Eco Route. Draft Environmental Management Plan for: Leisure Isle Sea Walls ENVIRONMENTAL CONSULTANCY

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1 Eco Route ENVIRONMENTAL CONSULTANCY REGISTRATION NO. 1998/031976/23 DR. COLLEEN EBERSOHN MS. JANET EBERSOHN PhD Univ. Pretoria Bsc. Hons. Environmental Management Cell: Cell: Draft Environmental Management Plan for: Leisure Isle Sea Walls Prepared For: Knysna Municipality Prepared by: Eco Route Environmental Consultancy PO Box 3511 Knysna 6570 Tel/Fax: Contact Person: Ms Janet Ebersohn Dr Colleen Ebersohn

2 Contents 1. Introduction Background Information The Anticipated Construction Activities are as Follows: Implementation of the EMP Environmental Monitoring Committee Environmental Control Officer (ECO) ECO must comply with the following conditions: Environmental Awareness Training For the purposes of this EMP the following definitions and abbreviations shall apply: Environment: Potentially hazardous substance Method Statement The Method Statement shall cover applicable details with regard to: Solid waste Contaminated water Construction camp Working area Contingency Plans Monitorable standards Conclusion Table 1: EMP OBJECTIVES Table 2: Impacts and mitigation measures for: the maintenance of sea walls along Leisure Isle in the Knysna Estuary Table 3: Impacts and mitigation measures for: the operational phase for Leisure Isle proposed Sea wall Compliance with the EMP Site Office Signage Construction Control Access to the Site and Vehicle Control Hours of work Deliveries and removal vehicles Maintenance of Equipment Erosion Control Sand Removal and Stockpiling Limits of construction activity Site presentation and spoiling of excess material

3 7.12 Cleaning of vehicles and equipment Fires Smoking Ablution Facilities Speed Limit Payment of Fines Site clearing after Construction Table 2 Measures to be implemented during the Construction Phase Address Post Storm, Seasonal and Annual Inspections Reporting Mechanism to the competent authority Monitoring reports Pro form method statement for use by contractors Rehabilitation EMP Rehabilitation EMP Terms of Reference: The Vegetation Rehabilitation Plan: (CCA CEMP 2005) General Methodology: Plant Search and Rescue Operations: Seed Collection and Storage: Nursery: Landscaping and Ground Surface Preparation: Irrigation: Weed Disease and Pest Control: Seedlings / Shrubs / Trees: Program and Time Scale:

4 1. Introduction Definition of an Environmental Management Plan EMP: A plan or programme that seeks to achieve a required end state and describes how activities that have or could have an adverse impact on the environment, will be mitigated, controlled, and monitored. Environmental Management Plan. [Retrieved, September 05, 2010, from The EMP consists of various environmental specifications and recommendation in order to achieve the less impacted route to follow. The EMP is aimed at ensuring that the contractor maintains adequate control over the project to minimize the impacts of the proposed project on the receiving environment. The EMP will indicate which measures needs to be implemented to ensure appropriate restoration of areas affected by the proposed project and prevent long term environmental degradation. The contractor must be made aware of the environmental obligations that are stipulated in the EMP. The contractor must declare themselves to be conversant of all relevant environmental legislation, the conditions in the Environmental Authorisation and the EMP. 1.1 Background Information Leisure Isle: the sea walls along Cearn Street, Bollard Bay, Green Hole, Steenbok Park and Landfall Eco Route Environmental Consultancy has been appointed as independent environmental practitioners by the applicant, Knysna Municipality, to ensure compliance with the National Environmental Management Act, 2008 (Act 62 of 2008) for the various proposed stabilisation options along Leisure Isle in the Knysna Estuary. The aim of this application is to prevent further degradation and erosion along various sections of the Leisure Isle sea wall, to identify positive and negative impacts on the receiving environment and to identify the best solution and minimize any impacts on the Knysna Estuary. Fraser Consulting Civil Engineers has been appointed to identify various stabilisation options that would ultimately prevent further erosion along this bank. The Knysna Estuary is rated as the most sensitive estuary in South Africa; in particular for the conservation status of its biota. The refurbishment of stabilising structures within the Knysna Estuary triggers several listed activities in the 2010 Environmental Impact Assessment Regulations as per the National Environmental Management Act (NEMA) with regard to construction occurring within a water course. The refurbishment of the embankment falls within the Garden Route National Park and is indicated on GIS maps as an area designated for conservation use. Over time Leisure Isle has been developed and infrastructure was constructed in order to serve the residential properties in the area. The shoreline of the Knysna Estuary alongside the Island has changed over time due to siltation and erosion processes due to normal estuarine dynamics; including flooding as a result of severe rain storms, and erosion as a result of wave impact on the shoreline caused by westerly winds. 4

