APPENDIX H ENVIRONMENTAL MANAGEMENT PROGRAMME

Transcription

1 APPENDIX H ENVIRONMENTAL MANAGEMENT PROGRAMME

2 Draft PROPOSED ROADS AND STORMWATER INFRASTRUCTURE FOR SOSHANGUVE BLOCK L, CITY OF TSHWANE METROPOLITAN MUNICIPALITY ENVIRONMENTAL MANAGEMENT PROGRAMME (EMPR) AND REHABILITATION PLAN MARCH 2019 DRAFT PREPARED FOR: BIGEN AFRICA SERVICES (PTY) LTD

3 Draft Table of Contents 1 PURPOSE OF THE DOCUMENT DOCUMENT ROADMAP PROJECT OVERVIEW Project Background and Motivation Project Location Technical Information ENVIRONMENTAL ASSESSMENT PRACTITIONER LEGISLATION AND GUIDELINES CONSIDERED Overview of Legislation National Environmental Management Act, National Water Act (Act No. 36 of 1998) (NWA) The National Environmental Management Waste Act (Act No. 59 of 2008) ROLES AND RESPONSIBILITIES GDARD Project Proponent Environmental Control Officer (ECO) Contractor s Environmental Officer (EO) MONITORING Compliance Monitoring ENVIRONMENTAL TRAINING AND AWARENESS CREATION ENVIRONMENTAL ACTIVITIES, ASPECTS AND IMPACTS Environmental Activities Potential Significant Environmental Impacts SENSITIVE ENVIRONMENTAL FEATURES IMPACT MANAGEMENT i

4 Draft 11.1 Environmental Principles Pre-construction Phase Construction Site Planning and Layout Environmental Awareness Creation Specialised Environmental Investigations Safeguarding of Existing Services and Infrastructure Ongoing Consultation with Community and Affected Parties Construction Phase Site Clearing Site Establishment Management of Construction Camp and Eating Areas Management of Ablution Facilities Management of Workshop and Equipment Fencing and Barricades Management of Labour Force Management of Health and Safety Management of Emergency Procedures Management of Access and Traffic Management of Waste Management of Storage and Handling of Non-Hazardous Material Management of Pollution Generation Potential Management of Topsoil Management of Erosion Potential Management of Excavations Management of Visual Aspects Management of Flora Management of Fauna Management of Archaeological and Cultural Features Management of Water on Site Management of Watercourses Management of Rehabilitation Operational Phase Routine Maintenance Inspections and Repairs Ongoing Consultation with the Community Pollution Control Measures ii

5 Draft 12 REHABILITATION PLAN Objectives of Rehabilitation Plan Rehabilitation of Construction Camps and Storage Areas Rehabilitation of Construction Area General Rehabilitation Measures Soil Preparation Site Clearance Excavation Topsoil shaping Ripping and scarifying Grassing Die back Maintenance and monitoring Control over noxious, invasive and problem vegetation Rehabilitation of the Wetland Areas MAINTENANCE AND MONITORING List of Tables Table 1: Document Roadmap Table 2: EMPr core team members Table 3: Environmental Legislative Framework Table 4: Listed activities for the Proposed Roads and Stormwater Infrastructure for Soshanguve Block L Table 5: Activities associated with the Pre-construction Phase Table 6: Activities associated with the Construction Phase Table 7: Activities associated with Operation Phase Table 8: Potential significant environmental impacts Table 9: Potential Significant Environmental Impacts during Operation Phase List of Figures Figure 1: Provincial and local municipality map Figure 2: Main places surrounding the proposed project site iii

6 Draft Figure 3: 1: Topographical Map Figure 4: Sensitivity Map Figure 5: Mitigation Hierarchy Figure 6: Location for erosion mitigation features (The Biodiversity Company, 2019) iv

7 Draft List of Abbreviations BA Basic Assessment CA Competent Authority DEA Department of Environmental Affairs DWS Department of Water and Sanitation EA Environmental Authorisation EAP Environmental Assessment Practitioner ECO Environmental Control Officer EIA Environmental Impact Assessment EMPr Environmental Management Programme EO Environmental Officer GA General Authorisation GDARD Gauteng Department of Agriculture and Rural Development GN Government Notice IAP Interested and Affected Party km Kilometer m Meter MSDS Material Safety Data Sheets NEMA National Environmental Management Act, 1998 (Act No. 107 of 1998) NWA National Water Act, 1998 (Act No. 36 of 1998) PHRAG Provincial Heritage Resources Authority for Gauteng RE Resident Engineer WUL Water Use License WULA Water Use License Application - v

8 Draft Definitions Auditing Environment Environmental Aspect Environmental Authorisation Environmental Feature Environmental Impact Environmental Impact Assessment (EIA) Environmental Management Programme (EMPr) Environmental Objective Environmental Target Floodplain A systematic and objective assessment of an organization s activities and services conducted and documented on a periodic basis. The surroundings in which humans exist and which comprise: The land, water and atmosphere of the earth. Micro-organisms, plant and animal life. Any part or combination of a) and b) and the interrelationships among and between them. The physical, chemical, aesthetic and cultural properties and conditions of the foregoing that can influence human health and well-being. Those components of the company s activities, products and services that are likely to interact with the environment. The written statement from the relevant environmental authority in terms of the National Environmental Management Act (Act 107 of 1998), with or without conditions, that records its approval of a planned activity and the implementation thereof and the mitigating measures required to prevent or reduce the effects of environmental impacts during the life of a contract. Elements and attributes of the biophysical, economic and social environment. The change to the environment resulting from an environmental aspect, whether desirable or undesirable. An impact may be the direct or indirect consequence of an activity. The process of examining the environmental effects of a development in terms of the National Environmental Management Act (Act 107 of 1998) and the Environmental Impact Assessment (EIA) Regulations. A detailed plan of action prepared to ensure that recommendations for enhancing positive impacts and/or limiting or preventing negative environmental impacts are implemented during the life-cycle of a project. Overall environmental goal pertaining to the management of environmental features. Performance requirement that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives. A flat expanse of land bordering a river channel, formed through sediment deposition and other alluvial processes, and often characterized by frequent flooding as a result of bank overspill from the river channel. - vi

9 Draft Groundwater Hazardous waste Landscape Management Actions Management Objectives Monitoring Natural Vegetation Pollution Protected Plants Reinstatement Runoff Sub-surface water in the zone in which permeable rocks, and often the overlying soil, are saturated. Waste that are proven to be toxic, corrosive, explosive, flammable, carcinogenic, radioactive, poisonous or classified as such in legal terms. Land modified for human use and occupation, embracing both the natural (wilderness) environment and the urban. Practical actions aimed at achieving management objectives and targets. Desired outcome of management measures for mitigating negative impacts and enhancing the positive impacts related to project activities and aspects (i.e. risk sources). A systematic and objective observation of an organization s activities and services conducted and reported on regularly. All existing vegetation species, indigenous or otherwise, of trees, shrubs, groundcover, grasses and all other plants found growing on the site. Any change in the environment caused by substances, radioactive or other waves, or noise, odours, dust or heat, emitted from any activity, including the storage or treatment of waste or substances, construction and the provision of services, whether engaged in by any person or an organ of state, where that change has an adverse effect on human health or wellbeing or on the composition, resilience and productivity of natural or managed ecosystems, or on materials useful to people, or will have such an effect in the future. Furthermore, pollution can also be regarded as an undesirable state of the natural environment being contaminated with harmful substances as a consequence of human activities. Plant species officially listed on the Protected Plants List (each province has one), and which may not be removed or transported without a permit to do so from the relevant provincial authority. Reinstatement is defined as the return of a disturbed area to a state, which approximates the state (where possible), which it was before disruption. The total water yield from a catchment including surface and subsurface flow. Riparian Habitat The physical structure and associated vegetation of the areas associated with a watercourse which are commonly characterised by alluvial soils, and which are inundated or flooded to an extent and with a frequency sufficient to support vegetation of species with a composition and physical structure distinct from those of adjacent land areas. - vii

10 Draft Sensitive Environmental Features Subsoil Topsoil Transplanting Wastewater Watercourse Weeds and Invader Plants Wetland Environmental features protected by legislation (e.g. heritage resources), or identified during the EIA as sensitive through specialists findings and input received from Interested and Affected Parties. The soil horizons between the topsoil horizon and the underlying parent rock. Topsoil can be regarded as the fertile upper part or surface of the soil. The removal of plant material and replanting the same plants in another designated position. Means water contaminated by the project activities. A geomorphological feature characterized by the presence of a streamflow channel, a floodplain and a transitional upland fringe seasonally or permanently conveying surface water. Weeds and invader plants are defined as undesirable plant growth that shall include, but not be limited to all declared category 1, 2 and 3 listed invader species as set out in the Conservation of Agricultural Resources Act (No 43 of 1983) regulations. Other vegetation deemed to be invasive should be those plant species that show the potential to occupy in number, any area within the defined construction area. Land where a surplus of water (i.e. waterlogging) is the key factor determining the nature of the soil development as well as the types of plants and animals living at the soil surface. - viii

