures to sustain
the falls and hence the park.
6. The holistic and sustainable perspective is NB to DEA.
When water bypasses falls this is seen as a key issue.
7. Gap in EIA was lack of flow data, short and long term/ and
risk of low flows. Must be properly managed as if not can be
a fatal flaw. Second largest water fall in Africa.
1. This aspect has been dealt with in the Faunal
Specialist Study and the impact section of the
EIAR.
2. Noted and recommended
3. A Stormwater management Plan would need to be
produced as a condition of approval. Detailed
design will determine where the pipeline needs to
be deeper to achieve the mitigation measure of
minimizing visual impacts through burial.
4. This relates to the required servitude for the
pipeline/conveyance system.
5. Recommendations in the EMP and mitigation
measures in the EIAR deal with this issue, which
has been a central focus of the EIA.
6. Noted and addressed.
7. More detailed flow data and analyses are included.
See for example Section 3.3 of the EIAR.
8. This has been addressed in the DEIR, the
development will not avail istelf of any water once
the flow is reduced to 30m3/s. This is the
environmental flow required and the power plant
will be not operate at this level.
9. The design of the weir is such that it will
guarantee 30 cumecs of water over the falls.
10. The Hydrological Model looked at the past sixty
years (although the banking model will only be
based on the last 20 years – as this more
Page 6
No.
Issue
8. DEA need assurances from developer that they will not
affect the falls. Water availability over the falls over a long
term period needs to be investigated. Must consider long
term trends especially extended dry periods and also climate
change.
9. HydroSA will be able to guarantee 30 cumecs over the
falls, based on the weir design.
10. Need to look at last 20 to 50 years when there was less
than 30 cumecs over the falls. Need to interrogate data and
include a more detailed analysis of hydrology and flows in
the system.
11. HydroSA – the option of designing an additional sluice
gate that is under the control of the park and after a protocol
is followed they could shut down the plant (over-ride switch).
Give them a physical mechanism to control flows and hence
guarantee flow.
12. SANPARKS- support renewable energy but Augrabies is a
national park and therefore cannot support the
construction of a weir or power lines within the park.
13. RVM community have been asking if SANPARKS is
approving the HEP scheme. Have received questions from
public about this. SANPARKS concerns are not included in the
FSR as they were received after FSR was completed.
14. SANPARKS needs to provide a list of their concerns so it
can be incorporated into the project design.
15. RVM community – they are in favour of project, subject
to acceptable environmental impacts.
Raised by
April 2015
accurately reflects the current flow regime –
based on controls at Van Der Kloof and Gariep
Dams) Over the last 20 years there have been
561 days (out of 7300 days) where the flows have
been less than 30m3/sec (7.7%) whereas there
has been 233 days over the last 10 years (3650
days - 6.4%)
11. An emergency shutdown procedure is decribed in
Section 3.3.2 of the EIAR.
12. Noted
13. SANParks concerns have been received and are
dealt with in various and many places within the
EIAR.
14. As above
15. Noted
16. Noted. A legal review relating to land ownership
and management of the land was undertaken and
the results are presented in Section 2.4 of the
EIAR.
17. Noted
18. Noted. Dealt with in Section 2.4 aqnd elsewhere in
the EIAR.
19. Noted. The EIA has focused on all aspects of the
project’s potential impacts.
20. As for response 18 above.
21. Noted with concern
22. See asection 3.3.1 of the EIAR.
23. A legal review relating to land ownership and
management of the land was undertaken and the
results are presented in Section 2.4 of the EIAR.
24. Has been done
25. Noted
16. DEA Minister is responsible for settlement of land in
protected areas and protected status must continue. A
settled land claim must take protected status into account
Page 7
No.
Issue
and SANPARKS has jurisdiction over the area.
Raised by
April 2015
17. Niel Theron (HydroSA) is aware of all the rights they
need to get. Prerequisite to bid is the environmental
authorization.
18. DEA Kalie Naude. National Park authority sits with
SANPARKS and there is no other act that overrides this.
Deproclamation can only be done by parliament.
Management authority (SANParks) must give permission for
activities that take place in a national park. DEA look
negatively at developments in National Parks. If SANPARKS
as management authority is opposed to development then
approval is unlikely. Their management plan is a legislated
instrument that must be complied with. If the project is not
part of the management plan then changing the plan could
delay the project by years.
19. SANPARKS Hugo Bezuidenhout - Need to also adhere to
management plan in park as it is not all about the falls.
20. SANPARKS comments relate to remoteness, zonation of
areas. If project required changes to zonation then
management plan needs must be changed and Minister must
approve it.
21. Danie Smit of DEA. Would like all parties to work
together but once they receive report and if it has negative
comments from SANPARKS then approval highly unlikely.
22. The 30 cumecs figures need to be fully justified. How did
HydroSA determine this as the minimum flow required for
the falls? Elucidate in the EIA.
23. Land claim on Portion 497/0 could take a number of
years to remove. Land is currently zoned remote in terms of
SANParks management plan.
Page 8
No.
Issue
24. Need to check listing notice 3 because if protected area
then there are much lower thresholds.
Raised by
April 2015
25. Option of approving the EIA subject to changes to
management plan - not an option according to Danie Smit.
End of questions
Minutes prepared by Ted Avis
The South African National Parks Position Paper,
August 2014, 7 page document is hereby appended as
part of the record of the notes of the National
Department of Environmental Affairs, SANParks and
Hydro SA meeting and site visit.
Eskom Network Planning
13.
Dear Lebogang,
I trust this finds you well.
As you are aware, Tom Bezuidenhout recently submitted the
Grid Application for the proposed project. I am currently
finalising the Environmental Impact Assessment for the
project and one of the conditions imposed by the
Department of Environmental Affairs (“DEA”) is that we
obtain a letter from Eskom expressing the need or
desireability for such a project in the area. This is not a
request usually imposed on an IPP. Discussions with Robin
Buske at the Brackenfell office have lead me to you.
Lebohang Motoai
Grid access Unit,
Eskom Holdings
SOC, comment by
e-mail, 07 April
Dear Mercia,
We do not write such letters to all IPP`S, We do not even
have a template for such letters.
I am sorry cannot assist you with such letter.
Regards,
Lebohang Motoai
Grid access Unit
For ease of reference I insert the clause from the letter
received from DEA below. Given the current status quo and
the fact that the project would feed into the National Grid - a
national rather than even provincial shortage would be
relevant.
Kindly advise if you would be able to assist with such a letter
and if not would you kindly point me in the direction of
someone that could assist please.
Page 9
No.
Issue
Raised by
April 2015
Best regards
14.
Mercia Grimbeek
Project Manager
Good Day Mercia,
Please find a summary of our discussion for the meeting
regarding Hydro SA’s RVM project.
Please note that the attached minutes do not bind or commit
Eskom to anything but merely reflect a record our
discussion.
Robin Buske,
Network
Development
Planning
Engineer, Eskom
Holdings SOC,
comment by email, 07 April
2015
Meeting minutes of the Eskom-Hydro SA meeting
regarding the transmission integration of the project are
appended. Six page document.
Formal commitment and costing for your connection is only
done when you officially apply and pay for your CEL and
Eskom provides you with a CEL. I believe this has been done
and Eskom GAU has received
your official application on the 2nd April 2015 as it
was sent to me.
This discussion also ignores the preferred connection of any
selected bidder approved in Round 4, for which no
announcement has been made yet by the DoE.
Regards,
Robin
Issues Raised By Kobus van Coppenhagen, Gerhard Smit & Andrew Hockly
15.
To whom it may concern
Kobus van
Coppenhagen,
We have been informed several months ago by AURECON, Augrabies,
that they are no longer acting as consultants for the above comment by ementioned application and that they are currently involved in mail, 05 March
litigation with the applicant. This follows more than 18 2015.
months of requests from us for a copy of the so called
upgraded application form, which they have refused to
provide, citing invalid reasons.
Dear Mr van Coppenhagen
Many thanks for your email. As you note, we are the new
EAP on the project, and assure you that we will execute
the EIA in a fair and transparent manner. Mr Bill Rowlston
of CES is responsible for writing the EIA, as he has a
large amount of expertise in this field, and I act as study
leader. Public consultation is undertaken by Shawn
Johnston, who specialises in this field, and has worked
extensively in the area. I copy them both in. Further
Page 10
No.