5 Of particular concern are portions of Leisure Isle's shoreline that has been subjected to severe erosion to the point where damage to the following infrastructure is prominent: Sea walls along Cearn Drive, Steenbok Park, Green Hole, Bollard Bay and Landfall Leisure Isle, Knysna and is linear in nature. 1.2 The Anticipated Construction Activities are as Follows: Activity Clear vegetation within the construction zone Cut to fill/spoil within the construction zone Dredging Management of storm water runoff Rehabilitate by planting indigenous vegetation Construction zone to be demarcated Contractors camp to be demarcated Overnight areas for machinery to be demarcated. Responsibility of ECO/ Engineer/ Contractor towards The EA and EMP The ECO and Engineer will determine to where the vegetation is to be cleared. Any vegetation removed that can be used for rehabilitation should be placed in the onsite nursery. Knysna municipality needs to be contacted in regard to obtaining water for rehabilitation purposes. 3 months of watering will be required in rehabilitated areas. No vegetation may be cleared outside of the designated working area Refer to Engineers construction design and footprint. ECO to monitor the process to ensure activities are only within the designated areas, ensuring minimal impact on the receiving environment. The ECO and Engineer will determine where dredged material will be stockpiled. Sufficient storm water protection must be provided to protect stockpiles. No dredging to take place after working hours. Refer to section in EMP regarding working days and hours. Install storm water protection in affected areas. ECO to monitor process to ensure minimal impact on the receiving environment. SANParks to provide list of indigenous plants that may be used. Rescued plants from the clearing of vegetation that is stored in the onsite nursery to be used for replanting. Engineer and ECO to determine No GO areas that needs to be demarcated at all times. Notice boards to be placed in strategic areas to warn public of construction activities in progress. Contact details of engineer and ECO should be displayed on the signs. The contractors camp could in all probability be established beneath the big tree in the parking area, this area to be used to store machinery and equipment. ECO should approve the site before establishment. This overnight area to be used to park machinery, the ECO should approve the site before establishment. As per engineers instruction. Drip 5

6 Mixing of concrete Machinery plant Activities Trucks will haul from designated borrow to work/site area. trays to be placed under machinery to ensure no leakage of oils and fuels classed as hazardous material in allocated area. All material used in construction to be prepared in demarcated areas away from the estuary. ECO should approve the site before establishment. Responsibility of ECO/ Engineer/ Contractor towards The EA and EMP ECO ensure all vehicles have the required ORV licences in place. CapeNature or Knysna Municipality will supply the licences. Contractor to ensure drivers stay on designated access areas, stick to the speed limit and that the trucks are in good working condition, no leaking of oil. Fuel to be stored for vehicles in contractor s camp. Fire extinguishers need to be placed in re fuelling and storing area. Contractor to ensure no leaks or spillage of fuel has occurred on site. Contractor to write a contingency plan in case of accidental spillage. The contingency plan to be approved by engineer and ECO and kept on site permanently. In the event of a spill the contractor to advice ECO immediately. 20t excavator in construction zone during the day. No vehicles or workers are allowed on site after 5:00pm. Refer to section in EMP regarding working days and hours. Contractor to indicate how many trucks, back actors and other machinery they will be utilising to excavate the required amount of sand per day/ to move the rock baskets. This information must be supplied to the engineer and ECO. Such vehicles must be out of the construction area at night and parked in the Parking area. The work times will depend on low tide and spring tides. 1.3 Implementation of the EMP The EMP is a condition of approval for this development and as such, the developer and all contractors are bound to comply with the conditions set herein. This EMP is to be submitted for approval to the Department of Environmental Affairs, prior to the commencement of construction and written specifically for the alternative authorized by DEA. A week s notice (in writing) must be given to DEA before commencement of construction. The objective of the EMP is identifying the possible environmental impacts of the proposed activity, and developing measures to minimise, mitigate and manage the negative impacts while enhancing the positive impacts. 6

7 The engineer is responsible for monitoring the compliance of the Contractor to the EMP. To assist the Engineer and to bring environmental expertise to his team, it is required that the Engineer appoints an appropriately qualified environmental professional with expertise in EMPs to act as the Environmental Control Officer (ECO) for the project. The ECO appointed is Eco Route Environmental Consultancy. 1.4 Environmental Monitoring Committee An Environmental Monitoring Committee must be established to oversee the development and compliance of all parties to the EMP. It is suggested that the Committee comprise the following: The Project Engineer (for the duration of the construction phase) The Environmental Control Officer The Manager (from the time that s/he is appointed) A representative of the Municipality A representative of SANParks Two representatives of the Homeowners/ Conservancy associations. 1.5 Environmental Control Officer (ECO) The name and contact details of the ECO must be forwarded to DEA, prior to the commencement of construction activities. The ECO s specific function will be to monitor the Contractor s compliance to the EMP and his impact on the environment and thus help the Engineer in this regard. As per the Environmental Regulations the ECO is required to comply with the conditions set out in the Authorisation (this may change regarding the EA) Give 7 calendar days written notice to DEA before commencement of construction. It is envisaged that the ECO will be on site for the following periods: A site visit or visits at the start of the project for as many hours as required. A site visit or visits at the completion of the project for as many hours as required. Site visits at the start and completion of major portions of the contract as required. A minimum of one visit per week for the rest of the project presuming no major problems. Site visits immediately after any heavy rain, in order to assess erosion and/or sedimentation damage on site. Whenever there is an emergency environmental incident. The ECO should attend all monthly site meetings. The ECO will be responsible for monitoring, reviewing and verifying compliance with the EMP by the Contractor. The ECO s duties in this regard will include the following: Ensuring licenses and permits have been obtained; Monitoring and verifying that the EMP is adhered to at all times and taking action if the specifications are not followed; Monitoring and verifying that environmental impacts are kept to a minimum; 7