11 1 PURPOSE OF THE DOCUMENT This document serves as the Environmental Management Programme (EMPr) for the Preconstruction, Construction and Operational phase activities for the Proposed Roads and Stormwater Infrastructure for Soshanguve Block L, as well as the Rehabilitation Plan. The EMPr contains all suitable mitigation measures proposed to manage (i.e. prevent, reduce, rehabilitate and/or compensate) the environmental impacts of the project. This document must be implemented during the Pre-construction, Construction and Operational phases of the project. An EMPr represents a detailed plan of action prepared to ensure that recommendations for enhancing positive impacts and/or limiting or preventing negative environmental impacts are implemented during the lifecycle of a project. The primary objectives of the EMPr are to: Describe actions that when implemented will achieve mitigation of environmental impacts, or result in improved management of activities thereby reducing the probability of impacts occurring; Define organisational and administrative arrangements for environmental management and monitoring of the work contract, including defining the responsibilities of staff and coordination, liaison and reporting procedures; Ensure that discussions are held with site supervision staff, regarding pro-active environmental management, such that potential problems can be identified and mitigation measures adopted prior to rehabilitation work being carried out; Define procedures for environmental control, in the event of pollution (spillage) or similar events requiring action; Preserve the topsoil, flora and fauna on the proposed area to be affected; Ensure for the control of invasive plants in the construction footprint; and To leave the site in such a state that will allow for easy site rehabilitation. This Rehabilitation Plan has been compiled in accordance with the requirements contained in Government Notice No. R. 541 (General Authorisation in terms of Section 39 of the National Water Act 1998, Act 36 of 1998). Objectives pertaining to the rehabilitation of the aquatic habitat affected by the Proposed Roads and Stormwater Infrastructure for Soshanguve Block L are indicated below: a) Rehabilitation of lay down area; b) Stabilisation and rehabilitation of construction area of the proposed water upgrades; and c) Rehabilitation of the identified wetlands affected by the development footprint. - 1

12 This plan provides specific measures to rehabilitate the aquatic environment that will be affected by the project s construction activities. In the context of this plan rehabilitation refers to repairing the affected aquatic environment to a state that existed prior to construction or better, based on pre-determined targets. 2 DOCUMENT ROADMAP The information documented serves as the EMPr for the Proposed Roads and Stormwater Infrastructure for Soshanguve Block L. The EMPr is intended to meet all requirements as stipulated in Government Notice (GN) No. 982 of the 2014 EIA Regulations, as amended (07 April 2017), Appendix 4. Table 1 presents the document s composition in terms of the aforementioned regulatory requirements. Table 1: Document Roadmap Chapter Title Correlation with G.N. No. R982 1 Purpose of the N/A Document 2 Document Roadmap N/A 3 Project Overview N/A 4 Environmental Assessment Practitioners 1(a) Details of (i) the EAP who prepared the EMPr; and (ii) the expertise of that EAP to prepare an EMPr, including curriculum vitae. 5 Legislation and Guidelines Considered N/A 6 Roles & 1(i) An indication of the persons who will be responsible for Responsibilities the implementation of the impact management actions contemplated in paragraph (f). 8 Environmental Training & Awareness Creation 1(g) 1(h) 1(k) 1(l) 1(m) The method of monitoring the implementation of the impact management actions contemplated in paragraph (f). The frequency of monitoring the implementation of the impact management actions contemplated in paragraph (f). The mechanism for monitoring compliance with the impact management actions contemplated in paragraph (f). A programme for reporting on compliance, taking into account the requirements as prescribed by the Regulations. An environmental awareness plan describing the manner in which - - 2

13 Chapter Title Correlation with G.N. No. R982 9 Environmental Activities, Aspects and Impacts 10 Sensitive Environmental Features 11 Impact Management 1(b) 1(c) 1(d) 1(e) 1(f) 1(j) 1(l) (i) the applicant intends to inform his or her employees of any environmental risk which may result from their work; and (ii) risks must be dealt with in order to avoid pollution or the degradation of the environment. A detailed description of the aspects of the activity that are covered by the final environmental management plan. A map at an appropriate scale which superimposes the proposed activity, its associated structures, and infrastructure on the environmental sensitivities of the preferred site, indicating any areas that should be avoided, including buffers. Information on any proposed management or mitigation measures that will be taken to address the environmental impacts that have been identified in a report contemplated by the EIA Regulations, including environmental impacts or objectives in respect of (i) planning and design; (ii) pre-construction activities; (iii) construction activities; (iv) rehabilitation of the environment after construction and where applicable post closure; and (v) where relevant, operation activities. A description and identification of impact management outcomes required for the aspects contemplated in paragraph (d). A description of proposed impact management sections, identifying the manner in which the impact management objectives and outcomes contemplated in paragraphs (d) and (e) will be achieved, and must, where applicable, include actions to - (i) avoid, modify, remedy, control or stop any action, activity or process which causes pollution or environmental degradation; (ii) comply with any prescribed environmental management standards or practices; (iii) comply with any applicable provisions of the Act regarding closure, where applicable; and (iv) comply with any provisions of the Act regarding financial provisions for rehabilitation, where applicable. The time periods within which the impact management actions contemplated in paragraph (f) must be implemented. A programme for reporting on compliance, taking into account the requirements as prescribed by the Regulations. - 3

14 Chapter Title Correlation with G.N. No. R982 N/A 1(n) Any specific information that may be required by the competent authority 3 PROJECT OVERVIEW 3.1 Project Background and Motivation The Soshanguve Block L is currently experiencing flooding due to poor stormwater management. In addition, the roads within the area are poorly maintained and hinder access to the area. Therefore, the City of Tshwane (CoT) Metropolitan Municipality Roads and Transport Department propose to upgrade the road infrastructure and implement improvements to the stormwater management system to prevent flooding within Soshanguve Block L. The main aim of the project is to ensure that the standard of living of local residents is improved, public safety is enhanced, and damage to related infrastructure such as roads is reduced. The proposed Roads and Stormwater Infrastructure for Soshanguve Block L will have a significant positive social impact by providing better access and improve the service provision to the area. As a result of the road and stormwater infrastructure upgrade, there will be better access provision for schools, community facilities, business sites, recreational facilities, open space and places of worship for the community. In addition, construction is to be executed by using both conventional construction and labour-intensive construction methods in accordance with the Expanded Public Works Programme (EPWP) which will empower the community. 3.2 Project Location The proposed Roads and Stormwater Infrastructure for Soshanguve Block L falls in the jurisdiction of CoT Metropolitan Municipality, situated in the Gauteng Province (Figure 2). The site is situated within Soshanguve Block L, which is surrounded by Mabopane, Kopanong and Soshanguve East (Figures 3 and 4). The site is situated to the South of Commisioner Street, West of the R80, East of the M43, and North of Ruth First Road. - 4

15 Figure 1: Provincial and local municipality map - 5

16 Figure 2: Main places surrounding the proposed project site - 6

17 Figure 3: 1: Topographical Map - 7

18 3.3 Technical Information The method statement and design drawings can be referred to in Appendix C of the GA Technical Report. The Stormwater Management Plan is contained in Appendix I of the GA Technical Report and the Geotechnical Report is contained in Appendix J of the GA Technical Report. 4 ENVIRONMENTAL ASSESSMENT PRACTITIONER Nemai Consulting was appointed by Bigen Africa Services (Pty) Ltd as the Independent EAP to undertake the EMPr for the Proposed Roads and Stormwater Infrastructure for Soshanguve Block L. This section provides an overview of Nemai Consulting and the company s experience with Environmental Impact Assessments (EIAs), as well as the details and experience of the EAPs that form part of the GA team. Nemai Consulting is an independent, specialist environmental, social development and Occupational Health and Safety (OHS) consultancy, which was founded in December The company is directed by a team of experienced and capable environmental engineers, scientists, ecologists, sociologists, economists and analysts. The company has offices in Randburg (Gauteng) and Durban (KwaZulu-Natal). The core members of Nemai Consulting that are involved with the EMPr for the proposed development are captured in Table 2 below. Table 2: EMPr core team members Name Qualification Responsibility Ms S. Gerber BSc (Honours) Environmental Science Environmental Consultant Ms J. Davis BSc (Honours) Geography Project Manager 5 LEGISLATION AND GUIDELINES CONSIDERED 5.1 Overview of Legislation Some of the pertinent environmental legislation that has bearing on the proposed development is captured in Table 3 below. A description of the policy and legislative context within which the development is proposed including an identification of all legislation, policies, plans, - 8