Issue
We have come to the conclusion that the DEA is either
indulging the applicants tardiness, for unknown reasons, or
just don't care about our National Heritage, both of which are
intolerable situations. Failing a prompt response from this
department in due course, we will have no option
but to approach the office of the Minister of Environmental
Affairs directly, for relief. We are also putting on record the
fact that it seems as if no water license application has been
submitted, because we have also requested that document,
without success.
We want to re-iterate our prior concern that the application
is procedurally and administratively flawed, because it seems
as if the applicant is conducting this "upgraded" procedure
on their own Terms of Reference, i.e. without the proper
directions/instructions of the DEA and without any deadline
for conclusion of the procedure and even without a
consultant! If the DEA did issue a new set of instructions for
this upgrade, after requesting the revised application on 18
June 2013, we would like to receive a copy of the full
documentation.
Regards
Kobus van Coppenhagen
0836564498
Raised by
April 2015
correspondence should be addressed to Shawn.
I wish to confirm that we have all previous information,
reports, communications and data from Aurecon to enable
us to complete the EIA process. All of your previous
comments were dealt with and incorporated into the Final
Scoping Report, which we have reviewed together with
the specialist studies to ensure all issues have been or
will be dealt with. Would you like Shawn to give you a list
of your communications we received from Aurecon, just
to be certain?
Currently we are updating and finalising the specialist
reports to ensure that they address all issues and
concerns raised by IAP’s, and that they deal with the
single, 40 Mwatt project. We are currently initiating the
drafting of the EIA report, and hope to circulate this
towards the end of April. Shawn will notify all registered
IAP’s of the exact date, and will also circulate an email
updating everyone on the current status of the EIA phase.
We will also schedule focus group meetings with key
stakeholders during the EIA phase.
We are not involved in the WULA application but I will ask
Mercia, the HydroSA environmental manager (and copied
herein), to send this to you when available.
The other documents you refer to will be available as part
of the DEIR.
You will note that I have not copied all the parties you
included in your email. In my experience the authorities
and other officials prefer not to be copied in, as all
correspondence is codified and included in the EIA report
and its annexures. You are, of course, free to continue
copying them in if you so choose.
Regards
Ted Avis
Page 11
No.
16.
Issue
Subject: Hydro-electric power station in the Augrabies Falls
National Park
Dr. Avis
We are a registered affected party for the above mentioned
application, which was launched by three separate SPE's in
Dec 2012 and which was subsequently "upgraded" to double
the capacity of the proposed installation.
For the sake of brevity we will not elaborate any further,
assuming that your company is in possession of the details of
all the registered IAP's together with all the correspondence
which was exchanged between IAP's and AURECON. As a
matter of interest; we have suggested 2 years ago that
AURECON should be replaced as the consultants because
they
were
conducting
a
procedurally
flawed
and
administratively unfair process. This happened a few months
ago and your company has the unenviable task of concluding
the process in a transparent and fair manner. As a matter of
record it must be noted that a precedent was set several
years ago when another applicant was directed by the
Competent Authority, to allow the IAP's to participate in the
appointment of the consultants due to the impacts of the
proposal, which was also our notion in this case, from the
outset. Details of this directive can be provided on request
and which would then serve as proof of precedent.
Raised by
Kobus &
Hannecke van
Coppenhagen,
Augrabies,
2015.
April 2015
We confirm that we have all the relevant details of
previously registered IAPs.
We note your comment that another applicant was
directed by the Competent Authority; to allow the IAP's to
participate in the appointment of the consultants, but
confirm that this was not a requirement in this case.
Based on a perusal of the Issues and Response trail in the
Final Scoping Report, it appears that a large amount of
comemnts from you are included. However, we are not in
a position to undertake an audit of your comemnts, as we
do not have the original communications. You would be
best placed to do so.
We do respectfully request that your facilitator contact us
(and perhaps others) to confirm our status as affected
parties, especially due to our many valid concerns and the
incompetent manner in which it was being dealt with. We
also need to verify with the facilitator that your company is
in possession of a full record our correspondence, for
consideration.
In the meantime we do need a copy of the valid upgraded
application (requested by DEA 18 June 2013) together with
Page 12
No.
17.
Issue
the subsequent instructions and directives issued by this
competent authority, which would have validated the
application and which would lead the consultants in the
design of the Scoping and EIA Reports. We also need a copy
of the water license application, together with the
instructions and directives issued by DWA.
Regards
Kobus & Hannecke van Coppenhagen
Augrabies.
0836564498
Subject: Re: Application for Hydroscheme in the Augrabies
Falls National Park
Good day
We are not sure whether this e-mail is actually meant for the
office of Mr. Gordon although his name appears on the
related documents. In order to remove any ambiguity this email is adressed to the Director General; Ms. Nosipho
Ngcaba, for attention. Regards
18.
0836564498
Good day Shawn
Our telecon of this morning refers;
Mr G Smit forwarded contact details of EOH CES on 9 March,
after this e-mail was sent.
Attached below is a copy of an e-mail which was sent to DEA
on 5 March and which we redirected to the DG after
discovering that M Gordon's portfolio did not include
environmental authorization, although his details have been
listed since the launch of the application. The same was true
of DWA where the name of an official, which has retired
years before the application, was used, but we cleared that
Raised by
April 2015
Kobus &
Hannecke van
Coppenhagen,
Augrabies,
2015.
Noted
Kobus van
Coppenhagen,
Augrabies,
2015.
Dear Mr. Kobus & Mrs Hannecke van Coppenhagen,
Thank you for our telephone conversation early this
morning. I wish to thank you both for highlighting your
concerns about the proposed project. I look forward to
engaging with you and other affected parties during the
environmental impact assessment phase.
I hereby acknowledge receiving your e-mail highlighting
the communications with the National Department of
Environmental Affairs and the concerns you have raised
regarding the quality of reports and the correct facts. I
will make sure these comments are passed onto Dr. Ted
Avis and Dr. Bill Rowlston at EOH Coastal &
Page 13
No.
Issue
issue up by ourselves and notified the EAP. We want to bring
your attention to the fact that documents should not be
littered with obvious mistakes if you want to conduct a fair
and transparent process. The trend of the document is self
explanatory and now that we have your contact info, you
could share it with the applicant.
Raised by
April 2015
Environmental Services.
I look forward to meeting with you and other affected
parties during the EIA phase. Sincerely,
Shawn Johnston
Regards
19.
0836564498
Good day Shawn and Ted
The new BID which was forwarded for our attention refers;
(1) Firstly, we do not want to have to correct you on certain
aspects of this "application" on a constant basis. We have
referred to the fact (to AURECON) that the PROJECT TITLE
was ambiguous, because the public would not know that the
site is located within the Augrabies Falls National Park
(AFNP) and that the proposed activities would directly affect
the status of this National Park, i.e. that the Park must be
de-proclaimed in order to give effect to an approval. This
would be a major upheaval and quite similar to what the
Tasman Government wanted to do in a Tasman National Park
in the recent past; to be able to conduct logging operations
inside the National Park and then to re-proclaim it as a
National Park again, afterwards. In actual fact, there is
another example where they did exactly that, in order to
achieve their goals. The IUCN opposed their latest proposal
and we have also approached the IUCN in respect of this
application inside the AFNP, but are still waiting for a
response. (2) (You must be aware that the Tasman
Government, via their wholly owned HYDRO ELECTRIC
CORPORATION (HEC), which trades under the names Hydro
Tasmania (HT) and Entura are partners in this (and other)
applications and that they would be benefiting heavily from
these projects? This is probably the origin of the culture of
Kobus &
Hannecke van
Coppenhagen,
Augrabies,
2015.
Dear Mr. Kobus van Coppenhagen,
Thank you for your e-mail.
I hereby acknowledge receiving your correspondence and
will clarify it with the environmental impact assessment
practitioner and the developer and revert back to you as
soon as possible.