8 Reviewing and approving construction method statements together with the Engineer; Assisting the Contractor in finding environmentally responsible solutions to problems; Giving a report back on the environmental issues at the monthly site meetings and other meetings that may be called regarding environmental matters; Keeping records of all activities! Incidents on Site in the Site Diary concerning the environment; Inspecting the Site and surrounding areas regularly with regard to compliance with The EMP; Keeping a register of complaints in the Site Office and recording and dealing with any community comments or issues; Monitoring the undertaking by the Contractor of environmental awareness training for all new personnel coming onto site; Ordering the removal of person(s) and/or equipment not complying with the specifications (done via the Engineer); Issuing of fines for transgressions of site rules (done via the Engineer); Ensuring that activities on site comply with other relevant environmental legislation; Completing start-up, weekly, monthly and site closure checklists; Keeping a photographic record of progress on Site from an environmental perspective; and Undertaking a continual internal review of the EMP and submitting a report to the Engineer at the end of the project. 1.6 ECO must comply with the following conditions: The Eco must adhere to all conditions stipulated in the approved final EMP, as approved by DEA. The Eco must be on site during ANY construction activities that may pose an environmental risk. To review method statements and determine the most environmentally sensitive options of modus operandi for the construction of related tasks, when considered necessary by the ECO. To make on-site decisions regarding any tree or other vegetation removal or retention in consultation with SANParks. The ECO is empowered to order the Contractor to immediately cease any element of the works which contravene with the conditions of the EMP or EA and / or which to be stopped as a matter of urgency in order to prevent serious adverse environmental damage or potential environmental damage of any of the adjacent properties or areas outside the boundaries of the erf, provided that the ECO shall without delay report on such action to the contractor / project manager / owners. Conduct regular site visits during the period of construction (weekly). Review method statements and site development plans prepared by the applicant in compliance with the EMP, and ensure these are sufficient to meet the outcomes required. Engage in regular discussions with relevant authorities on any significant non-compliance by the applicant and the steps to be taken to rectify this. The ECO must report to the relevant authorities on a monthly basis during the construction phase in the form of an environmental management compliance report. The applicant shall ensure that the ECO is on site at any time when construction takes place that could pose an environmental risk A monitoring and auditing programme must be implemented to assess compliance with the conditions stipulated in the EA. Independent specialist s consultants must be called upon when, in the opinion of the ECO or DEA, there is a need for expert opinion during the monitoring of the construction and operational phases. 8

9 1.7 Environmental Awareness Training Education and Monitoring there is a twofold approach in ensuring the compliance on site with regulations as set out in the EA and the EMP. Firstly, it is the responsibility of the appointed ECO to ensure that the contractors and sub-contractors are aware of the acceptable environmental management methods and correct protocol and secondly, the contractor must at some point take responsibility for the actions on site. The education/awareness programme given by the ECO must be aimed at all levels of management within the contractor team and operators of all specialist construction vehicles. This must focus on: Maintenance of the integrity of the environment: promote awareness of the demarcated sensitive areas, the importance of the installation of silt traps for the prevention of erosion, keeping to the identified access points and ensuring that vehicles and any hazardous liquids are kept in suitable identified areas. Waste management: No litter, rubble or any other form of waste must be allowed to build up on or around the construction site. Contractors must be made aware of the need to maintain a clean environment and the responsibility of removing rubble to a formally permitted waste disposal site. Hygiene: all staff on site to be made aware of sanitary requirements in terms of toilet facilities and general waste disposal areas. The monitoring of compliance must be recorded. With respect to the obligations of the contractor, it is important that method statements be prepared and form part of the daily of weekly work plan. 2. For the purposes of this EMP the following definitions and abbreviations shall apply: 2.1 Environment: Refers to the surroundings within which humans exist and that are made up of : a) The land, water and atmosphere of the earth; b) Micro-organisms, plant and animal life; c) Any part or combination of i) and ii) and the interrelationships among and between them; and d) The physical, chemical, aesthetic and cultural properties and conditions of the foregoing that influence human health and well-being. 2.2 Potentially hazardous substance Is a substance, which, in the reasonable opinion of the Engineer, can have a deleterious effect on the receiving environment? 2.3 Method Statement Is a written submission by the Contractor to the Engineer, in response to the specifications or a 9