19 guidelines, spatial tools, municipal development planning frameworks and instruments that are applicable to this activity and are to be considered in the assessment process. Table 3: Environmental Legislative Framework Legislation Constitution of the Republic of South Africa (Act No. 108 of 1996) National Environmental Management Act (NEMA) (Act No. 107 of 1998) National Water Act (NWA) (Act No. 36 of 1998) National Environmental Management Air Quality Act (Act No. 39 of 2004) National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004) National Environmental Management: Protected Areas Act (Act No. 57 of 2003) National Forests Act (No. 84 of 1998) Occupational Health & Safety Act (Act No. 85 of 1993) National Heritage Resources Act (Act No. 25 of 1999) Conservation of Agricultural Resources Act (Act No. 43 of 1983) National Environmental Management: Waste Act (Act No. 59 of 2008) Description and Relevance Chapter 2 Bill of Rights. Section 24 Environmental Rights. Section 24 Environmental Authorisation (control of activities which may have a detrimental effect on the environment). Section 28 Duty of care and remediation of environmental damage. Environmental management principles. Authorities Department of Environmental Affairs (DEA) or Gauteng Department of Agriculture and Rural Development (GDARD) Chapter 3 Protection of water resources. Section 19 Prevention and remedying effects of pollution. Section 20 Control of emergency incidents. Chapter 4 Water use. Authority DWS. Air quality management Section 32 Dust control. Section 34 Noise control. Authority GDARD. Management and conservation of the country s biodiversity. Protection of species and ecosystems. Authority GDARD. Protection and conservation of ecologically viable areas representative of South Africa's biological diversity and natural landscapes. Section 15 Authorisation required for impacts to protected trees. Authority Department of Agriculture, Forestry and Fisheries (DAFF). Provisions for Occupational Health & Safety Authority Department of Labour. Section 34 protection of structure older than 60 years. Section 35 protection of heritage resources. Section 36 protection of graves and burial grounds. Section 38 Heritage Impact Assessment for linear development exceeding 300m in length; development exceeding 5 000m 2 in extent, etc. Authority Gauteng Provincial Heritage Resources Authority (PHRAG). Control measures for erosion. Control measures for alien and invasive plant species. Authority Department of Agriculture. Chapter 4 Waste management measures Chapter 5 licensing requirements for listed waste activities. Authority DEA. - 9

20 5.2 National Environmental Management Act, 1998 The National Environmental Management Act (Act No. 107 of 1998) (NEMA) is the overarching Act dealing with the management of the environment. The environment as referred to in NEMA does not only relate to the biophysical environment but supports the sustainability principle by including the socio-economic environment as well. The regulations regulating the evaluation of activities are captured in the 2014 EIA Regulations, as amended (07 April 2017) and consist of the following: EIA procedures Government Notice No. R. 982; Listing Notice 1 Government Notice No. R. 983; Listing Notice 2 Government Notice No. R. 984; and Listing Notice 3 Government Notice No. R Sections of stormwater pipes and roads trigger Listed Activities in terms of the 2014 EIA Regulations as amended. The Listed Activities, described in Table 4, requires Environmental Authorisation (EA) from the Competent Authority, i.e. GDARD. As such, a Basic Assessment (BA) Process will be undertaken for the sections that trigger the Listed Activities. Table 4: Listed activities for the Notice No. GN GN 985 GN 985 Activity No. 12 (c)(ii) 14 (ii)(a)(c)(iv) Activity description The infilling or depositing of any material of more than 10 cubic metres into, or the dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock of more than 10 cubic metres from a watercourse. The clearance of an area of 300 square metres or more of indigenous vegetation c. Gauteng ii. Within Critical Biodiversity Areas or Ecological Support Areas identified in the Gauteng Conservation Plan or bioregional plans The development of (ii) Infrastructure or structures with a physical footprint of 10 square metres or more; where such development occurs (a) Within a watercourse c. Gauteng iv. Sites identified as Critical Biodiversity Areas (CBAs) or Ecological Support Areas (ESAs) in the Gauteng Conservation Plan or in bioregional plans; 5.3 National Water Act (Act No. 36 of 1998) (NWA) NWA regulates the surface and subsurface water of South Africa. Water is considered a scarce commodity and should therefore be adequately protected. Amongst others, the act deals with the protection of water sources, water uses, water management strategies and catchment management, dam safety and general powers and functions. - 10

21 The purpose of the act is to ensure that South Africa s water resources are protected, used, developed, conserved, managed and controlled. Water uses and permissible water uses are discussed in Section 21 and 22 of this Act. The project entails the following activities that constitute water uses in terms of Section 21 of NWA: 21 (c): Impeding or diverting the flow of water in a watercourse; 21 (i): Altering the bed, banks, course or characteristics of a watercourse. The proposed Roads and Stormwater Infrastructure for Soshanguve Block L involves construction work within a 500m radius of wetlands, construction of sections of stormwater pipes and roads that traverse wetlands and will discharge stormwater into the regulated area of a watercourse. Therefore, a GA is required in terms of Section 21 (c) and (i) of NWA. According to General Notice 509 as published in the Government Gazette No of 2016, it must be noted that as defined by the Replacement GA in terms of Section 39 of the NWA, on account of the extremely sensitive nature of wetlands and estuaries, the section 21(c) and (i) water use GA does not apply to the use of water in terms of section 21(c) or (i) of the Act within the regulated area of a watercourse where the Risk Class is Medium or High. As the proposed development falls within the regulated area of a watercourse (500m radius of wetlands), traverse two wetlands and will discharge stormwater into the regulated area of a watercourse where the Risk Class is classified as Low according to the DWS Risk Matrix, a GA would apply for this project. 5.4 The National Environmental Management Waste Act (Act No. 59 of 2008) The National Environmental Management Waste Act (Act No. 59 of 2008) (NEM: WA) regulates waste management in order to protect the health and environment of South African citizens. This is achieved through pollution prevention, institutional arrangements and planning matters, national norms and standards and the licensing and control of waste management activities. The latest list of waste management activities that have or are likely to have a detrimental effect (GN No. 921 of 29 November 2013) contains activities listed in Categories A and B that would require licensing from the provincial or national authorities and activities contained in Category C which would require meeting the requirements of various Norms and Standards. No authorisation will be required in terms of the NEM: WA, as the project will not include any of the listed waste management activities. - 11

22 6 ROLES AND RESPONSIBILITIES The implementation and enforcement of the EMPr will require the input of numerous parties, including but not limited to the Applicant, Environmental Control Officer (ECO) as well as the Contractor s Environmental Officer (EO). 6.1 GDARD GDARD is the mandated authority in terms of the NEMA and thus is responsible for issuing an Environmental Authorisation (EA) following a decision-making process conducted as part of the BA. If approved the EA will include project specific conditions. The EMPr should be updated to include these conditions should the EA be granted. GDARD also fulfils a compliance and enforcement role with regards to the authorisation. The Department may perform random inspections to checks compliance. GDARD may request to review the monitoring and auditing reports compiled by the ECO. 6.2 Project Proponent City of Tshwane (CoT) Metropolitan Municipality is the applicant in terms of the NEMA. CoT is also the Project Proponent for all components of the work related to the development and is ultimately responsible for the development and implementation of the EMPr and ensuring that the conditions in the GA and EA are satisfied. The liability associated with environmental non-compliance rests with the Project Proponent. 6.3 Environmental Control Officer (ECO) The ECO is a competent and independent representative, who is responsible for monitoring the compliance of the EMPr during the construction phase. The EMPr recommends that the ECO undertake monthly compliance monitoring. The monitoring reports will be submitted to the Applicant. A quarterly monitoring report, unless otherwise specified by the Department, will be submitted to GDARD. The Applicant must appoint the ECO prior to the commencement of construction. The ECO will be responsible for the following: Conduct monthly observation and inspections and audits of all construction areas; Monitoring of compliance against the EMPr and EA; Provide the Contractor management and site Environmental Officer (EO) with an environmental induction on the EMPr and EA; and - 12

23 Make recommendations on how to best apply the environmental requirements on site and advise the Applicant on the site instructions required to facilitate effective environmental compliance. 6.4 Contractor s Environmental Officer (EO) The primary role of the competent EO is implement the EMPr and EA during the construction phase. A suitably qualified EO, with at least 3 years of proven environmental site experience must be appointed full time on site during construction activities. Specific responsibilities of the EO, who will be on site, will include the following: Aiding the Contractor to comply with all the project s environmental management requirements; Assisting the Contractor in compiling Method Statements which include the relevant environmental conditions and mitigations from the EMPr and EA; Assisting the Contractor in compiling and Environmental Emergency and Response Procedure which should include, as a minimum, spillages and fires; Facilitating environmental awareness training of relevant persons on site; Exercising an internal compliance management system on behalf of the Contractor; Daily inspections of the site to ensure adherence to the management actions of the EMPr and the Method Statements and compliance to the EA ; Provide inputs to the regular environment report to be prepared by the ECO (as required); Liaison with the ECO regarding planned construction activities and compliance Liaison with the construction team on issues related to implementation of, and compliance with, the Pre-construction and Construction EMPr; Maintaining a record of environmental incidents (such as spills, impacts, legal transgressions) as well as corrective and preventive actions taken; and Maintain a public complaint register in which all complaints are recorded, as well as action taken. 7 MONITORING Monitoring is required to ensure that the receiving environment at the study area is suitably safeguarded against the identified potential impacts, and to ensure that the EMPr requirements are adequately implemented and adhered to during the construction phase. - 13

24 7.1 Compliance Monitoring Compliance monitoring will commence in the pre-construction phase, where those conditions in the EA that need to be adhered to prior to project implementation will need to be checked and recorded. Compliance monitoring will be completed at the end of the defects liability period to check the performance of rehabilitation measures and whether the related objectives have been met. The ECO will undertake, as a minimum, monthly monitoring against the requirements and conditions stipulated in the EMPr and EA. Compliance monitoring with the EA and EMPr must be conducted in accordance with Regulation 34 of GN No. R 982 (04 December 2014, as amended) in terms of the following: 1. The holder of an EA must, for the period during which the EA and EMPr, remain valid - a. Ensure that the compliance with the conditions of the EA and EMPr is monitored; and b. Submit environmental monitoring reports to GDARD. 2. The environmental monitoring report musta. Be prepared by an independent person with the relevant environmental monitoring expertise; b. Provide verifiable findings, in a structured and systematic manner, oni. The level of performance against and compliance of an organization or project with the provisions of the requisite EA or EMPr; and ii. The ability of the measures contained in the EMPr, to sufficiently provide for the avoidance, management and mitigation of environmental impacts associated with the undertaking of the activity; c. Contain the information set out in Appendix 7 of GN No. R 982 (04 December 2014, as amended); and d. Be conducted and submitted to GDARD at intervals as indicated in the EA. A document handling system must be established to ensure accurate updating of EMPr documents, and availability of all documents required for the effective functioning of the EMPr. Supplementary EMPr documentation could include: Method Statements; Site instructions; Emergency preparedness and response procedures; Record of environmental incidents; Non-conformance register; Training records; Site inspection reports; Monitoring reports; - 14