Sincerely,
Shawn Johnston
1. Project title - We note your comemnts, and refer
you to section 2.4 of the EIAR, which provides
details on a legal review and matters pertaining to
land ownership and the management thereof
which has a bearing opn the project’s title.
2. Proponent - We are aware of the associate
between HydroSa and HydroTasmania, and note
your reservations.
3. Changes to the application and applicant –
4. Fatally flawed application – The Department of
Energy (DOE) initially had a 10MW cap on small
hydro projects in the REIPPPP. Hydro SA therefore
submitted three Basic Assessment Applications for
three separate 10MW projects. The DOE
subsequently increased the cap to 40MW. This
Page 14
No.
Issue
intolerance by the applicant to any form of objection, if you
have investigated their modus operandi?). Anyway, the DEA
accepted our objections regarding the naming of the project
and their suggestion is reflected in the letter below and we
have also used it in the subject title above. We propose that
you confirm that this is the correct name in order to be able
to move forward from the title page!
(3) Secondly, the letter (below) dated 18/6/2013 requests
that the RVM 1 Hydro Electric Power (Pty) Ltd, application
document must be revised to reflect the increased capacity
applied for, which has to be done in order for the
Department to confirm the ToR for the continuation of the
application. (We have asked for copies of this revised
document for the last 18 months, with no success).
However, this letter from DEA is silent regarding the
activities applied for by RVM 3 Hydro Electric Power (Pty) Ltd
(weir and conveyance infrastructure) which the consultants
are attempting to transfer to RVM 1Hydro Electric Power
(Pty) Ltd (a separate SPE) as it would become apparent in a
letter of 3 June 2013, to DEA. A meeting between the
applicant and DEA was held on 7 May and followed up by a
letter from AURECON, dated 3 June 2013, addressed to Mrs.
Linda Poll-Jonker (DEA) where the EAP falsely states on page
2 "Withdrawal of two application forms:
Initially RVM1 applied for 3 separate projects ......."
Which is patently false, because the notice dated 21/12/2012
(and many other docs) states on page one:
Raised by
April 2015
prompted Hydro SA to have only one project
which can generate 40MW instead of three smaller
projects. It would also reduce the environmental
footprint substantially. As a result two of the three
Basic Assessment applications were withdrawn
and the remaining application was upgraded to a
full Environmental Impact Assessment. The
correct procedures were followed with the
Department of Environmntal Affairs to execute
this. Copies of all application forms are attached
as appendices to the DEIR
5. Water balance aspects – Information on flow
duration and hydrology are presented in Section
3.3 of the EIAR and elsewhere. Please note
however, that this is a run of river scheme and
hence is non consumptive. Nevertheless, the
project is based on an annual power generation
capacity of 235 gigawatt-hours (GWh). There will
be periods when no power can be generated, as
run of river is below the threshold of 30 cumecs
required for the falls, but the financial model
considers this. A positive IRR and NPV will be
generated.
6. Turbidity – The risks of increased turbidity have
been assessed as low in the EIAR.
7. Height of the weir – The weir will not be higher
than 5m – see Section 3.2.1 of the EIAR.
"1) Introduction:
RVM 1 Hydro Electric Power (Pty) Limited, RVM 2 Hydro
Electric Power (Pty) Limited and RVM 3 Hydro Electric Power
(Pty) Limited, (RVM 1, 2 and 3) wishes to construct..........."
Thus
3
separate
legal
entities
(Special
Project
Vehicles/Entities as Mr Theron referred to it in the first public
meeting) !!!!!!!!
(4) This clearly demonstrates that the EAP/applicant made a
Page 15
No.
Issue
false statement, but the contractual relationship between
the three SEPARATE ENTITIES is clearly illustrated in a
Powerpoint presentation document titled: RVM Hydro Electric
Project, Overview 30 July 2012, Kimberley on page 15,
section 8. This document can be forwarded if required.
Thus, the closure of the application which provides for the
water conveyance infrastructure activities and weir, cannot
be "revived/inherited immediately" by another entity,
according to the regulations. In a document to AURECON,
titled Hydrology of the Orange river, we did allude to the fact
that the old Bophutatswana Government built a coal fired
power station somewhere in what is now Northwest Province,
but did not make allowance for the water needed and thus
the plant never started up. From a procedural/administrative
point of view this is a fatal flaw and if approved the RVM 1
application will have to be reviewed on this ground alone,
because it has NEVER applied for the water conveyance
infrastructure related activities, which also affects other
properties.
Raised by
April 2015
(5) Thirdly, if your specialist investigations does not include a
full water balance investigation this application would be
useless, because we have already shown (hydrology doc and
others) that there would be a deficit of more than 660 million
cumec per annum in the Lower Orange River Valley in the
near future, just because of Lesotho Highlands Water
Scheme Phase II, which would transfer an additional 21
cumec/second to the Vaal Catchment Area. There are other
increases in consumption which we have also alluded to,
which the EAP seemed to ignore, because the viability of the
project and also the rationale for the doubling of the capacity
of the plant would have no scientific/reasonable basis. This
was clearly demonstrated in a letter dated 2 July 2014, to
AURECON by Dr. Riaan Wolhuter, who is an electrical
engineer! On the other hand, it is possible that the applicant
is only interested in the construction phase profits and does
not care if the investors and community are saddled with a
non-profitable installation. Obviously, this would be valid
Page 16
No.
Issue
comments for the other planned installations too. (6) Not a
word has been mentioned by the EAP/applicant about the
turbidity of the water of the Orange River, which is the
highest in Africa and 4th highest in the world, which would
not be good news for a water driven turbine operator,
especially for higher elevation run-of-river type systems.
Raised by
April 2015
(7) Fourthly, the height of the weir is now suddenly
increased to 5 m again, according to the BID. Are you busy
with a copy and paste exercise, because if you are not
serious, you might eventually regret becoming involved in
this application!
For the moment this will suffice and we would expect a
proper response to the above-mentioned issues, because
skirting around the them will not make it disappear?
<DEA let re Upgrade to EIA 190613.pdf>
20.
Regards
Kobus and van Coppenhagen
0836564498
Dr. Avis' e-mail regarding comments of IAP's refer;
Please consult the correspondence below, to verify that our
comments were not considered for the FSR, due to
unavailability of the documents.
Regards
Kobus and Hannecke van Coppenhagen
0836564498
Begin forwarded message:
Kobus van
Coppenhagen,
Augrabies,
2015.
Dear Mr Kobus van Coppenhagen,
Thank you for informing our team that your comments
submitted to Aurecon during the final scoping phase have
not been incorporated. I will incorporate your comments
into the draft environmental impact assessment phase.
Mr. van Coppenhagen, can you please submit the
mentioned comments directly to me.
Sincerely,
Shawn Johnston
From: Louise Corbett <[email protected]>
Date: 09 Oktober 2013 7:43:14 nm. SAST
To:
Nelis
Bezuidenhout
<[email protected]>,
"Kobus
van
Page 17
No.
Issue
Coppenhagen" <[email protected]>
Cc: Simon Clark <[email protected]>
Subject: RE: PROPOSED HYDROPOWER STATION ON THE
FARM RIEMVASMAAK, AUGRABIES, NORTHERN CAPE - RVM
1:
DEA
Ref:
14/12/16/3/3/1/681;
NEAS
Ref:
DEA/EIA/0001403/2012 - AVAILABILITY OF THE FINAL
SCOPING REPORT FOR REVIEW
Raised by
April 2015
Dear Kobus
As noted on site today there will still be further opportunities
to comment on the EIA Process. However, should you still
wish to comment on the FSR you are welcome to do so. We
will then forward your comment to DEA for their information
and we will include and respond to it in our next report (the
Draft Environmental Impact Assessment Report, unless DEA
require us to revise the FSR).
Kind regards
Louise
Louise Corbett
Associate I Environmental Services I Aurecon
T +27 21 526 6027 I F +27 86 667 3532 I
E [email protected]
Aurecon Centre 1 Century City Drive, Waterford Precinct
Century City I South Africa
aurecongroup.com
From: Nelis Bezuidenhout
Sent: Wednesday, October 09, 2013 8:03 AM
To: Kobus van Coppenhagen
Cc: Simon Clark; Louise Corbett
Subject: RE: PROPOSED HYDROPOWER STATION ON THE
1:
DEA
Ref:
14/12/16/3/3/1/681;
NEAS
Ref:
Page 18
No.
