INTRODUCTION SECTION 24G PROCESS

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1 PROJECT: Section 24G application to authorise the continued storage and processing of building waste on a portion of the Remaining Extent of Portion 16 of the Farm Lombardy 36-IR, Cnr London Road and N3, Modderfontein. APPLICANT: Rubble Tech (Pty) Ltd EAP: Umhlaba Environmental Consulting CC DATE: September 2013 PURPOSE OF THIS DOCUMENT Provide an overview of the section 24G application. Invite Interested & Affected Parties (I&APs) to participate in the process. INTRODUCTION Building rubble has been illegally tipped onto the property in question from unknown contractors during various development projects from surrounding areas. Over time building waste has accumulated on this site and become an illegal dumping ground. The lessee of the property subsequently made an agreement with Rubble Tech (Pty) Ltd to remove the waste and clean up the site and such activities of processing the waste material began in June Section 20(b) of the National Environmental Management: Waste Act (NEM:WA), Act No. 59 of 2008 states that no person may commence, undertake or conduct a waste management activity except in accordance with a waste management license issued in respect of that activity. Rubble Tech was unaware that building material of this nature was considered to be waste due to the un-contaminating nature of the material (mostly excavated earth). By the time Rubble Tech learned that these activities (i.e. processing or recycling waste) being conducted were triggered waste activities, they had already commenced with their operation. Rubble Tech has decided to apply for rectification of the unlawful storage and processing of building waste in terms of Section 24G of NEMA, Act No. 107 of 1998, as amended and obtain authorisation in terms of Section 19 of the NEM:WA, Act No.59 of 2008 for the associated listed waste activities in GN R 718 of 3 July Currently all operations have ceased until the application process has been completed. SECTION 24G PROCESS A Section 24G application is a process of rectifying illegal activities and obtaining the relevant environmental authorisation. The main role players in the process include: Applicant: Rubble Tech. Environmental Assessment Practitioner (EAP): Umhlaba Environmental Consulting CC. Interested & Affected Parties (I&APs): Any member of the public; property landowners and adjacent occupiers, including residents associations and other organs of state. Competent Authority (CA): Gauteng Department of Agriculture and Rural Development (GDARD). Rubble Tech is the applicant responsible for undertaking the activities pertaining to the Section 24G Application. The EAP is responsible for carrying out the Section 24G Application Process including public participation, communicating with I&APs as well as compiling and submitting the Environmental Assessment Report (EAR). I&APs include a realm of members of the public or stakeholders that may have a particular direct or indirect interest in the project such as business, financial or personal concern or as a result of the application or are affected in some way. I&APs are encouraged to participate in terms of a public participation process. The GDARD is responsible for making a decision on the Section 24G Application and will within 60 days from the date of receipt of the information contained in the Environmental Assessment

2 Report (EAR), review the submitted information and, thereafter inform the applicant in writing of the rejection of the report or re-request any outstanding information that the Department deems necessary and relevant for processing of the application. Should there be no communication in this regard, it is considered that the report has been accepted and the GDARD will continue with the next step of eth Section 24G Process, which is to issue and administrative fine. Such administration fine may not exceed 1 Million Rand (R1, 000,000). LOCATION The area where the abovementioned activities were taking place is illustrated in Figure 1, located within the local municipality of the City of Johannesburg, on a portion of the Remaining Extent of Portion 16 of the Farm Lombardy 36-IR, Corner of London Road and N3, Modderfontein. LISTED ACTIVITIES The following activities identified in terms of GN R 718 of 3 July 2009 have been conducted on site since June 2011 and explanation of why this activity has been contravened is provided further: Storage of Waste: Activity 1: The storage including the temporary storage of general waste at a facility that has the capacity to store in excess of 100m 3 general waste at any one time, excluding the storage of waste in lagoons. capacity of the site, whereby the site has the potential capacity to store in excess of 100m 3 at any one time. It must be noted that the capacity in this case refers to the size of the land and the ability of the land to store materials in excess of one hundred cubes and does not refer to the capacity of any particular facility as such. Reuse, Recycling and Recovery: Activity 5: The sorting, shredding, grinding or bailing of general waste at a facility that has the capacity to process in excess of one ton of general waste per day. recycling/re-use (processing) of material (earth, rock, rubble) whereby the facility has the processing capacity of more than one ton/day. Activity 7: The recycling or re-use of general waste of more than 10 tons per month. recycling/re-use (processing) of material (earth, rock, rubble) whereby the quantities may exceed one ton/month. Disposal of Waste: Activity 14: The disposal of inert waste in excess of 20 tons and with a total capacity of tons, excluding the disposal of such waste for purposes of leveling and building which has been authorized by or under other legislation. disposal of inert waste (in excess of 25 tons in total) whereby the associative contractors have not been authorized in terms of any other legislation to dispose of the aforesaid waste at this site and is considered illegal as Rubble Tech has accepted the disposed waste for the purposes of processing and recycling into saleable product(s). However it must be considered that this does not apply to the historical waste that was previously disposed of prior to Rubble Tech occupying the site. Activity 15: The disposal of general waste to land covering an area of more than 50m 2 but no less than 200m 2 and with a total capacity not exceeding tons. size of the land where the area covered by waste exceeds 50m 2. PUBLIC PARTICIPATION PROCESS The role of an I&AP is to: Register with the EAP, who will include you on a database called the I&AP Register in order for you to receive future project information and/or formally record issues and concerns (comments). Access project information that is made available to you in order to provide feedback within the required timeframe. Communicate with the EAP to raise your comments in order that they can be included and addressed within the BAR. CONTACT US Please contact Candis Lubbe of Umhlaba Environmental Consulting to raise your queries, comments or concerns at: Tel: Fax: candis.umhlaba@telkomsa.net PO Box , Fairland, 2030 Website: A comment sheet is attached at the end for your use. Please ensure that you provide us with your name, contact details and interest in the project.

3 London Road A Portion of RE of Portion 16 of Lombardy 36-IR Rubble Tech (Pty) Ltd Pure Magic Compost cc N3 Figure 1: Location of Rubble Tech (Pty) Ltd on a portion of the remaining extent of Portion 16 of the farm Lombardy 36-IR.

4 Figure 2: Location of Rubble Tech (Pty) Ltd on a portion of the remaining extent of Portion 16 of the farm Lombardy 36-IR.

5 COMMENT FORM Title: Mr Mrs Ms Miss Name: From: Contact Details: Tel: Cel: Fax: Postal: Interest in the Project: Mark with (X) Business / Finance Residential General Interest Other Specify: Legal / Process Neighbour Comments / Concerns / Suggestions (attach additional pages if necessary): Attention: Candis Lubbe candis.umhlaba@telkomsa.net