25 Auditing reports; and Public complaints register (single register for maintained for overall site). The Contractor shall also develop and submit a Site Layout Plan illustrating the planned site layout, access routes, storage facilities, site camp area, parking areas, etc. This Site Layout Plan must first be approved by the Applicant and ECO prior to site establishment activities commencing. 8 ENVIRONMENTAL TRAINING AND AWARENESS CREATION Training aims to create an understanding of environmental management obligations and prescriptive measures governing the execution of the project. It is generally geared towards project team members that require a higher-level of appreciation of the environmental management context and implementation framework for the project. Awareness creation strives to foster a general attentiveness amongst the construction workforce to sensitive environmental features and an understanding of implementing environmental best practices. The various means of creating environmental awareness during the construction phase of the project may include: Induction course for all workers before commencing work on site; Refresher courses (as and when required); Daily toolbox talks, focusing on particular environmental issues (task- and area specific); Courses must be provided by suitably qualified persons and in a language and medium understood by the workers; Erect signage and barricading (where necessary) at appropriate points in the construction domain, highlighting sensitive environmental features (e.g. wetland); and Place posters containing environmental information at areas frequented by the construction workers (e.g. eating facilities). Training and awareness creation will be tailored to the audience, based on their designated roles and responsibilities. Records will be kept of the type of training and awareness creation provided, as well as containing the details of the attendees. 9 ENVIRONMENTAL ACTIVITIES, ASPECTS AND IMPACTS In order to establish best management practices and prescribe mitigation measures, the following project-related information needs to be adequately understood: - 15

26 Activities associated with the proposed project; Environmental aspects associated with the project activities; Environmental impacts resulting from the environmental aspects; and The nature of the surrounding receiving environment. 9.1 Environmental Activities For the purposes of effective and efficient monitoring, the aspects of construction are outlined separately for pre-construction and construction phases. In order to understand the impacts related to the project it is necessary to unpack the activities associated with the project lifecycle, as shown below: Table 5: Activities associated with the Pre-construction Phase 1. Obtain EA, GA and other relevant permits 2. Applicant to appoint ECO PRE-CONSTRUCTION PHASE Project Activities 3. Negotiations and agreements with the affected landowners and stakeholders 4. Initiate legal process required for servitudes 5. Detailed engineering design, if applicable 6. Survey and mark construction servitude 7. Construction site planning, access and layout 8. Pre-construction photographic records 9. Development and approval of method statements inclusive of environmental impact mitigation 10. Development and approval of construction plans 11. Ongoing consultation with landowners, community members, and Interested and Affected Parties (IAPs) 12. Diligent compliance monitoring of the EMPr, EA and other relevant environmental legislation 13. Barricading and installing barriers around buffer areas identified in specialist studies Table 6: Activities associated with the Construction Phase CONSTRUCTION PHASE - 16

27 Project Activities 1. Site establishment 2. Construction employment 3. Establish construction laydown area 4. Fencing of the construction area 5. Demarcation of buffers around sensitive areas 6. Environmental awareness training 7. Delivery of construction material 8. Transportation of equipment, materials and personnel 9. Storage and handling of material 10. Excavation 11. Stormwater management plan 12. Management of topsoil and spoil 13. Waste management 14. Traffic control measures 15. Site security 16. Reinstatement and rehabilitation of construction domain 17. Diligent compliance monitoring of the EMPr, EA and other relevant environmental legislation 18. Implement environmental monitoring programmes 19. Ongoing consultation with landowners, community members, and IAPs 20. Safeguarding of existing services and infrastructure on site Table 7: Activities associated with Operation Phase OPERATION PHASE Project Activities 1. Routine maintenance inspections 2. Implementation of the alien plant monitoring and eradication programme - 17

28 3. Monitoring of stormwater discharges 4. Repair and maintenance works 5. Ongoing consultation with landowners, community members, and IAPs 9.2 Potential Significant Environmental Impacts Environmental impacts are the change to the environment resulting from an environmental aspect, whether desirable or undesirable. Refer to Table 8 for the potential significant impacts associated with the preceding activities and environmental aspects (including preconstruction, construction and operation phases). Table 8: Potential significant environmental impacts Feature Geology Soil Ecology Noise Air Quality Aesthetic Quality Wetlands and Potential Impact Unsuitable geological conditions risks to structural integrity of infrastructure; Sourcing of construction material from illegal borrow pits; Disposal of spoil material in unauthorised localities; Loss of topsoil (through mixing with subsoil, contamination, etc.) Soil erosion (land clearance, poor stormwater management during construction activities); and Soil contamination through poor construction practices. Potential clearance of indigenous vegetation; Potential loss of significant or protected flora and fauna species; Impact to the identified Protected Tree species; Encroachment into ESAs, which are important in terms of biodiversity, ecosystem functionality and ecological processes; and Clearing of vegetation for construction purposes may result in the proliferation of exotic vegetation, which could spread beyond the construction domain. Localised increase in the noise levels during construction. Dust generation during the construction phase. Visual quality and sense of place to be adversely affected by construction activities. Encroachment of construction activities into wetlands. Siltation and sedimentation of channels and wetlands; Erosion of channels and wetlands; Loss of vegetation; Direct loss of wetland areas; Decrease in functionality; Additional water quality impairment; Compaction; Altering hydromorphic soils; Drainage pattern changes; - 18

29 Feature Socio-economic Environment Traffic Historical Features Existing Structures and Infrastructure Potential Impact Altering overland flow characteristics; and Temporary impacts to flow during the instream works Provision of roads and stormwater infrastructure; Employment opportunities; Safety and security; Impact to visual quality and sense of place; and Increase in property value. Potential damage to property (e.g. gates, fences); and Nuisance from dust and noise generated during construction Increase in traffic of the surrounding residential road network; and Risk to local road users. Possible impact to unmarked human burials, burial pits, potsherds or stone tools uncovered during bulk earthworks on site. Risk of damaging existing services, infrastructure and structures during construction; and Disruptions to traffic on local residential road network during construction. Table 9: Potential Significant Environmental Impacts during Operation Phase Feature Geology and Soil Terrestrial Ecology Aesthetic Quality Socio Economic Wetlands Potential Impact Decrease in soil fertility due to loss of topsoil (poor construction and rehabilitation activities) Encroachment by exotic species through inadequate eradication programme Loss of sensitive ecosystems (threatened ecosystem, CBA and forest area) which provide habitat for a number of species Poor growth and recovery of vegetation due to poor rehabilitation practices Inadequate reinstatement and rehabilitation of construction footprint impacting negatively on visual aesthetics of the area Service provision for the area. Potential increase in the PES, EI and ES by pollution through possible spillages, erosion, siltation, and sedimentation. - 19

30 10 SENSITIVE ENVIRONMENTAL FEATURES Within the context of the project area, cognisance must be taken of the following sensitive environmental features, attributes and aspect, for which mitigation measures are included in the EMPr (Figure 4): The existing structures and infrastructure in the area. Unchanneled valley bottom wetlands and one hillslope seep wetland were identified within 500m from the proposed development. Three sections of the proposed stormwater infrastructure traverse the identified wetland systems. The proposed development site falls within Ecological Support Areas regions. One protected tree species was recorded along the proposed road route, namely the Sclerocarya birrea subsp. caffra (Marula tree). No heritage resources were found on site. - 20

31 Figure 4: Sensitivity Map - 21

32 11 IMPACT MANAGEMENT The impact assessment carried out for each environmental impact that may result from the proposed project, forms the basis for determining which management measures are required to prevent or minimise these impacts. The management measures are furthermore a means by which the mitigation measures, determined in the impact assessment are translated to action items required to prevent or keep those impacts that cannot be prevented within acceptable levels. Mitigation should strive to abide by the following hierarchy (1) prevent; (2) reduce; (3) rehabilitate; and/or (4) compensate for the environmental impacts. Figure 5: Mitigation Hierarchy Prevention mitigation measures (1) are the first preference for developments and are usually measures that avoid impacts completely. The impacts for the mitigation measures listed below will mostly fall under the reduction hierarchy (2). This involves mitigation measures that minimise impacts. This EMPr also includes remediation and rehabilitation measures (hierarchy 3) for environmental impacts. Compensation (4) involves compensating the loss of an entire feature. In the case for the environment, this usually means consideration of an offset associated with rehabilitation and mitigation. The basis for the management measures which follow below comprise of the following: Management objectives i.e. desired outcome of management measures for mitigating negative impacts and enhancing the positive impacts related to project activities and aspects (i.e. risk sources); Targets i.e. level of performance to accomplish management objectives; and Management actions i.e. practical actions aimed at achieving management objectives and targets; Responsibilities; and Monitoring requirements. - 22