Issue
Raised by
April 2015
Dear Mr Van Coppenhagen
Please find attached the email correspondence with regards
to the matter in your email below.
The first email was sent on 23 September 2013 (11h32)
followed shortly by a follow-up email (15h23).
Kind Regards
Nelis
Nelis Bezuidenhout I MPhil Cum Laude, BA Development &
Environment
From: Kobus van Coppenhagen [mailto:[email protected]]
Sent: Tuesday, October 08, 2013 7:21 PM
To: Nelis Bezuidenhout; Simon Clark
Subject: Fwd: PROPOSED HYDROPOWER STATION ON THE
1:
DEA
Ref:
14/12/16/3/3/1/681;
NEAS
Ref:
Good day Nelis & Simon
We have still not received the courtesy of a reply to the
matter below, would you be so kind to respond.
Regards
0836564498
From: Kobus van Coppenhagen <[email protected]>
Date: 23 September 2013 10:51:04 MGT+02:00
To: Simon Clark <[email protected]>
Cc:
Nelis
Bezuidenhout
<[email protected]>
Page 19
No.
Issue
Subject: Re: PROPOSED HYDROPOWER STATION ON THE
1:
DEA
Ref:
14/12/16/3/3/1/681;
NEAS
Ref:
Raised by
April 2015
Good day Simon
We are still not able to access the FSR for the
abovementioned project on your website and request if you
would extend the review period accordingly.
Regards
0836564498
On
18
Sep
2013,
at
14:58,
<[email protected]> wrote:
Simon
Clark
We apologise for the inconvenience, the entire site is
currently down, we have technicians currently working on
rectifying the access issues to the documentation. We will
notify as soon as the website becomes available.
Kind regards
Simon Clark ,Aurecon
Sent: Wednesday, September 18, 2013 12:23 PM
To: Simon Clark
Subject: Re: PROPOSED HYDROPOWER STATION ON THE
1:
DEA
Ref:
14/12/16/3/3/1/681;
NEAS
Ref:
Page 20
No.
Issue
Raised by
April 2015
Good day Simon
Thank you for the e-mail, but the FSR & several other
documents are not yet posted to the website. Would you be
so kind to inform us when this has been posted?
Regards
0836564498
On
17
Sep
2013,
at
16:44,
<[email protected]> wrote:
Simon
Clark
Dear Sir/ Madam
PROPOSED HYDROPOWER STATION ON THE FARM
RIEMVASMAAK (REMAINDER OF FARM NO. 497 AND
PORTION OF FARM NO. 498), ON THE ORANGE RIVER IN
THE VICINITY OF AUGRABIES FALLS NATIONAL PARK,
NORTHERN CAPE
RVM 1: DEA Ref: 14/12/16/3/3/1/681; NEAS Ref:
DEA/EIA/0001403/2012;
AVAILABILITY OF THE FINAL SCOPING REPORT FOR REVIEW
The abovementioned project refers.
This email serves to notify I&APs of the availability of the
Final Scoping Report (FSR) for the above mentioned project
for comment.
1.
Introduction
Following the comment period on the DSR, the Final Scoping
Report (FSR) was compiled. The FSR includes comments and
concerns that were raised by Interested and Affected Parties
(I&APs) during the comment period of 40 days which
Page 21
No.
Issue
stretched from 19 July 2013 until 28 August 2013.
2.
Raised by
April 2015
Changes made to FSR
This FSR is an update of the DSR, including additional
information on the current status of the public participation
process and amendments made in light of some of the
comments made. Substantive changes to the Draft Scoping
Report are reflected as underlined text, while deletions are
reflected with strikethrough text. For your convenience we
have attached the non-technical summaries (English &
Afrikaans) to this email.
The following annexures have been updated:
Annexure B (includes updated database and proof of I&AP
correspondence); and Annexure C (includes Comments and
Response Report 2 and comments received).
3.
Way forward
The FSR will be available from 16 September 2013 until 7
October 2013 for a 21-day review and comment period at
the Kakamas Public Library, at Reception at Augrabies Falls
National
Park
and
on
Aurecon’s
website
(www.aurecongroup.com please change the current location
to “South Africa” and follow the “public participation”- link).
The FSR is also available at each of the three Riemvasmaak
Community Trust offices or alternatively contact Mr Bennie
Kordom on 071 443 9277.
If the proposed project crosses your land and you are the
landowner, but not the occupier of the property, please
inform the occupier of the land on which the proposed
project is located or advise us of their contact details so that
we may do so. To ensure that all Interested and or Affected
Parties (I&APs) are informed of the proposed project we
kindly request that, should you know of someone that would
be interested in or affected by the proposed project, you ask
Page 22
No.
Issue
them to contact us. Alternatively please inform us and we
will contact them directly.
Raised by
April 2015
If you would like to obtain more information, submit any
comments or register as an I&AP, please contact Nelis
Bezuidenhout at Aurecon: Tel: 021 526 6031, Fax: 021 526
9500, E-mail: [email protected] or P.O.
Box 494, Cape Town, 8000 on or before 7 October 2012. Any
comments received on the FSR will not be captured in a
Comments and Response Report, but will be forwarded
directly to the Department of Environmental Affairs for their
consideration and responded to in the EIA Phase only.
Should you have any further queries, please contact the
undersigned.
Yours sincerely, AURECON
21.
Simon Clark on behalf of Nelis Bezuidenhout
Dr Avis
Subject: Proposed Augrabies Hydro Power Plant, Northern
Cape.(2)
We believe that you need to be informed that we are not
against any type of renewable energy project, as a matter of
principle, but rather that applications should only be
launched in appropriate areas, which would exclude National
Parks from the outset. We have been living in challenging
conditions, with no services (off-grid and brackish drinking
water), for the last 7 years, with only our own resources to
rely on. Thus, the need for the generation of renewable
energy from sustainable sources, weigh heavily on our
minds. In that regard, the record will show that we have
suggested to the DEA and the applicant that the site
alternatives to the Augrabies Falls National Park, being
Neusberg and Boegoeberg, should be considered for
approval, since they are brownfield sites. It is also quite clear
Kobus &
Hannecke van
Coppenhagen,
Augrabies,
2015.
I hereby acknowledge receiving your correspondence date
17 March 2015, at 11:09:36 SAST. I will process these
comments
into
the
draft
environmental
impact
assessment report's comments and response report.
Thank you for placing these comments on record for the
EIA phase.
Sincerely,
Shawn Johnston
Find attached the response I have received from HydroSA
relating to your request for information on the WULA
Application.
Page 23
No.
Issue
from authoritative documents that the development of
conservation areas for non-aligned activities, in biodiversity
priority areas are unacceptable e.g.
1) Study Name: Orange River Integrated Water Resources
Management Plan
Raised by
April 2015
Sincerely,
Shawn Johnston
Dear Shawn,
Report Title: Environmental Considerations Pertaining to the
Orange River (p61) Authors: R Heath, C Brown Date of
issue: August 2007
"Due to electric power generation (that is between Gariep
and Vanderkloof Dams and below Vanderkloof Dam for some
200 km) loss of species diversity is severe. The river
immediately below Vanderkloof has been described above as
an ecological desert. The creation of further "ecological
deserts" would not be desirable. They would be unacceptable
in parts of the river of particular conservation importance."
In response to Mr Van Copenhagen’s request for a copy of
the WULA for RVM. We are quite happy to oblige once the
application is complete.
2) Siyanda Environmental Management Framework Report
2008 (p76)
Kind regards
Mercia Grimbeek
Project Manager
In the instance of the Lower Gariep Alluvial Vegetation,
conservation is the only acceptable use of the area because
it represents:
that can already not be attained anymore due to the extent
of transformation that has already occurred; and
The developers met with the Department of Water Affairs
on 10 February 2015 to discuss the draft application.
This application is now being finalised for submission and
once submitted we will supply a copy for Mr Van
Copenhagen’s perusal.