10 request by the Engineer, in consultation with the ECO. It sets out the plant, materials, labour and method the Contractor proposes using to carry out an activity, identified by the relevant specification or the Engineer (when requesting the Method Statement) in such detail that the Engineer is enabled to assess whether the Contractor s proposal is in accordance with the contract specifications and whether it will impact negatively on the environment. The Engineer must approve any Method Statements in consultation with the appointed ECO. 2.4 The Method Statement shall cover applicable details with regard to: Method statements need to be completed by the person who will undertake the work (contractor). The Method statement will enable the negative environmental impacts associated with the proposed activity to be assessed. Method statements need to be compiled and approved prior to any activity occurring on site. It is recommended that the contractor completes and submits his mission statement 14 days after he has received an acceptance letter for the project. The method statement can only be implemented once approved by the ECO. The contractor must also sign the method statement indicating that all operations will be carried out according to the method statement ensuring the least impacted environmental path followed. The ECO will review the method statement as it will give the ECO and indication of how work will be conducted to prevent environmental damage. The ECO might amend the method statement and require the contractor to sign the amended method statement. The ECO uses the method statement to audit compliance by the contractor with the requirements of the method statement. This is an effective method as the method statement should cover all required implementation of the EMP. The method statement should cover construction procedures, materials and equipment that will be used during construction of the proposed project. The method statement needs to elaborate how equipment will be bought to site and removed from site. It must also stipulate where the equipment will be placed and stored on site, and how the equipment will be moved around on site. The method statement needs to highlight how material will be stored on site, especially hazardous material. The method statement will indicate precaution methods to avoid spills and leaks of hazardous material and indicate remedy actions to take in case of an accidental spill. It is important that the method statement indicates the timing and location of activities, this will ensure that the ECO can do site visits at the appropriate times, making this a very effective method to use to ensure compliance with the EMP. 2.5 Solid waste Is defined as all solid waste, including construction debris, chemical waste, and excess cement. Concrete, wrapping materials, timber, tins and cans, drums, wire, nails, food and domestic waste (e.g. plastic packets and wrappers). 2.6 Contaminated water Means water contaminated by the Contractor s activities, e.g. concrete water and runoff from plant! Personnel wash areas. 10

11 2.7 Construction camp Means the area designated for all temporary site offices, storage sheds and areas, parking areas, maintenance workshops, staff welfare facilities, accommodation, etc. 2.8 Working area Means any area within the boundaries of the Site where construction takes place, including any working space. 3. Contingency Plans A contingency plan is a plan devised for a specific situation when things could go wrong. Environmental damage that occurs as a result of the project needs to have contingency plans in place on how to address the situation and which remedial actions need to be incorporated to avoid further damage to the receiving environment. Contingency plans are very effective mechanism in the EMP, as immediate action can take place if environmental damage occurs. An example would be a spill of hazardous goods onto soil, or in water bodies. The contingency plan will identify remedy actions and steps to take. The contingency plan should be in place prior to any activities occurring on site and the contractor must be made fully aware of these plans. This will save time in trying to determine what to do and immediate action can be taken. Contingency plans should highlight and be developed according to predicable different crisis that may result and effect the environment in a negative manner. These include natural hazards such as floods, tidal waves and veld fires to name a few. Technological hazards such as the breaking of equipment, or leaking of equipment. A contingency plan must be in place should Red Data Fauna or Flora be found on site, or if heritage or cultural or historic items are discovered on site. Should erosion be present on site, due to the project construction or operation a contingency plan should be in place to remedy the action and process. The contingency plans should be developed with the ECO and the building / demolition contractor prior to any activity taking place. 4. Monitorable standards Environmental monitoring provides feedback about the actual environmental impacts of a project. Monitoring results help judge the success of mitigation measures in protecting the environment as stipulated in the EMP. Without monitoring there is no mechanism for evaluating the success of the mitigation measures undertaken. Environmental monitoring provides important information that allows for more effective planning and an adaptive response based on an assessment of the effectiveness of mitigation measures. Standards need to be set that can be monitored, throughout the process. This is an effective mechanism to ensure that the mitigation methods are adhered to in the EMP. The ECO will be required to monitor these 11