33 11.1 Environmental Principles The following principles should be considered at all times during the pre-construction and construction phase activities. The environment is considered to be composed of both biophysical and social components. Construction is a disruptive activity and all due consideration must be given to the environment, including the social environment, during the execution of a project to minimise the impact on affected parties. Minimisation of areas disturbed by construction activities (i.e. the footprint of the construction area) should minimise many of the construction related environmental impacts of the project and reduce rehabilitation requirements and costs. As minimum requirements, all relevant standards relating to international, national, provincial and local legislation, as applicable, shall be adhered to. This includes requirements relating to waste emissions (e.g. hazardous, airborne, liquid and solid), waste disposal practices, noise regulations, road traffic ordinances, etc. Every effort should be made to minimise, reclaim and/or recycle waste material Pre-construction Phase The planning or pre-construction phase largely entailed conducting the necessary specialist studies, determining the site layout and carrying out the requisite environmental processes to obtain authorisation. General requirements during the pre-construction phase include the following: Design to consider and incorporate environmental requirements. Define and communicate roles and responsibilities for the implementation of the EMPr. Develop and implement an environmental awareness programme. Compile and implement an employment strategy construction labour Construction Site Planning and Layout Management Objective: Appropriate planning and layout of construction site to ensure environmental protection. Target: No impacts to sensitive environmental features as a result of construction site planning and layout. Management Actions: Before construction commences, all sensitive features must be clearly demarcated. - 23

34 Conduct a pre-construction survey of the area to be affected by the development. This must include site investigations with photographic records. During site preparation, topsoil and subsoil are stripped separately from each other and must be stored separately from spoil material. This topsoil must be re-used during the rehabilitation phase. Topsoil must be stripped to at least 150 mm and stored separately to the subsoil. During backfilling, topsoil must be replaced last to the level that it was removed. The Contractor to develop method statements to be approved by the Applicant prior to construction taking place. Method statements must include the relevant management actions from the EMPr and conditions of the EA. Method statements that need to be developed must include, as minimum: o Site clearance and topsoil stripping and storage; o Excavations; o Hazardous substances storage and management; o Sensitive environmental features management; o Waste storage and management. A site layout plan must be developed prior to construction. The plan must show the following (as relevant), as a minimum: o Buildings and structures; o Contractors camp and lay down areas; o Site offices; o Roads and access routes; o Essential services (permanent and temporary water, electricity and sewage); o Rubble and waste rock storage and disposal sites; o Solid waste storage; o Site toilets and ablutions; o Topsoil stockpiles; o Construction materials stores; o Vehicle and equipment stores; o Sensitive environmental features; and o Any other activities, facilities and structures deemed relevant. Define and communicate roles and responsibilities for the implementation of the EMPr. Develop and implement an environmental awareness plan. The appointment of an ECO. Records of compliance / non-compliance must be kept on site at all times. Records of all environmental incidents must be maintained, and a copy of these records be made available on request throughout the project execution. Prior to establishment of the site camp(s), the Contractor shall produce a plan showing the positions of all buildings, laydown yards, batch plants, vehicle wash areas, vehicle repair area, batching areas and infrastructure. - 24

35 Project Management shall allocate a laydown area for Contractor-supplied items. At all times, the Contractor shall be responsible for the safe and adequate storage of all materials and equipment on site which he is to install, whether they are supplied by himself or others. The safe handling, unloading and loading of material receipts and dispatches at site or storage areas shall be the Contractors responsibility. Demarcation of ESA remaining habitat at construction edge. Clear demarcation of the wetland boundary and 32m buffer zone. Induction of all personnel and plant operators with regard to no-go areas and the location of all demarcated boundaries and buffer zones on site. Contractor to appoint a Community Liaison Officer (CLO), or to assign such responsibilities to a competent staff member who will have adequate time to fulfil relevant functions. Responsibilities: Proponent acquire permits. ECO to check and monitor compliance. Contractor to implement management actions. Monitoring Requirements: Approved site plan and method statements. Barricading and signage. Records of awareness creation Environmental Awareness Creation Management Objective: Ensure that the Contractor, construction workers and site personnel are aware of the relevant provisions of the EMPr, EA and other relevant permits. Target: All construction workers and employees to have completed appropriate environmental training. A record of environmental training undertaken to be kept on site. Management Actions: The Contractor must arrange that all of his employees and the sub-contractor s employees go through the project specific environmental induction and environmental awareness training courses before the commencement of construction and as and when new employees or sub-contractors are brought on site. The Contractor's site staff including foremen and site management staff must attend an environmental induction on the conditions of the EA and requirements of the EMPr - 25

36 provided by the ECO and a signed attendance register shall be kept available for confirmation. This will be a once off training session. Thereafter, it will be the responsibility of the Contractor to provide the environmental induction to employees and subcontractors. The environmental training is compulsory for all employees and structured in accordance with their relevant rank, level and responsibility, as well as the Environmental Specification. Responsibilities: Project Manager and ECO - to monitor compliance. ECO to conduct once-off EA and EMPr training with Contractor s Supervisory Staff and EO. Contractor to conduct Environmental induction training with all its staff and subcontractors. Monitoring Requirements: Records of environmental training and awareness Specialised Environmental Investigations Management Objective: Identify sensitive and protected environmental features in addition to those that have been identified as part of the EIA process. Target: All sensitive and protected environmental features to be identified in the construction domain (all the components of the project). All relevant approvals to be obtained prior to relocation of red data, protected and endangered flora and fauna species, medicinal plants, heritage resources and graves. Management Actions: Suitable specialist(s) to identify sensitive environmental features (including watercourses, fauna, and flora) where special care needs to be taken and implement suitable mitigation measures to safeguard these features (e.g. barricading, signage and awareness creation). Given that construction activities will expose workers and landowners to excessive noise rating levels, it is recommended that a baseline noise survey also be conducted as soon as possible following commencement of site activities in accordance with the requirements of the Noise Induced Hearing Loss Regulations (OHS Act 85 of 1993) and SANS 10083:2004. A permit from DAFF is required before construction commences in order to disturb, destroy or remove the Marula tree noted along the proposed road reserve. Demarcation of ESA remaining habitat at construction edge. - 26

37 Clear demarcation of the wetland boundary and 32m buffer zone. Induction of all personnel and plant operators with regard to no-go areas and the location of all demarcated boundaries and buffer zones on site. Responsibilities: Implementing agent to appoint suitably qualified specialists. Specialists to execute the management actions. Monitoring Requirements: Approval by relevant environmental authorities Safeguarding of Existing Services and Infrastructure Management Objective: Ensure that existing services on site are safeguarded against damage during construction. Adhere to agreements made with owners / custodians of the services and infrastructure. Target: No damage to existing services on site. No unwarranted complaints regarding adverse impacts to existing services and infrastructure. No adverse impacts to existing services and infrastructure. All relevant approvals to be obtained prior to working within existing servitudes (including roads, railway line, gas pipeline, powerlines, telephone lines, etc.). Management Actions: Identify and record all existing services and infrastructure. Positions where existing services interfere with the proposed development must be marked for the Contractor to see the exact position of interference. Negotiations and agreements with owners and landowners regarding existing services and infrastructure to be undertaken prior to construction and adhered to throughout the project lifecycle. Conform to requirements of relevant service providers. Agreements to be in place. Ensure access to infrastructure is available to service providers and owners at all times. Immediately notify service providers of disturbance to services. Rectify disturbance to services, in consultation with service providers. Maintain a record of all disturbances and remedial actions on site. Notify landowners of any disruptions to essential services and infrastructure. All visible and underground existing services near the road and stormwater infrastructure to be constructed must be located prior to construction. - 27

38 Existing services to be located may include, inter alia, the following: o Water reticulation networks; o Telkom infrastructure; o Stormwater drainage infrastructure; o Road services and associated infrastructure; o Underground electrical cables; o Data cables; and o Gas pipelines. All existing services must be re-instated to the condition in which they were found prior to construction, unless otherwise decided under written agreement with the existing service provider. Telkom SA SOC LTD provided the following conditions in their letter dated 04 : o Contact: Stone Mashila: or StoneM@openserve.co.za Frans Mothoa: or (Cable Network Services manager) prior to work commencing please. Toll free number for damages o As exact positions of the cables can only be assumed, due to various reasons, the positioning of the cables as indicated on the attached plan must be regarded as only a guideline. Telkom does not guarantee that the information provided is complete in every respect, and the fact that the information was requested and provided does not limit the responsibility of anyone who is working in the vicinity of Telkom SA SOC Limited s services, to ensure that no damage is caused to Telkom SA SOC Limited s network. o The person or organization responsible for any damages to cables or telecommunication equipment during their excavations or construction work will be held responsible for the repair costs. o Prior to the commencement of any work, Telkom must be contacted to have the position of the cables identified. Kindly advise this office after completion of the work. Responsibilities: Contractor to implement management actions. Applicant to ensure compliance. Monitoring Requirements: Public complaints register. Wayleaves and other written agreements Ongoing Consultation with Community and Affected Parties Management Objective: - 28