(1 & 2) Ww note with thanks the references provided
relating to the conservation importance of the Orange
River and related habitats. Imopacts associated with weir
construction and the off-channel imtake are discussed
and assessed in the EIAR.
dynamic and subject to natural physical change over time
due to the interaction between the alluvial nature of the area
and flood events.
3) We would also appreciate your comment on the legitimacy
of this application against the background of the Park
Management Plan and exactly how the NEM: PAA and its
regulations must be waived to allow for this installation,
(3) The role and function of SANParks and the Augrabies
falls Management Plan are discussed, inter alia, in the
Page 24
No.
Issue
which would initiate the dismantling of our protected areas
system, if approved. The notion that the lease of a protected
area can be negotiated for non-aligned activities (for up to
100 years, according to Mr Theron in press), is fraught with
unimaginable complications. Soon, applications for wind
farms on Table Mountain National Park and Solar installations
in other National Parks would follow JUST BECAUSE THE
POTENTIAL EXIST and a precedent would have been set for
its approval.
Raised by
April 2015
Fauna Specialist Report and the EIAR.
As far as we are concerned one of the most important
aspects of this project is the diversion of water away from
the currently active river channel and waterfall (over a
distance of 9km) together with the impact of that proposal
on the environment, which is a protected area. A water
license have not been applied for, according to your
submission. Whenever this happens we would also want to
register as an IAP for that process. We do also continue to
insist on receiving a copy of the "upgraded" application from
the EAP/applicant (as provided for in the application form,
note 8 on page 1)
You must please also check on the "RVM1" application
document page 8, where it states:
Please note that any authorisation that may result from this
application will only cover activities applied for
We have carefully perused the regulations and listed
activities, and are confident all possible listed activities
are included in the application and the EIAR.
For your convenience we are recording the details of what is
being applied for (page 8 of application form), etc. Please
make your own conclusions, considering the above
statement. (Is it possible to entrust someone with the care of
our National Heritage if they cannot grasp this most basic
information, even after 18 months of requests?)
3.0 OTHER AUTHORIZATIONS REQUIRED,
3.1 Do you need any authorizations in terms of any of the
Page 25
No.
Issue
Raised by
April 2015
following laws?
3.1.1 National Environmental Management : Waste Act
....................applicant stated: No???
3.1.2 National Environmental Management : Air
Quality Act .............applicant stated: No
3.1.3
National
Environmental
Management
:
Protected Areas Act ....applicant stated: No???
3.1.4
National
Environmental
Management
:
Biodiversity Act ...........applicant stated: No???
3.1.5 ........
3.1.6
National
Water
Act
......................................................................ap
plicant stated: Yes
3.1.7
National
Heritage
Resources
Act
............................................... applicant stated:
Yes
3.1.8 ...
3.2
Have
such
applications
been
launched
already?...........................applicant stated: N/A???
Notwithstanding note 5 on page one, which specifically warns
against the use of N/A, because the application can be
rejected if it relates to material information, the applicant
used the term N/A. We hope that the deficiencies in this
"RVM 1"application are now apparent to you as the new EAP
and that our contentions in the next paragraph starts to
make sense to you. It is clear that the applicant also wants
to collect a water license without specifically applying for it
and following the licensing procedure. We have requested
that an IWULA (integrated water use license application)
procedure must be conducted because of the impact on the
Augrabies Falls National Park. This would require a full
verification process by Department of Water Affairs, to
determine whether the quantity of water could be allocated.
Thus, a (future) water balance determination is crucial,
because of the quantity of water applied for and the
Page 26
No.
Issue
statement of the EAP (AURECON), that all future water
allocations upstream, would have to consider the
requirements (power factor) of the proposed installation,
which is a misconception and shows a lack of knowledge of
the NWA and its regulations. This highlights the general lack
of a professional approach to this very controversial proposal
in an area of the highest protected status in South Africa.
Another matter of concern is that investors might be led to
believe that the schemes are viable because for example in
the case of Neusberg, ENTURA (a beneficiary) has been
appointed to evaluate the feasibility of the proposed project.
(CDM Validation Report, p18). IS THE EAP AWARE OF THIS
PRACTICE OF THE APPLICANT, APPOINTING ITS PARTNERS
FOR VERIFICATION PURPOSES? The applicant has admitted
in a meeting that they have only considered historical
records for the determination of the "dispatchability/power
factor" of the proposed Hydro power installation, which is a
grave error in the case of the Lower Orange River, due to
planned changes in the water balance upstream.
As far as our correspondence is concerned we need to inform
you that AURECON published the FSR too late for all the
comments to be submitted timeously and was thus not
incorporated
into
the
FSR.
(We
have
forwarded
correspondence to that effect). It would be essential to
receive a list of all our correspondence (in your possession)
in date order to determine whether you have all the
documents. We are however convinced of the fact that the
"application" has lapsed or is invalid, at least due to the
inadequate documentation, lack of ToR from DEA and that
the starting point, for the Scoping Report, should have been
timeous rectification of this document. We are very
concerned about DEA's tolerance/indulgence of the
"tardiness" of the applicant to revise and submit the
application in due time, because the application lapses if an
instruction is not complied within 6 months (21 months have
elapsed in the meantime). We are committed to the
Raised by
April 2015
The banks (lenders) accepted the verification provided by
Entura – Neusberg was successfully constructed within time
and within budget
The applicant was granted an extension to 30 April 2015.
Page 27
No.
Issue
administrative process but then it MUST be fair and
transparent. In the meantime we have approached the office
of the DG of DEA for action in this regard. Failing a proper
response we would be forced to approach the office of the
Minister of Environmental Affairs in due course.
Raised by
April 2015
If the applicant was the owner of the land and it was situated
outside of the protected area and its buffer zones, the
scenario would be different (as far as location is concerned)
and we expect that the EAP must always keep this in mind.
Regards
22.
0836564498
Sent: 15 April 2015 12:44 PM
To: Ted Avis
Cc: M Gordon; Danie Smit; A B Abrahams; Howard
Hendricks; Lucius Moolman;
Frans Van Rooyen; Mike Knight; Gene Visser; Gerhard Smit;
Andrew Hockley; Angus Tanner
Subject: Re: Hydro-electric power station in the Augrabies
Falls NationalPark
Dr Avis
We have requested more than 4 weeks ago, that you should
furnish us with the copy of the valid application form date
stamped by the DEA and according to which the ToR for your
EIA has been determined. You have failed to provide us with
this document, without which the application is invalid and
the procedurally flawed. Do you refuse to provide this
document? Your response is urgently required.
Regards
0836564498
Kobus &
Hannecke van
Coppenhagen,
Augrabies,
comment by email, 15 April
2015.
Thanks you for your email. My apologise for the late
response, but we are in the final stages of completing all
documents for the HydroSA project and somewhat busy.
Our engagement process, and indeed that of the EIA
process, is to gather all correspondence from IAPs and
integrate this into a comments and response trail, in
preference to individual and piece-meal responses. The
latter is an inefficient and somewhat exclusive way of
engaging, whereas including concerns and responses in
the comments trail of the EIAR is a more transparent and
inclusive manner of engaging with IAPs. This way
everyone is privy to the debate, rather than a select few.
With regard to the application form, it will be included in
the Draft EIAR as an appendix for all to see.
Regards
Ted Avis
Page 28
No.
23.
Issue
From: Gerhard Smit [mailto:[email protected]]
Sent: 09 March 2015 12:20 PM
To: Dr T Avis
Subject: Augrabies hydro-electric power station.
Raised by
Gerhard Smit,
2015
Good afternoon,
I watched the TV News last night and noticed that the
Planned Hydro-electric power station in the Orange River is
still on-going.
I would herewith request to be registered as an I&AP for this
project.
Please confirm to this email address receipt of this message
and also that I have been registered as requested.
Please also advise me at what stage the process is and also
please forward all relevant documentation to me.
Your kind co-operation in this matter is appreciated.
Kind regards
Gerhard Smit
0164283497
24.
Hi Shawn, Dankie Gerhard
Please register me as an interested and affected party for
this unsolicited proposal of a Hydro Electric Scheme in the
primitive and remote areas of the Augrabies Falls National
Park and the Riemvasmaak Community Conservancy.