12 standards on a regular and continuous basis. The Eco will be required to report back on these standards and there implementation. The EMP must state which action must be taken to ensure the mitigation method is adhered to including how often it is required for the action to occur. An example would be ensuring that all building materials remain within the footprint determined within the site. This will require monitoring when materials are delivered and continuous monitoring during the construction phase. Another example would serve to the mixing of cement on site. A certain dedicated area must be demarcated for this activity and can be monitored every time; cement is required during the construction phase. 5. Conclusion To ensure the success of the EMP mechanism are put in place to prevent environmental damage. These mechanisms ensure that a contractor complies with the EMP. Any mechanism used to ensure compliance with the EMP, can be regarded as effective, as awareness, responsibility and understanding is created for the contractor and site staff. Environmental awareness training should be a continuous process during the project and copies of the EMP and other relevant documents should be on site at all times to ensure environmental protection at all costs. The ECO plays an important role in ensuring that the EMP is adhered too and should be involved in site meetings, construction meetings and be on site on a regular basis. Table 1: EMP OBJECTIVES Performance Objective(s) Site Establishment: Demarcation of construction zone and contractors camp Demarcation of no-go areas Demarcation must remain effectively in place for the duration of the construction activities All access routes and storage areas to be identified and approved by the ECO Dangerous areas are to be cordoned off to prevent injury All materials and equipment stored in the contractors camp All equipment stored, serviced and refuelled in contractors camp Fuels and flammable materials must be stored in the contractors camp and comply with fire safety requirements All existing services are to be identified to avoid damage Appropriate Use of Machinery: Machinery must be used appropriately for the task at hand Oil/Fuel leaks to be repaired immediately as identified Machinery must be maintained in an acceptable state of repair 12

13 All spills to be reported to the ECO immediately Protection of natural features: All construction activities to be undertaken within the identified and demarcated work and storage areas ECO to perform a site walkthrough prior to any vegetation removal to undertake plant rescue No wild animals trapped, killed or otherwise disturbed Excavations and Dredging: All major earthworks with heavy machinery to be undertaken under constant supervision Spoil material from excavations must be securely stockpiled to avoid wind erosion and surface runoff Anti-erosion and storm water control measures must be applied in all exposed areas Anti-erosion measures must be implemented in anticipation of heavy-rainfall events Waste management: No contaminated effluent from construction site should enter natural watercourses Reduction, re-use, recycling and disposal to be practiced where appropriate Construction related waste to be securely stored against wind dispersal Adequate refuse bins and daily refuse collection to be ensured Wind and animal-proof refuse bins to be used Solid waste to be suitably disposed of on a weekly basis, or as necessary Site management: Construction activities will be limited to within normal working hours No fires inside the construction area Adequate fire-fighting equipment on site ECO must be informed immediately should any archaeological or heritage resources be uncovered during construction phase Educate all site staff on environmental impacts and mitigation measures. 13

14 Enforce legislation and regulations The ECO must keep compliance and non compliance records and made available to the relevant authorities within 5 days of receipt of this request. Any complaint from the public during construction must be adhered to as soon as possible to the satisfaction of the parties concerned Management Strategies Tasks Responsibilities Performance Indicators Frequency or Time The performance objectives above will be achieved by the following management strategies: ECO on site EMP on site for easy referral Avoid and minimize impacts Ensure that all relevant licenses are in place Ensure all relevant parties are aware of impacts Enforce applicable legislation Regularly monitor and report proceedings on a monthly basis Adhere to legislation and EMP Report any non compliance Regular monitoring of activities. The ECO to compile a weekly monitoring report and keep a photo journal. The contractor/s to submit a method statement on how the work will be carried out to the ECO. Environmental training for all labour staff / contractors on site. Demarcate no go areas. Ensure safety measures are implemented and adhered too. This EMP will be the responsibility of the property and the facilities management division. The actions outlined in this plan are the responsibility of Knysna Municipality & Facilities staff where applicable. The ECO to ensure compliance of the conditions set out in the EA and the EMP and report any non compliance. Visible damage to the receiving environment. Time schedules and programs. Adherence to legislation, regulations and EMP. Co-operation from contractors, site staff and personnel Weekly reports from ECO According to the Time Schedule Monitoring and Reporting Monitoring Activity Compliance with EA Compliance with conditions Responsible Agent 14 Time Period Reporting Method ECO Weekly Monthly report ECO Contractor Weekly Daily Record of site

15 of the EMPR Compliance with approved method statements ECO Contractor Weekly Daily visits Site diary Complaints register Start-up, weekly, monthly and site closure checklists Photographic records Monthly reports Specialist studies to be conducted when required and adjusting reports as required throughout the process. Reporting and advising relevant personal of new discoveries of relevant information immediately. A weekly environmental report to be completed by the ECO Monthly monitoring report to be submitted to relevant authorities Failure to comply Issuing of fines removal from site Suspending all activities Table 2: Impacts and mitigation measures for: the maintenance of sea walls along Leisure Isle in the Knysna Estuary. Element of the Environment Geographical and physical environment Impact Description Impact on Significance and probability of the impact before mitigation Relatively high turbidity is expected to be created in the vicinity of the construction area. The dredging of bottom sediment has the possibility to release dissolved or absorbed chemicals into the water. Some pollutants are expected to be released into the Estuary and will Water Quality and aquatic organisms. High Actions proposed in mitigation of impacts Placing barriers along the work area within the Estuary. Removing all dumped materials on a daily basis. Stock piling materials (eg sand) that can be re used on dry land, which will not be affected by tides or storm Significance and probability of the impact after mitigation Low 15