39 Establish and maintain a record of all complaints and claims against the project and ensure that these are timeously and effectively verified and responded to. Adhere to agreements made with landowners and community members regarding communication. Target: All complaints and claims are to be acknowledged within five (5) working days and are to be responded to within 10 working days of receipt, unless additional information and/or clarification are required. No deviations from agreements made with landowners and community members. Management Actions: Establish lines of communications with affected parties, landowners, and community members. Establish processes and procedures to effectively verify and address complaints and claims received. Complaints or liaison with affected parties, landowners, and community members with regard to environmental aspects, compensation or disturbance to activities or animals, must be recorded, reported to the correct person and a record of the response is to be entered in the complaints register. Provide the relevant contact details to affected parties, landowners, and community members for queries / raising of issues or complaints. All contractors staff must be easily identifiable through their respective uniforms. Continued liaison with authorities with regards to compliance with the EA. Good landowner/public relations to be maintained. Register to be kept of recorded damages. Construction-related damages to be repaired by Contractor. Responsibilities: Project Manager/engineer and ECO to monitor compliance. Contractor to implement management actions. Monitoring Requirements: Public complaints register Construction Phase Site Clearing Management Objective: - 29

40 Manage environmental impacts associated with site clearing. Ensure that only areas that are specifically required for the construction purposes are cleared. Target: No damage is caused to sensitive environmental features outside of the demarcated construction areas, including marked and barricaded heritage resources, protected trees, structures and infrastructure. Management Actions: Restrict site clearing activities to construction area. Method Statement to be developed, which will provide the details of how site clearing will be executed. Where possible, clearing by hand is recommended in order to create employment opportunities. Clearing of vegetation to be conducted in a phased manner (where possible), with due consideration of the search and rescue activities. All vegetation clearing must be kept to an absolute minimum, and must be within footprints of the servitude, laydown area, construction camp or roads to be used. A minimum of 150mm of topsoil must be stripped during clearing, and be stored separately from subsoil. Maintain barricading around sensitive environmental features. Suitably experienced personnel (relevant to the potentially affected environmental features) to monitor the clearing activities, with particular focus on heritage resources. The contractor has to clear the site of all inert waste and rubble, including surplus rock, foundations and batching plant aggregates. The site shall be cleared of all litter/waste prior to any construction related activities and the waste shall be disposed of at a registered waste disposal facility. Responsibilities: ECO to monitor compliance. Contractor to implement management actions. Monitoring Requirements: No clearing outside of construction domain. Intact barricading. Contractor s method statement Site Establishment Management Objective: - 30

41 Minimise environmental impacts associated with site establishment. Target: No damage to the environment outside the construction area during site establishment. No access or encroachment into no-go areas. No justifiable complaints regarding general disturbance and nuisance received from the affected parties and community members. Management Actions: The Contractor is to produce a site plan prior to the establishment of the site, which aims to identify construction activities, facilities and structures in relation to the watercourses near the site. This plan will serve as a spatial tool that facilitates the execution of the construction phase with due consideration of the watercourse. Locate construction and labour camps in areas where watercourse and other sensitive environmental features will not be impacted on. Facilities and structures shall be located with due cognisance of the terrain and geographical features of the project site. Positioning of the storage and laydown areas should aim to minimise visual impacts. Control the movement of all vehicles (including suppliers), such that they remain on designated routes and comply with relevant agreements. Maintain barricading around sensitive environmental features until the cessation of construction works. Barricading should be established around electrical powerlines present on site in order to prevent damage to the powerlines and to prevent people on site from possible harm. Appoint security personnel. Ensure noise levels are within their lawfully acceptable limits as per SANS Minimise disturbance from lighting of the construction camp and site. The extent of the site should by all means be limited, to avoid any additional clearance of vegetation. The Contractor shall ensure that the Contractors camp and working areas are kept clean and tidy at all times. The ECO shall inspect these areas on a regular basis. The Contractor shall comply with all safety requirements enforced; these include emergency evacuation procedures, fire preventative measures, etc. The Contractor shall supply firefighting equipment in proportion to the fire risk presented by the type of construction and other on-site activities and materials used on site. This equipment shall be kept in good operating order. This particularly applies to welding activities, etc. Designated and demarcated smoking areas should be provided, with special bins for discarding of cigarette butts. - 31

42 Every precaution should be taken, to prevent pollution of air, soil, ground and surface water as a result of construction activities on site. Fuel, lubricants, transmission and hydraulic fluids shall only be stored in the designated areas that comply with the OHS Act, and must have an adequate secondary containment (e.g. bund) with a capacity no less than 110% of the stored volume. Restrict development footprint to absolute minimum area necessary. Responsibilities: ECO to monitor compliance. Contractor to implement management actions. Monitoring Requirements: Contractor s method statement. Public complaints register Management of Construction Camp and Eating Areas Management Objective: Minimise environmental impacts associated with the construction camp and eating areas. Target: No environmental contamination associated with the construction camp. Minimise visual impact associated with the construction camp. No complaints regarding the construction camp. Management Actions: Construction and labour camp to be screened to minimise the visual impact, where practicable. The Contractor shall provide eating areas for all staff. Eating areas be cleaned daily and shall provide adequate temporary shade. Open uncontrolled fires will be forbidden at the site camp. Rather, contained cooking mechanisms will be used (e.g. gas stoves or an enclosed braai facility). Eating areas will be designated and demarcated. Refuse bins must be placed at all eating areas. The feeding, or leaving of food for animals, is strictly prohibited. Sufficient vermin/weatherproof bins will be present in this area for all waste material. Dishwashing facilities will be provided to ensure that wastewater is disposed of appropriately. Failure to comply with the general code of conduct, or the rules and procedures implemented at the construction camp will result in disciplinary actions. - 32

43 Provide safe potable water for food preparation and drinking. Prohibit the felling of trees for firewood. Responsibilities: ECO to monitor compliance. Contractor to implement management actions. Monitoring Requirements: Public complaints register. Contractor s method statement. Disposal certificates Management of Ablution Facilities Management Objective: Minimise environmental impacts associated with ablution facilities. Target: No environmental contamination associated with ablution facilities. Minimise visual impact associated with ablution facilities. Management Actions: Provide sufficient ablution facilities (e.g. mobile / portable / VIP toilets) at the construction camp and along construction sites, which conform to all relevant health and safety standards and codes. No pit latrines, french drain systems or soak away systems shall be allowed. Conservancy tanks must be SABS approved to ensure that the integrity of the tank is such that no ground contamination takes place. A sufficient number of toilets shall be provided to accommodate the number of personnel working in any given area. Toilets may not be further than 100m from any active working area. Toilet facilities supplied by the Contractor for the workers shall occur at a maximum ratio of 1 toilet per 15 workers. All staff to use the provided toilets at all times. All temporary/portable/mobile toilets shall be secured to the ground to prevent them from toppling over due to wind or any other cause. Some form of screened off changing facility must be provided separately for each sex. The entrances to the toilets will be adequately screened from public view. All sanitary fees that may be payable to any local authority shall be paid by the Contractor. Ablutions are to be cleaned/emptied on a regular basis, before they are full and contaminate the environment. - 33

44 The Contractor will ensure that no spillage occurs when the toilets are cleaned or emptied and that a licensed service provider removes the contents from site. Disposal of such waste is only acceptable at a licensed waste disposal facility. Sanitary hygiene bins will be provided for female staff. Toilet paper shall be provided. No showering or bathing on site Responsibilities: ECO to monitor compliance. Contractor to implement management actions. Monitoring Requirements: Public complaints register. Maintenance register for ablution facilities. Disposal certificates. Contractor s method statement Management of Workshop and Equipment Management Objective: Minimise environmental impacts associated with workshops and equipment use. Target: No environmental contamination associated with workshops and equipment use. Management Actions: Vehicles must be maintained and serviced according to the manufacturers standards. Daily checklists must be completed by drivers and operators before the vehicles and equipment are used. Vehicles and equipment must be turned off when not in use. Drip-trays must be placed under vehicles and equipment when not in use. All vehicles and equipment will be kept in good working order and serviced regularly. Leaking equipment to be removed from the site for repair. Suitable storage (closed containers stored within a bund) and disposal of hydraulic fluids and other vehicle oils. All diesel-powered equipment and vehicles used in construction activities must be suitably serviced, maintained and repaired in order to minimise the emission of diesel particulate matter and reduce subsequent worker exposure to this carcinogenic substance. - 34

45 Emergency on-site maintenance should be done over appropriate drip trays and all oil or fuel must be disposed of according to waste regulations. No washing of plant may occur on the construction site. Plant to be washed in dedicated wash bay off site, which has a concrete floor, bund walls for containment, and drains to a sump from which contaminated water must be pumped out by a licenced service provider for disposal as hazardous waste. All machinery and equipment should be inspected regularly for faults and possible leaks, these should be serviced off-site. Responsibilities: ECO to monitor compliance. Contractor to implement management actions. Monitoring Requirements: Recorded evidence of spillages. Vehicle and equipment checklists Training register. Contractor s method statement Fencing and Barricades Management Objective: To ensure and assist with controlled fencing and barricades in the working environment. Minimise disturbance to animals. Limit the entry to sensitive environments and private property. Target: Provide a clearly demarcated and safe working area. No fauna to be trapped in trenches. No unauthorised access to private property. Management Actions: Fencing and barriers will be in place in accordance with the OHS Act and comply with the provisions of the Fencing Act (Act No. 31 of 1963). In places where temporary fencing is required, the Contractor shall erect such fencing when and where required and maintain temporary fencing as necessary. Temporary fencing shall remain in position either until it is replaced by permanent fencing or until completion of the works. Register to be kept of recorded damages. Construction-related damages to be repaired by Contractor. - 35