April 2015
Dear Mr. Gerhard Smit,
Thank you for your e-mail dated 09 March 2015. I hereby
confirm that you are registered as a interested and
affected party
for the proposed Riemvasmaak Hydro Project EIA.
The project is now in the environmental impact
assessment phase. EOH Coastal & Environmental Services
are
the
new
environmental
impact
assessment
practitioners on the project. Their team are lead by Dr.
Ted Avis and Dr. Bill Rolston. EOH Coastal &
Environmental Services are currently drafting the draft
environmental impact assessment report for release
towards the end of April 2015. A copy of this document
will be sent to you as soon as it becomes available.
Andrew Hockly,
2015
Sincerely,
Shawn Johnston
Dear Mr. Andrew Hockly,
In order for a realistic assesmanty of the proposal I hereby
request the documents from which this new set of
consultants will be referring to in making this assessment.
In particular:
Thank you for your e-mail. I hereby acknowledge
receiving your request to register as an interested and
affected party and confirm that you have been registered
on the stakeholder database. I will be forwarding you a
copy of the draft environmental impact assessment report
when it becomes available. The environmental impact
assessment practitioner (EAP) is currently draft the
report. I'm passing your request for information onto EOH
Coastal & Environmental Services.
Any document calculating the amount of water which could
be available. Preferably from DWAF.
I look forward to engaging with you during the EIA phase
of the proposed project assessment.
Any Geological data, in particular the Earthquake Risk
assessment.
Sincerely,
Shawn Johnston
Page 29
No.
Issue
A fine scale contour map of the proposed Diversion Weir and
Outtake structures, covering the full island, the island and in
particular the potential for the erosion of the entire island.
Raised by
April 2015
The EIAR report needs to be circulated, and the validity of
the report assessed by IAPs. It is not a requirement to
send IAPs the reports and data which the EIAR draws
from, if this is indeed the nature of this (unclear) request.
A n assessment of the noise pollution inevitability during
construction covering all weather variations and wind
directions. Particularly important is the winter cold periods
when any sound stays low and carries.
An assessment of the water quality as returned to the river
just above the man made lake from Vredesvallei. Adding
dead water to dead water appears unadvisable.
Any research on the Cape Clawless Otter.
Thanks and regards
Andrew Hockly
P.O.Box 20
Augrabies 8874
079 888 9502
Job Creation
25.
Will there be enough job opportunities for the Riemvasmaak
Community? What are the timeframe for developing and
building the project? What about job creation amngst the
youth? What about developing ourselves and having
sustainable livelihoods? Most of us are unemployed and in
need of skills.
26.
Our biggest concern is unemployment and job creation. We
need clarity on what the job opportunities for the
Riemvasmaak community will be. Please clarify this issue for
us.
150 -200 jobs will be available for the local community.
Patrick Regent,
Nolukholo
Nkuphu,
Nomthandazo
Masheqa,
Thandiswa
Macando, Welma
Kariato, Wendall
Jors, Gcobani
Mapikana and
John Cloete,
150 -200 jobs will be available for the local community.
Page 30
No.
Issue
Project Support
27.
Renewable energy decision.
The community agreed that the bid of Hydro SA must be
supported and added that a renewable energy mobilising
committee be established which will ensure that
Riemvasmaak has developers submitting compatible bids for
solar power and hydro-electricity. The Development
Committee must engage the Augrabies Falls, SANParks and
all other stakeholders.
28.
The Riemvasmaak community support the development of
the proposed hydro energy facility and the community
provided the various Riemvasmaak committees to persue
and investigate renewable energy opportunities further.
29.
In our area there is a shortage of power. It would be a good
idea to have a power station here. We will have less power
cuts in the area. Our community support the project.
30.
We support the Riemvasmaak hydro project.
April 2015
Raised by
comment by reply
form, 19 March
2015.
Riemvasmaak
Committee
Meeting decision,
held at Sending
Hall, 27
November 2014
The communities project support are noted as an affected
party input.
Ben Vass at
information
session with
Riemvasmaak
Development
Committee,
Governance
Committee,
Repatritation
Committee,
Planning
Committee, 10
February 2015
Antonia Vass &
Zolike Hoorn,
comment by reply
form, 20 March
2015
Theresia Hampira,
Ketelien Kotze,
Nomule Mafikata,
Mzingisi Nkupu,
Eunice, Niklaas
Tieties, Dennis
Vass, Christopher
Kotze, Dawid van
Comment noted.
Comment noted.
Comment noted.
Page 31
No.
31.
32.
33.
34.
Issue
I like the idea that you would want to assist the community
of Riemvasmaak with te project. It would assist us when we
have a major power cut. I hope the work can start so that
the Riemvasmaak community can benefit from it.
I’m quite excited about te project. Ihave visited the
Neusberg project and have seen what have been achieved
there. I hope they can do the same on our property at
Riemvasmaak. It will assist us greatly in dealing with
unemployment and job creation for our families and children.
We do not have any concerns about the animal life as it will
adapt to the noise and the people will make a plan with the
plants. This will be a very good job creation opportunity for
the community of Riemvasmaak. We need the power station
here. There is enough space to locate the project on the site.
I do not have a problem with the project. My wish is that our
community benefit from the project during construction to
create jobs.
Raised by
Wyk, Loot
Kariato, Yekani
Mate, Norman
Rhyn, Masixole
Booi, Leonard
Roman, Christina
Hendricks, Ethel
Vass, Silvester
Frans,
Sinethemba
Mathe, Isak
Green, Magdalene
Bostander,
comment by reply
form, 20 March
2015
Leon Kopers,
comment by reply
form, 20 March
2015
Gloria Adams,
comment by reply
form, 20 March
2015
LJ
Mblankomo,Noms
a Vass, Frans
Blaauw, Nwabisa
Damane &
Desmond Blaauw,
comment by reply
form, 19 March
2015
Regina Jaar,
comment by reply
form, 19 March
2015
April 2015
Comment noted.
Comment noted.
Comment noted.
Comment noted.
Page 32
No.
35.
Issue
I support the idea of the project as it holds numerous
benefits for the community of Riemvasmaak, such as job
creation and to reduce power cuts. Please conduct a
information session in Vredes Valley as soon as possible. I
hope we can cooperate in the future. Lets proceed with the
project.
36.
We are extremely positive about the development. I hope
the project contribute to more stable and sustainable energy
needs of Blouputs and Augrabies.
Melkbosrant Community Concerns
37.
My problem is that the original Melkbosrant community was
not involved in this project. What happenes to the graves
and nature on Melkbosrant? The Melkbosrant Committee
representing the Melkbosrant Community need to be
engaged. Conduct a workshop with the Marchand
community. It is a large project and it can destroy the forna
and flora.
38.
My concerns is the community conflict that might delay the
development of the project.
April 2015
Raised by
Isak Vass,
Demetheo
Beukes, daniel
van Weyers,
Norbert Coetzee,
Petronella Basson,
Ricardo Malgas,
Claudia Lukas,
Andreas Adams,
Henry Augus, Jan
Frans, Benjamin
Vass, Dirk van
Wyk, Jacobus
Basson, comment
by reply form, 20
March 2015
Alwyn Dippenaar
and Namein
Gagiano, Blouputs
Framers
Association,
comment by reply
form, 10 March
2015
Comment noted.
Bernard
Bezuidenhout &
Markus Basson,
Melkbosrant
Community,
comment by reply
form, 19 March
2015
Feitjie Basson,
comment by reply
form, 20 March
2015
Meetings will take place during the review period of the
EIAR, during which these issues can be discussed.
Comment noted.
The PPP will deal with this process related issue.
Page 33
No.
39.
Issue
My concern is the long lead time to develop the project and
the relationship and agreement between the park and the
community.
40.
The process must be completed as soon as possibe ad the
community need to be provided with all of the project
information.
Road Network
41.
Good morning Shawn,
Thank you for your email. Thank you for the google map.
Will it be possible to forward me a map indicating the
national road and properties involved. Kind regards, Rene,
April 2015
Raised by
Michael Basson,
comment by reply
form, 20 March
2015
Charlotte Dawids,
Governance
Committee
Riemvasmaak,
comment by reply
form, 20 March
2015.