16 Biological Impact Vegetation Mud Prawn Socio Economic subsequently result in a drop in the dissolved oxygen level, which would create lethal conditions for some marine biota. Pollution from construction material Impact on areas providing habitat for estuarine and marine ecosystems Dredging or excavating may in all probability disturb the current seed bank present in the estuary. Disturbance of mud prawn breeding sites Disturbance to people living, walking along Cearn Drive, Steenbok Park, Green Hole and Bollard Bay, and using the lagoon for fishing, boating and swimming. Impacts associated with general construction noise Impact on benthic and other estuarine species Impact on Macrophytes High Medium water flow. Working hours should only be permitted at low tide and spring tides. Rainy days dredging and excavation to be prohibited on site. All material used in construction to be prepared in demarcated areas away from the estuary Placing barriers around the work area will also minimize the impact. The top 15cm of sand excavated needs to be stored separately for re-use during rehabilitation. Mud Prawn Low No excavation between the months of July and October Residents, tourists and people using Knysna Estuary for recreational purposes. High Construction work and noise generation only allowed during weekday working hours. No construction is recommended during holiday periods Medium Low Low Medium 16

17 Table 3: Impacts and mitigation measures for: the operational phase for Leisure Isle proposed Sea wall Element of the Environment Geographical and physical environment Impact Description Increased erosion in adjacent areas which do not have sea walls Impact on Sea wall structures Significance and probability of the impact before mitigation High Actions proposed in mitigation of impacts Placement of stone ballast revetments at the ends of each sea wall Significance and probability of the impact after mitigation Low Biological Impact Disturbance of biota during periods of maintenance work Disturbance of estuarine habitat and various estuarine species High Maintenance work should be kept to an absolute minimal to ensure that the disturbed ecological system has sufficient time to recover. In other words should maintenance work be required ensure that all work is done simultaneously to prevent continues disturbance of the ecological area. Low Noise Visual Maintenance work may generate a degree of noise Sections of the sea wall will be visible from the Estuary Residents, tourists and people using Knysna Estuary for recreational purposes. Residents, tourists and people using Knysna Estuary for recreational purposes. Low Low Noise to be limited to weekdays and working hours. The re-planting of vegetation above sections of the sea wall. Low Low 1. A Maintenance Management Plan must be compiled in conjunction with the appointed Engineer for the alternative authorised in the Environmental Authorisation. 2. The Maintenance Management Plan must be sent to all commenting authorities for comments. 17

18 3. The Maintenance Management Plan must be approved by DEA. 4. The Maintenance Management Plan is a living document, should any changes be made to the Maintenance Management Plan all commenting authorities need to be notified. 6. Compliance with the EMP This EMP is regarded as a legal and binding document that needs to be adhered to. Failure to comply with this document can result in written warnings and ultimately after 3 written warnings for transgression by a specific labour, that labourer can be asked to be removed from site. Fines will be issued in regards to failure of compliance and the proceeds collected to be used for the rehabilitation of the site. Should any money be left over after the rehabilitation, the money will be donated to a registered environmental organisation. The fines will be determined by the developer, the project manager, SanParks, Knysna Municipality and the ECO, and will be included in the method statements that are required to be completed by the contractors after environmental awareness training Site Office There must be a single site office terrain for use by all contractors involved in each phase of the development. Areas need to be demarcated for the storing of vehicles, machinery and equipment overnight as none of the above will be permitted to remain on the beach or the burrow area after 5:00pm. Fuel and oil to be stored in demarcated area in site office, Fire extinguishers need to be placed in close proximity to fuel. Drip trays to be used when refuelling of vehicles to prevent spillage. 7.2 Signage The Estuary is used by the general public on a regular basis, in order to inform them on construction occurring on the sea walls. Members of the public must be directed to alternative access points and recreational areas. The engineer and ECO contact details must be displayed on all signage. 7.3 Construction Control The movement of vehicles on the site must be confined to the defined access routes. No unnecessary disturbance to vegetation outside of the demarcated areas. Due to a potential fire hazard, no open fires will be allowed on the site. The contractor shall ensure that all waste generated during the construction phase is collected on a daily basis and stored securely at an approved area until it is removed from the site and disposed of at a designated waste site. Reduction, re-use, recycling and disposal to be practiced where appropriate Speed limits of construction vehicles need to be adhered too. Method statements must be completed on a weekly basis and submitted to ECO prior to commencing of activities. 18