46 Any fences damaged by the Contractor shall be repaired as soon as possible at his/her cost and shall be of the standard of the original fence. All fences erected for construction purposes (e.g. fences around camp sites, fencing around trenches, etc.) should be inspected on a daily basis to detect whether any damage has occurred. Damaged fences/barricading to be repaired immediately. Fences should be constructed to meet the following requirements: o The fence should be straight and vertical; o All the straining posts should be firmly and vertically anchored; o All the posts should extend to the same height above ground level by corresponding to the terrain form; o The straining posts and droppers should not be too far apart the closer they are, the firmer the fence; o Each wire strand should be firmly attached to the standards or line posts at a specific height above ground level and should be a certain distance apart from each other; o The droppers should be neatly and evenly spaced between the standards. The wire strands should be firmly attached to maintain the proper space between the strands and to prevent vertical movement; o Fences should never be constructed of inferior quality material. Therefore, fencing material with the SABS mark should be used; and o Comply with Nature and Environmental Conservation Ordinance (Act No. 19 of 1974) with regards to the accommodation of relevant large mammal species. Responsibilities: Project Manager/Engineer and ECO to monitor compliance. Contractor to implement management actions. Monitoring Requirements: Public complaints register. Agreements with landowners Management of Labour Force Management Objective: Ensure suitable management of labour force to prevent security-related issues. Optimise the use of local labour. Target: No complaints from landowners and community members regarding trespassing or misconduct by construction workers. - 36

47 All unskilled labour to be sourced from local communities. Management Actions: Establish an employment strategy. Prevent trespassing of construction workers onto private property. Workers should be provided with identity cards and should wear identifiable clothing. Make suitable provision for transport and/or accommodation of workforce. The construction site should be fully fenced to ensure that workers have one access point in and out of the site. Creating nuisances and disturbances in or near communities shall be prohibited. Machine/vehicle operators shall receive clear instructions to remain within demarcated access routes and construction areas. Develop a community labour agreement with targets for employment and for progression. Training of labour to benefit individuals beyond completion of the project. No unauthorised entry other than the designated construction areas. Use local labour as far as possible. Where possible use labour-intensive methods of construction. Create opportunities for the employment of women. Where feasible introduce a programme to transfer skills particularly during the construction phase of the project. Responsibilities: Proponent employment targets. ECO to monitor compliance. Contractor to implement management actions. Monitoring Requirements: Public complaints register. Labour-related targets Management of Health and Safety Management Objective: Provide a safe and healthy working environment to construction workers and the public. Target: Approved Health and Safety Plan. No reportable health and safety incidents. - 37

48 Compliance with the OHS Act, Construction Regulations (2014) and other relevant regulations. Management Actions: The Contractor to provide an Occupational Health and Safety Management Plan to the Construction Manager for approval prior to the commencement of works in terms of the Construction Regulations (2014). The Contractor shall ensure compliance to the requirements of the Health and Safety Specification and approved Health and Safety Plan throughout construction. Compliance with Occupational Health and Safety Act (Act No. 85 of 1993). Health The Construction Regulations (OHS Act 85 of 1993) require that all contractors conduct an initial health risk assessment of their workers activities prior to initiating any work on site. Ready access to drinking water must be provided at all work locations. Issuing of appropriate protective wear (jackets, hats and gloves). Safety and Security First aid officers should be trained on site (levels 1 to 3) to deal with construction related injuries. When working in the area of encroachment is prevalent, all open excavated trenches and foundations should be clearly marked and secured to keep people and fauna from falling in. The Contractor must establish site access rules and implement and maintain these throughout the construction period. Access control must, amongst other, include the rule that non-employees will not be allowed on site unaccompanied. Maintain access control to prevent access of the public to the construction areas. Emergency contact details will be prominently displayed. All construction personnel must be clearly identifiable. All employees must also be issued with employee cards for identification purposes. All workers will be supplied with the required Personal Protective Equipment (PPE) as per the OHS Act. Appropriate signage must be posted to this effect and all employees on site must be instructed to ensure that non-employees are protected at all times. All non-employees entering the site must receive induction into the hazards and risks of the site and the control measures to be observed. All complaints and/or problems related to impacts on man-made facilities and activities must be promptly addressed by the Contractor and documented. Proper supervision of employees at all times. Employees to be clearly identifiable. Employees to remain within the site boundary and no loitering to be allowed. - 38

49 Access into and out of the servitude must only be via existing access roads from local public roads. Contractor to prepare and submit, for approval, a rescue procedure for employees in the case of an injury. Any employees of the Contractor or his sub-contractors found to be in breach of any of the Environmental Protection specifications may be ordered to leave the site forthwith. Supervisory staff of the contractor, or sub-contractors shall not direct any person to undertake any activities, which would place such person/organization in contravention to any law, regulation or the EMPr itself. Depending on the type of contravention or action it may also be necessary for the work to be called to a halt until such time as the contravention or action is corrected and investigated. When working in the area of encroachment is prevalent, all open excavated trenches and foundations should be clearly marked and secured to keep people and fauna from falling in. Ensure adequate security around the site footprint. Responsibilities: ECO to monitor compliance. Dedicated OHS system to be implemented by Contractor s Safety Officer. To be monitored and audited by the Client s Safety Agent, in terms of the Construction Regulations (2014). Contractor to implement management actions. Monitoring Requirements: Occupational Health and Safety system checked by Safety Agent Management of Emergency Procedures Management Objective: Minimise environmental impacts associated with emergency procedures. Target: No site fires to be caused by construction activities and workers. Approved emergency response procedures, where relevant. Emergency Preparedness. Management Actions: Fire Comply with the National Veld and Forest Fire Act (No. 101 of 1998). - 39

50 Proper emergency response procedure to be in place for managing fires. Burning of waste is not permitted. Suitable precautions will be taken (e.g. suitable fire extinguishers, water bowsers, welding curtains) when working with welding or grinding equipment. Firefighting equipment to be strategically positioned throughout the site. All fire control mechanisms (firefighting equipment) will be routinely inspected by a qualified investigator for efficacy thereof and be approved by local fire services. All staff on site will be made aware of general fire prevention and control methods, and the name of the responsible person to alert to the presence of a fire. No fires are allowed on site, unless in dedicated areas approved by the Project Manager. Dedicated smoking areas to be provided. Accidental Leaks and Spillages Proper emergency response procedure to be in place for dealing with spills and leaks. Ensure that the necessary materials and equipment for dealing with spills and leaks are available on site, where practicable. Remediation of the spill areas will be undertaken to the satisfaction of the Project Manager and ECO. In the event of a hydrocarbon spill, the source of the spillage will be isolated and contained. The area will be cordoned off and secured. The spillage and contaminated substrate will be removed, placed in a sealed plastic bag within a closed container for storage, and disposed of as hazardous waste. The Contractor will ensure that there is always a supply of an appropriate absorbent material readily available to absorb, breakdown and where possible, encapsulate a minor hydrocarbon spillage. All staff on site will be made aware of actions to be taken in case of a spillage. Provide contact details of person to be notified in a case of spillages signage to be displayed at strategic points within the construction domain (e.g. workshop, fuel storage area, hazardous material containers). Construction vehicles and mobile plant to be maintained in a safe operating condition to prevent any possible hydrocarbon leakages resulting in spillages. Drip trays to be positioned underneath the hydrocarbon substance containment components of all stationary construction vehicles and mobile plant. Drip trays must be kept in good working condition (no holes or cracks). Should rain water collect in drip trays, it must be carefully emptied into a drum (or other sealable container) for later disposal as contaminated hazardous waste water. Responsibilities: ECO to monitor compliance. Contractor to implement management actions. Monitoring Requirements: - 40

51 Approved Emergency Response Plan. Training and awareness creation records. Signage displayed. Contractor s method statement Management of Access and Traffic Management Objective: Ensure that all construction vehicles use only dedicated access routes to construction sites. Ensure that the community have reasonable access to the area during construction. Ensure proper access control. Prevent unlawful access to construction domain. Adhere to agreements made with landowners and community members regarding access. Ensure the safety of all road users by implementing proper signage and traffic control measures. Limit construction-related nuisance to service nodes. Target: No transporting of unsafe loads. Permits are to be obtained for abnormal loads. No speeding. No accidents. Management Actions: Ensure appropriate traffic safety measures are implemented. The Contractor must comply with all driving, vehicle, licensing and driver ability requirements. Permission required for the movement of any vehicles and/or personnel outside of designated working areas. Existing roads shall be used as far as possible for construction purposes. All properties adjacent to the site must be able to access the main roads. The Contractor shall organise the site in such a manner that pedestrians and vehicles can move safely and without risks to health, including sufficient and suitable traffic routes and safe walkways with relevant signage. Construction vehicles travelling on all public roads shall adhere to the posted speed limits and speeds along proposed access route shall be controlled at 40km/h to minimise potential conflict. Access roads to be maintained in a suitable condition. Suitable erosion protective measures to be implemented for access roads during the construction phase. - 41