Noted. Unfortunately large complex projects take a long
time to develop.
Rene de Kock,
South African
National Roads
Agency
(SANRAL),
2015
Dear Rene,
Comment noted.
Thank you for your e-mail. This project is about 60km
away from the N14 and not near the National Road. It is
off the road to Riemvasmaak. Do you deal with the
district roads in this area?
Sincerely,
Shawn Johnston
Thank you Shawn,
Please take note that SANRAL must be consulted before
the transport of abnormal loads on national roads.
Please forward Transport Plan to Garth Julius from this
office at [email protected] if SANRAL is affected.
Kind regards
Rene
SANParks Submission (Frans van Rooyen)
42.
1, The destruction of the habitat in which at least one
endemic species (Augrabies Flat lizard) occurs. This lizard
does not occur anywhere else in the world, only in a small
radius around the waterfall.
Frans van
Rooyen,
Park Manager:
Augrabies Falls
The re submission of this four page document by Frans
van Rooyen, Park Manager: Augrabies Falls National Park
is hereby acknowledge.
Page 34
No.
Issue
2. The destruction of the geology and possible weakening of
the wall of the canyon on the northern side in the
construction. Especially when considering that this area is
already prone to earth tremours and that the river is situated
on a fault line.
3. Flow of the waterfall – This waterfall is a MAJOR attraction
not only in the Northern Cape but also in South Africa.
During the 2010/11 floods, people travelled from all over SA
to come and see the falls. Once the project is completed then
there will be no control over how much water is diverted, the
cost of the project and the need to supply electricity will be
more important.
4. Destruction and disturbance to ecology and biodiversity
during construction. This is a sensitive arid environment
where rehabilitation will be very difficult if not almost
impossible.
5. The ethics of the Park will be compromised.
6. SA does not have many waterfalls therefore they should
be protected in their pristine state. Surely, at dams (where
destruction has already taken place) hydo projects can be
put in place.
7. The noise and disturbance during the long construction
period will chase tourists away and they will probably not
return as they will conjure up their own ideas/pictures of
what the falls and park will look like afterwards.
8. For the small amount of electricity to be produced the
total destruction is not worth it. It should not even be
considered within a National park
9. The different Cormorants that nest and breed close to the
area were the proposed weir is planned is a big concern,
Raised by
National Park,
2015
April 2015
1. The faunal specialist report investigated this and
Impact 4 of section 7.3.4 of the EIAR discusses
this.
2. A specialist study to investigate seismic risks was
undertaken. Section 6.5 of the EIAR presents a
summary of the findings, and Sections 7.2.9;
7.3.9. and 7.4.9 of the EIAR respectively assess
design, construction and operatyional phase
impacts.
3. The weir is designed with a broad crested profile
at level 616.0m, and a 7.5m-wide low-flow slot
left of the channel centreline, which will allow the
agreed environmental flow of 30m3/sec to pass
through the weir structure unimpeded to ensure
that to ensure that at least 30m³/s flows through
the low-flow slot before water is diverted into the
HPP headrace. See Figure 3.7 and Section 3.3 of
the EIAR for further details.
4. This issue is addressed in both the Faunal and
Botanical specialist studies, and impacts are
discussed in Chapter 7 of the EIAR.
5. Deproclamation would not be required. However,
the project will occur in areas classified by the
SANParks Management Plan as remote.
6. Most of the suitable sites for HEP generation in
South Africa have already been developed.
Chapter 13 of the EIAR provides further details.
7. A specialist study on noise impacts was
undertaken, and the impacts are discussed in
Chapter 7 of the EIAR. The outcome of increased
noise stated here is conjecture. There are no
indications that this will or will not be an outcome,
although it is highly unlikely given the low impacts
associated with noise.
8. The justification for the project is discussd in
Chapter 4 of the EIAR.
9. This issue is dicussed in the Faunal specialist
Page 35
No.
Issue
they will be disturb.
10. The forebay will be above ground level, how will they
camouflaged it to prevent visibility once people visit the
lookout points?
11. The place where they planned to put the water back in a
dry stream is also a concern because there is currently no
water the plants and trees will die if you put water all of a
sudden there the plants are well adapted to the dryness of
the stream.
Dear Nelis Bezuidenhout and Louise Corbett
South African National Parks (SANParks) acknowledge the
opportunity to comment on the Draft Scoping Report for the
Proposed Hydropower Station on the farm Riemvasmaak
(Remainder of Farm no.497 and Portion of Farm no. 498) on
the Orange River, in the vicinity of Augrabies, Northern Cape
Province.
SANParks submits that South Africa’s economy is energy
intensive, mainly from mining, pulp and paper, and smelting.
To date, almost 90% of South Africa’s current Electricity
Generation Capacity is provided by coal. There is almost no
renewable energy generation. It is for this reason that South
Africa explores and invest in generating alternative electricity
from renewable resources. SANParks therefore supports
renewable energy generation traditionally provided by
technologies such as hydro, wind, solar and biogas.
To this effect, SANParks seeks an alignment between the
proposed hydropower station development and the National
Environmental Management: Protected Areas Act, 2003 (Act
No. 57 of 2003), (NEM:PAA) being the primary Act for
managing protected areas in the country for the following
reasons;
Raised by
April 2015
study, and impacts of the weir are discussed in
sections 7.2.4.and 7.3.of the EIAR. See for
example impact 3 in section 7.3.4.
10. The headpond and forebay – the intake to the
penstocks – is located at the downstream end of
the headrace, immediately upstream of and
adjacent to the site of the power chamber. There
is no need to camouflage it as it is a small
structure and will only be visible when one is close
to it.
11. This has been assessed in the Aquatic specialist
study, and in Section 7.4.2 of the EIAR as an
impact of low significance.
The following responses the numbered comments to the
left:
1. Legislative issues are discussed in the EMPr.
2. The Department of Energy (DOE) initially had a
10MW cap on small hydro projects in the
REIPPPP. Hydro SA therefore submitted three
Basic Assessment Applications for three separate
10MW projects. The DOE subsequently increased
the cap to 40MW. This prompted Hydro SA to
have only one project which can generate 40MW
instead of three smaller projects. It would also
reduce the environmental footprint substantially.
As a result two of the three Basic Assessment
applications were withdrawn and the remaining
application was upgraded to a full Environmental
Impact Assessment. The correct procedures were
followed with the Department of Environmntal
Affairs to execute this. Copies of all application
forms are attached as appendices to the DEIR
3. Section 2.6 of the EIAR, based on a legal opinion,
explains the issue of land ownership and land
management.
Page 36
No.
Issue
1. Discrepancies between the proposed development and
SANParks mandate must be regarded within all the
applicable environmental legislation both nationally and
internationally, not just NEM:BA as the draft scoping
report alludes;
2. The draft scoping report provides no procedural
explanation for the valid application upgrade from
approximately two 10 x 10 MW substations to one 40 MW
substation, including the regulatory framework that
provided for three applications which were lodged by
RVM1Hydro Electric (Pty) Ltd, RVM 2 Hydro Electric (Pty)
Ltd and RVM 3 Hydro Electric (Pty) Ltd, respectively in
comparision with Department of Energy lifting the cap of
≤10 MW;
3. Whilst the draft scoping report provides the fundamental
arguments for “Riemvasmaak land, owned by the
Riemvasmaak Community Trust, located within the
borders of the Augrabies Falls National Park” followed
their forced removal in 1973/1974 during Apartheid, the
report
uses
such
notion
of
land
ownership
interchangeable to avoid referencing the cabinet decision
of parliament that such land must be used for the
purpose of conservation, hence the current contractual
agreement between SANParks and the Riemvasmaak
Trust including the acceptance of an annual ex gratia
payment – this highlights the need for clarity on land
ownership and the appropriate landuse thereof;
4. While not explicitly forbidden in the NEM:PAA, the
provision of land for infrastructure linked to the
commercial generation of power is not listed as one of
the functions of SANParks and it is therefore questioned if
SANParks is in a position to lease or otherwise provide
rights for power generation infrastructure such as those
contained in the proposed development;
Raised by
April 2015
4. Construction of the project-related infrastructure
across Remainder of farm Waterval No 497 will
require the establishment of a servitude or
servitudes, for which application must be made to
the Department of Public Works. Construction of
the project-related infrastructure on Portion 1 of
Farm Riemvasmaak 498 will require the Applicant
and the Trust to enter into a long term Lease
Agreement. Such an arrangement has been
drafted and currently is being reviewed prior to
approval via a special general meeting of the
Trustees and beneficiaries of the Trust. See
section 2.6 of the EIAR.