19 7.4 Access to the Site and Vehicle Control Access and movement of construction vehicles is to be limited to existing access routes. Any deviation, where absolutely necessary and for whatever reason, must first be approved by the ECO, in consultation with the site engineer. ORV licences must be obtained for all vehicles/ back actors entering the ORV designated area. These ORV licences must be kept on site at all times. Access to the area is to be monitored during the construction phase. A constant regard must therefore be taken to safety. Dangerous areas must be adequately cordoned off to prevent accidental injury. All site personnel and site visitors to wear safety gear: Hard hats Safety shoes Safety vests A sign needs to be erected at the entrance of the site indicating safety measures to be adhered to prior to entering the site. 7.5 Hours of work Coastal works are affected by limited work windows. Seasonal conditions often restrict work to the spring and autumn: in winter the weather may be too harsh and the days too short, while in summer work may disrupt recreational use of the beach. Daily tidal cycles will restrict work below the high tide line. Other restrictions may be imposed by natural events such as bird nesting or migration, or by optimum seasons for vegetation transplanting. Each site will have its own set of restrictions, and these may well influence decisions on the initial scheme or the long term management options. It is suggested that construction work only commences if the mouth is open. It is best to avoid construction work during July to October and December to March to protect the mud prawn breeding season. No work allowed on Saturdays, Sundays or Public Holidays/ School Holidays. Should the contractor be required to work over these periods written permission must be obtained from the ECO, SanParks, Knysna Municipality and the Engineer. 7.6 Deliveries and removal vehicles Contractors will at all times be responsible for the compliance of delivery and removal personnel with the contents of this agreement. The contractor shall ensure that all delivery and removal times will be limited to the times defined as working hours. The contractor shall ensure that the size of the delivery vehicle is limited to those that can be accommodated by the existing roads on site. The position of delivery points must be indicated on the site diagram approved by the ECO. The delivery of sand or rock has the potential to cause the most damage to the road surfacing and vegetation. It is therefore important that these deliveries are handled in an environmentally sensitive way. The contractor shall ensure that the drivers of these trucks are briefed on the conditions of this document. 19

20 Drivers found to be contravening the EMP will be escorted off site and refused further access to the site. The contractor will be liable for penalties incurred by a delivery vehicle. The contractor will be fined a set amount agreed to by all authorities. 7.7 Maintenance of Equipment All mechanical equipment and work vehicles which may be kept on site are to be stored, only at designated areas within the contractor s camp. Within these areas drip trays and other materials are to be used to prevent contamination of the ground in any way. The Resident Engineer or the ECO may order the removal of equipment that is causing continual environmental damage from leaking oil or diesel for example, until such equipment has been repaired. 7.8 Erosion Control Erosion control measures must be implemented as a matter of course and the use of erosion berms, silt traps (anchored bidem cloth curtains) and sand bags is essential in all exposed areas where there is a risk of degradation to natural drainage lines on the property. Should any erosion be detected on site, the ECO and site engineer must identify the cause of such erosion and ensure that the most appropriate method of mitigation or stabilisation is employed as soon as possible. In the case of general exposed road edges, a suitable organic mulch together with a fast-establishing grass seed can be applied at an early stage to exposed areas. It is envisaged that the following indigenous grass species could be made use of: Eragrostis curvula (oulandgras) Cynodon dactylon (kweekgras) Seed must be applied immediately after disturbance while the soil is loose and then covered with at least a 5cm layer of mulching material in order to keep the seed moist. 7.9 Sand Removal and Stockpiling Following vegetation clearance from areas in which road access and construction is to take place, the top 15cm sand is to be removed and stockpiled, where at all possible, for later use during rehabilitation of disturbed areas Limits of construction activity All activities relating to the construction must be confined to within the designated footprint and boundaries where the works are to be executed. It is the responsibility of the Contractor to ensure that his personnel remain within the demarcated areas of the estuary on which they are working. Workers and equipment need to stay clear of no-go areas. The contractor will be fined a certain amount per transgression as determined by the authorities involved in the process. 20

21 7.11 Site presentation and spoiling of excess material The contractor shall keep the appearance of the construction area neat and tidy at all times to the satisfaction of the ECO and relevant authorities. Rubble must be removed from the daily to an approved waste disposal site. Refuse drums must be supplied for the purpose of storing refuse until removed from the construction area by the contractor. Should the contactor fail to remove litter within a specified timeframe after receiving written notice to this effect, the rubble will be removed by an outside contractor. The costs of this outside contractor shall be paid by the developer and reclaimed from the contractor. The contractor will be denied access to the property until such costs have been paid in full. In addition to this the contractor will be fined an additional amount per offence. General waste during the construction phase is the responsibility of the contractor. Refuse such as rubble, cans, plastic, wire, etc. generated during the execution of the works should be stored in an appropriate area on site, protected against wind dispersion and removed on a daily basis for disposal at a permitted waste disposal site. No burying of refuse on site will be allowed, and a fine of pre determined amount will be issued per transgression. If construction workers are allowed to eat on the development site, other than within the contractor s camp, the contractor shall provide adequate refuse bins at all such places and ensure that they are used. The contractor must ensure that all structures, equipment, materials and facilities used on site are removed once the project has been completed Cleaning of vehicles and equipment The washing of contractor vehicles and equipment is not permitted on the site. The contractor will be fined prescribed amount per offence Fires No fires will be allowed on any part of the beach or estuary. The contractor is to provide at least six fully operational fire extinguishers, which must be on site at all times. The builder will be fined R per offence of not having the fire fighting equipment on site and in a working order. The contractor will in addition be held legally and financially responsible for any damaged caused by a fire resulting from employee negligence Smoking The contractor shall ensure that his employees do not smoke on the site except in a designated site within five-meter radius of a portable fire extinguisher. The contractor will be fined R per incident by any member of his team. 21