5. This issue has been resolved, and has no
significant bearing on the EIA, since a full Scoping
and EIA study is, in any avent, required.
6. SANParks concern about diverting a sizable
portion of the river’s flow from the falls that would
have a negative impact on the visitor experience
to the falls has been assessed. See especially
section 7.3.2, 7.3.7 and 7.4.7. These impacts are
low as a minimum flow regime will be guaranteed.
7. Please refer to Section 3.2 for details on this. The
maximum rate of diversion from the river to the
hydropower station will be 38m3/s. A 7.5m-wide
low-flow slot left of the channel centreline, with a
broad crested profile at level 616.0m, will allow
the agreed environmental flow of 30m3/sec to
pass through the weir structure unimpeded
8. The AFNP Management Plan has been carefully
considered in the EIA process. As explained in
section 2.6 there is no need to change the current
environmental zoning of primitive and remote,
and this is not recommended.
9. This has been noted.
10. Please refer to Chapter 5 of the EIAR for a
discussion on alternatives.
11. The land ownership issues are discussed in
Page 37
No.
Issue
5. The difference of opinion between DEA and the Aurecon
regarding Listing Notice 2 (GN No. R545) of the NEMA
EIA Regulations must be resolved with immediate effect,
rather than just prior to the submission of the final EIA
Report for decision-making;
6. The draft scoping report ignored SANParks concern about
diverting a sizable portion of the river’s flow from the falls
that would have a negative impact on the visitor
experience to the falls – instead, the report confuses this
concern with the visual impact group rather than a
tourism experience which highlight the shortcoming of
the draft scoping report in defining a tourism experience
as merely a visual impact;
Raised by
April 2015
Section 2.6. Chapter 4 discusses the need and
desirability of the project, in accordance with the
EIA regulations.
12. The issues raised here are all comprehensively
discussed in the Faunal specialist study.
13. A Socio-economic and tourism specialist study has
been prepared to deal with this issue.
7. The draft scoping report is silent on the planned volume
of water to be diverted during the low flow period; the
minimum reserve flow is required to maintain ecosystem
integrity whilst an additional amount of volume of water
will be required to provide a heightened tourism
experience at the falls;
8. The revision of an approved Park Management Plan is the
prerogative of the Minister in accordance to NEM:PAA
Section 40 (2), whereas the change of a particular zone
within a National Park is subject to Section 41 (g) of the
same Act compelling SANParks to change such zones
with predetermined conservation objectives and activities
for all the national parks in the country to allow for the
proposed project – the conservation objective is to
maintain remote and primitive zones in as near to a
natural state as possible with no impact on biodiversity
pattern or processes, essentially these areas retaining an
intrinsically wild appearance and character, or capable of
being restored to such and which is undeveloped, there
are no permanent improvements or any form of human
habitation, and provides outstanding opportunities for
solitude with awe inspiring natural characteristics;
Page 38
No.
Issue
Raised by
April 2015
9. SANParks notes that the proposed development is not in
accordance with the spirit of the National Strategy on
Buffer Zones around National Parks;
10.
The draft scoping report uses location alternatives
interchangeable between alternatives sites along the
Orange River versus alternative sites in the country which
limits a proper understanding of what feasibility studies
were done towards alternatives sites for the waterfall, no
indication is given as to where the 12 sites along the
Orange River were located (Ps. both Neusberg and
Boegoeberg are ideal alternative sites to the Augrabies
Falls National Park site which together is likely to deliver
at least 30% of the 75MW allocation for small hydro
stations);
11.
It is a grave concern that the draft scoping report
down plays the status of a National Park with the high
positive social impact that the project will have
(especially for the landowners, i.e. Riemvasmaak
Community), as well as the contribution it will make to
the energy grid in South Africa as the best practicable
environmental option for the proposed site of
development thereby disregarding regrettably the
importance of a National Park and the legal status
thereof;
12.
From a species management point of view, the
scoping report falls short on the importance the park
provides towards the conservation of many species to
this environment, including large breeding colony of birds
nesting in trees along the river and on a small islands
whilst the disturbance of normal riverine habitat and the
interference with the flow and stratum of the river bed
and bank are likely to permanently flood many large
rocks in the vicinity of the weir thereby disturbing a
watercourse that would otherwise have been used as
Page 39
No.
Issue
perching sites for birds such as cormorants which
constitutes a prohibition in NEM:PAA Regulations;
Raised by
April 2015
13.
SANParks submits grave concern about the fact that
the draft scoping report incorporates the impact on
tourism synonymous with the visual impact of the
proposed development and loosely as part of the impact
on the socio-economic environment – the impact on
tourism has merit to be investigated on its own, hence a
separate and additional specialist study will be required.
In anticipation that these comments receive your
consideration it will allow SANParks to optimally manage
Augrabies Falls National Park within the confines of the
regulatory framework for protected areas in the country as
well as international obligations.
43.
Telkom
44.
Good Day Shawn
We acknowledge receipt of your application. Our reference is
CAHS0170-15 for further enquiries in this regard.
Regards, Aletta Gabaitumele, NIP: Wayleave Management
45.
Good Day Shawn,
Attached find our cover letter for your application. Although
we are not affected, Mr. Vivian Groenewald must be
contacted at 054-338 6501 / 081 362 6738 before any
commencement of work
Mantwa
Gabaitumele,
Telkom Wayleave
Management,
2015
Mantwa
Gabaitumele,
Telkom Wayleave
Management,
2015
Dear Mantwa,
Thank you for your e-mail, your commnent are noted.
Sincerely,
Shawn Johnston
Dear Mantwa,
Thank you for your e-mail and attached Telkom letter,
your comments are noted and will be clarified within the
environmental impact assessment.
Sincerely,
Shawn Johnston
Regards, Aletta Gabaitumele
NIP: Wayleave Management
Your letter dated 13 March 2015. I hereby inform you that
Telkom SA SOC Ltd approves the proposed work on your
drawing in principle in terms of Section 29 of the Electronic
Communications Act No. 36 of 2005 as amended.
Page 40
No.
Issue
Raised by
April 2015
Although we are not affected, Mr. Vivian Groenewald must
be contacted at 054 338 6501/081 362 6738 before any
commencement work.
As per supplied sketches it would appear as if Telkom S Ltd
infrastructure would not be affected. However care should be
taken should it become evident that there is in fact Telkom
network present at the actual sites. Such lines should be
treated in accordance with, and clearance stipulated in the
Occupational Health and Safety Act no 85 of 1993, Electrical
Machinery
regulations 20 – Crossings, and Electrical
Machinery Regulations 15 – Clearance of Power Lines. If the
specifications could not be met, all deviations costs will be
for the applicant’s account. We also refer to section 25 of the
Electronic Communications Act 36 of 2005.
Any changes/deviations from the original planning or prior to
construction must immediately be communicated to this
office.
On completion of this project, please certify that all
requirement as stipulated in this letter have been met.
Please note that should any of Telkom SA
SOC Ltd
infrastructure has to be relocated or altered as a result of
your activities the cost for such an alteration or relocation
will be for the account in terms of section 25 of the Electronic
Communications Act.
This approval is valid for 6 months only, after which reapplication must be made if the work has not been
completed.
Please notify this office and forward an as built plan, within
30 days of completion of construction.
Although we are not affected, Mr. Vivian Groenewald must
be contacted at 0543386501/081 362 6738 before any
commencement of work. Should Telkom SA SOC Ltd
infrastructure be damaged while work is undertaken, kindly
call the Toll free number – 0800 203957.
Page 41

Issues and Response Trail - Coastal and Environmental Services

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