22 7.15 Ablution Facilities It is recommended to provide one portable toilet for every 8 site employees. This should be serviced on a regular basis and records must be kept of all services of the ablution facilities Speed Limit For security and safety reasons the speed limit on the beach and roads will be 20km/h. The contractor is to ensure that the speed limit is adhered to. The contractor will be fined a pre-determined amount per transgression Payment of Fines All monies owed to the developer regarding fines need to be settled by the Monday following the fine. The developer will keep a separate management record for these fines and ensure that monies from the fines are used to repair environmental damage only. In the event of a contractor failing to pay the fine in time the builder will be denied access onto the property Site clearing after Construction All construction material, spoil and equipment are to be removed from site within two days of completion of the embankment. The ECO is to check the site and sign a site clearance form, indicating that the site clearance has been satisfactorily undertaken. Final payment to the contractor will only be made once this site clearance is signed. Table 2 Measures to be implemented during the Construction Phase Action Task Technique Responsibility Identification of site boundaries, Submission of topographic map. Topographic map indicating site access points, location of temporary facilities and storage of equipment. Topographic map indicating no go areas on the site. Engineer Vehicle checks Ensure no leaking Contractor vehicles or vehicles with sediment stuck on wheels permitted on site. No washing of vehicles permitted on site. Site access. Controlled access is Contractor 22

23 Construction Rubble. Noise Pollution. required to ensure public safety. Machinery used must be equipped with the latest sound reduction technology. To be removed on a daily basis from site Construction will take place during daylight working hours and during the week. Contractor / Project Manager. Contractor / Project Manager. Contractor Storage Facilities. General site facilities and administration area. Identification for tool storage area. Materials exposed after excavation. Protective clothing. Labour Shelter for bad weather. Transport to and from the site. Protection from weather, check for oil and fuel leaks on a regular basis. Spray with water depending on the weather conditions to prevent the spread of dust particles. Set up erosion control barrier around stockpiles to manage storm water runoff. All site staff to have steel tipped shoes and protective hats. To wear any required protective gear when operating machinery. Make use of local labour staff. One general area to be provided. No construction work permitted in rainy weather. Safe, reliable transport, to access site only at access point. No walk 23 Contractor Contractor Contractor Contractor/ Project manager Contractor/ Project manager. Contractor.

24 Environmental considerations through suburbs or along the estuary will be permitted. First Aid. First aid kits on site, and emergency procedures should be implemented. Toilet facilities. 1 toilet for every 8 labourers to be provided. Demarcated area for lunch. Method Statements. Environmental training. Environmental Monitoring. Licences Bins, benches and potable water for washing hands should be provided. Will be written and submitted to the ECO The contractor, all labour staff and new staff appointed must complete an environmental training lecture. On a weekly basis and when major construction will occur the Eco must be present on site and complete an environmental feedback report. Directly after heavy rain or storm surges. After every reported environmental emergency. Ensure all correct and valid licenses are in place to ensure compliance with environmental legislation. Contractor/ Project manager. Contractor / Project manager. Contractor/ Project manager. Contractor. ECO ECO ECO/ Project manager. Comply with health, safety and environmental legislation Regular updates on training personnel, and meetings between management and the ECO. 24 ECO/Project Manager.

25 Waste Management Solid waste Sorting on site will be encouraged to separate recyclable waste from solid waste. Solid waste to be transported to a licensed landfill site. Contractor/ Project Manager 8. Address Post Storm, Seasonal and Annual Inspections. It is recommended that a minimum of four environmental audits be completed a year to ensure no degradation of the new embankment and degradation of the environment has occurred. 4 Environmental Audits per year at the start of each season Site visit by ECO after major storms Reports to be compiled and submitted to DEA The auditing reports must address the success of the maintenance programme. This aspect should be utilised to inform recommendations regarding the improvement of the structure, maintenance methods and reporting. 8.1Reporting Mechanism to the competent authority Monitoring reports 1. A report in the form of a checklist will be filled in after each site visit by the Environmental Control Officer, as to the compliance of each activity. Please see example attached. 2. An Environmental Monitoring Report will be compiled after each site visit, which will include the compliance rating of each activity, and will also include photographs and a brief description of each activity. Please see example attached. 3. Method Statements will be obtained from the Building Contractor/sub-contractors and will be included in each report to the competent authority. Please see example attached. 4. All the above will be sent to the competent authority on a monthly basis. 1. Definition of terms that will be used in this report Detection: A small or potential problem that might not, in the judgment of the Auditor, be a serious to detrimental impact to warrant the raising of the non-compliance, but is serious enough to state on record. Non-compliance: A non-reaction or the non-fulfillment of specified requirements and requests made by the Auditor. 25

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