52 Before any work can start, the Local Traffic Department must be consulted about measures to be taken regarding pedestrian and vehicular traffic control. All reasonable precautions must be taken during construction to avoid severely interrupting the traffic flow on existing roads, especially during peak periods. Responsibilities: ECO to monitor compliance. Contractor to implement management actions. Monitoring Requirements: Signage displayed and maintained. Public complaints register. Contractor s method statement Management of Waste Management Objective: Minimise environmental impacts associated with waste. Apply waste management principles of prevent, minimise, recycle or re-use, with disposal as a last option. Target: No littering on construction site. Maintain a clean and tidy construction site. 100% record of all waste generated and disposed at waste disposal facilities. Valid disposal certificates for all waste disposed. Provision of adequate waste containers that are easily accessible and maintained. Waste bins to be removed and cleaned weekly. Management Actions: Waste management activities must comply with the National Environmental Management: Waste Act (Act No. 59 of 2008). Vermin/weatherproof bins will be provided in sufficient numbers and capacity to store domestic waste. These bins must be kept closed to reduce odour build-up and emptied regularly to avoid overfilling and other associated nuisances. Where possible, waste must be separated at source (e.g. containers for glass, paper, metals, plastics, organic waste and hazardous wastes). Ensure daily site clean-ups to prevent the build-up of litter - 42

53 The Contractor will ensure that no burying, dumping or burning of waste materials, vegetation, litter or refuse occurs. All waste will be disposed of at suitable licensed disposal sites, based on the waste type (general or hazardous). Waste material that may harm man or animals should be removed immediately. The following requirements shall be incorporated into the waste management programme: o Solid Waste: Littering by the workers is prohibited. Clearly marked litterbins must be provided on site. Suitable litter receptacles to be positioned strategically across the site at all working areas. The Contractor shall dispose of all refuse generated on site or from the activities of construction or its related activities. The contractor shall on a weekly basis dispose of all refuse at an approved refuse disposal site. Proof of disposal must be kept on record. All bins must be cleaned of litter regularly. No refuse or litter is allowed to be burnt on site. All waste removed from site must be disposed at a municipal/permitted waste disposal site. Excess concrete, building rubble or other material must be disposed of at licenced disposal facilities, and not indiscriminately over the construction site. Contaminated soil must be treated or disposed of at a permitted waste disposal site and the area rehabilitated immediately. Monitor the presence of litter on site. All staff shall be sensitised to this effect. The entire site will be cleared of construction material, metal, tins, glass bottles, and food packaging or any other type of empty container or waste material or waste equipment used by the construction team on a daily basis. The recycling of all waste is to be encouraged of both the contractor and staff. o Liquid Waste No ablution facilities to be positioned within riparian areas or buffers provided by the aquatic specialist. Sufficient ablution facilities to be provided at the Construction Camp and along construction servitude. The Contractor must install and maintain mobile toilets on site. The Contractor must provide adequate and approved facilities for the storage of used oil and contaminated hydrocarbons. Such facilities must be designed and sited with the intention of preventing pollution of the surrounding area and environment. All vehicle parking areas are to be inspected carefully for diesel, oil and other spillages at least weekly. - 43

54 All chemical spills must be contained and cleaned up by the supplier or professional pollution control personnel. o Hazardous Waste: No hazardous materials, e.g. oil, diesel and fuel should be disposed of in the surrounding environment. Any diesel, oil or petrol spillages are to be collected and stored in specially marked containers and disposed of at a permitted waste disposal site and must be treated as hazardous waste. Proof of waste disposal to be kept on site. The Contractor must maintain a hazardous material register. Responsibilities: ECO to monitor compliance. Contractor to implement management actions. Monitoring Requirements: Public complaints register. Waste register. Recycling targets. Disposal certificates. Contractor s method statement Management of Storage and Handling of Non-Hazardous Material Management Objective: Ensure the protection of the natural environment and the safety of personnel on site, by the correct management and handling of hazardous substances. Target: No pollution due to handling, use and storage of non-hazardous material. In the event of a spill, appropriate containment, clean up and disposal of contaminated material. Spills to be cleaned within 24 hours. Management Actions: Hazardous substances must be stored and handled in accordance with the appropriate legislation and standards, which include the Hazardous Substances Act (Act No. 15 of 1973), the OHS Act (Act No. 85 of 1993), relevant associated Regulations, and applicable SANS and international standards. Where required, the Contractor shall ensure he obtain the necessary authorisation/s or permit/s for the storage of hazardous chemical substances, including flammable substances. - 44

55 A copy of the Material Safety Data Sheet (MSDS) for each hazardous chemical substance stored or used on site must be available on site and communicated to the relevant persons who might be exposed to the hazards thereof. Storage and use of hazardous materials will be strictly controlled to prevent environmental contamination and must adhere to the requirements stipulated on the MSDS. Where flammable liquids are being used, applied or stored the workplace must be effectively ventilated. No person may smoke in any area in which flammable liquid is used or stored. Install an adequate number of firefighting equipment in suitable locations around the flammable liquids store. Where flammable liquids are decanted, the metal containers must be bonded or earthed. No flammable material (e.g. paper, cleaning rags or similar material) may be stored together with flammable liquids. Staff that will be handling hazardous materials must be trained to do so. Any hazardous materials must be stored within a lockable store with an impermeable floor and bund that can accommodate at least 110% of the stored volume. Suitable ventilation to be provided. All storage tanks containing hazardous materials must be placed in bunded containment areas with impermeable surfaces. The bunded area must be able to contain 110% of the total volume of the stored hazardous material. Fully stocked spill kits must be available for the clean-up of hazardous material spillages. Provide secondary containment where a risk of spillage exists. Drip trays to be placed under parked construction vehicles, equipment and other receptacles of hazardous material to prevent spillages. In the event of spillages of hazardous substances, the appropriate clean up and disposal measures are to be implemented. Spill reporting procedures to be displayed at all locations where hazardous substances are being stored. Hazardous materials will be disposed of at registered sites or handed to registered hazardous waste disposal facilities for disposal/recycling. Proper and timeous notification of any pollution incidents associated with hazardous materials. Hazardous chemical substances containers be clearly labelled with the contents and main hazardous category e.g. Flammable or Corrosive. Materials to be suitably stored to prevent environmental contamination and visual impacts. Storage requirements to be determined based on chemical qualities of material and MSDS. Where required, stored material to be protected from rain and run-off to avoid environmental contamination. - 45

56 Materials to be appropriately transported to avoid environmental contamination. Loose loads (e.g. sand, stone chip, refuse, paper and cement) to be covered. Suitable remedial measures, depending on the nature of the contaminant and the receiving environment, to be instituted for spillages. Materials to be suitably used to prevent environmental contamination. Responsibilities: Engineer and ECO to monitor compliance. Contractor to implement management actions. Monitoring Requirements: Evidence of spillages. MSDS register Management of Pollution Generation Potential Management Objective: Ensure that all possible causes of pollution are mitigated as far as possible to minimise impacts to the surrounding environment. Target: No complaints regarding pollution. No measurable signs of pollution. Noise Comply with SANS 10103:2008. Management Actions: General Accidental pollution incidents shall be reported to the ECO immediately they occur and shall be cleaned-up (to the satisfaction of the Co-ordinator Environmental Rehabilitation or ECO) by the Contractor or a nominated clean-up organisation at the expense of the Contractor. Water The following requirements for water pollution management shall apply: All fuel, chemical, oil, etc. spills must be confined to areas where the drainage of water can be controlled. Use appropriate structures and methods to confine spillages such as the construction of berms and pans, or through the application of surface treatments that neutralise the toxic effects. Oil absorbent fibres must be used to contain oil spilt in water. - 46

57 Water shall not be pumped directly from excavations into municipal stormwater drains. Such water must first be pumped into a filtration structure e.g. silt sock, to filter through prior to release. Vehicular traffic across wetland areas must be avoided. No disturbances to nesting, breeding and roaming sites of animals in or adjacent to wetland areas and sensitive areas. Air The following requirements for air pollution management shall apply: Speed limits must be implemented in all areas, including public roads and private property to limit the levels of dust pollution. Waste must be disposed of, as soon as possible at a municipal transfer station, skip or on a permitted landfill site. Waste must not be allowed to stand on site to decay, resulting in malodours. No loud music is allowed on site and in construction camps. No fires are allowed. Cognisance must be taken of the landowners and surrounding community in terms of the site layout. Ablution facilities or eating areas should ideally not be located directly adjacent to the site boundary where houses/offices as situated in a close proximity where odour or noise may become a nuisance. Soil The following requirements for soil pollution management shall apply: At least 150mm of topsoil must be stripped. Topsoil must be temporarily stockpiled, separately from subsoil and rocky material, when areas are cleared. If mixed with sub-soil the usefulness of the topsoil for rehabilitation of the site will be lost. Stockpiled topsoil must not be compacted and must be replaced as the final soil layer. No vehicles are allowed access onto the stockpiles after they have been placed. Topsoil stockpiles must not be contaminated with oil, diesel, petrol, waste or any other foreign matter, which may inhibit the later growth of vegetation and microorganisms in the soil. Excess spoil material should be disposed of at a licenced facility identified by the Contractor and approved by the Engineer and ECO. Where possible spoil should be used to fill, shape and rehabilitate borrow pits. Limited vehicular access is allowed across rocky outcrops and ridges. Soil contaminated with oil must be appropriately disposed of at a permitted landfill site or the soil can be regenerated using bio-remediation methods. Vehicles must be maintained and serviced according to the manufacturers standards. - 47

58 Daily checklists must be completed by drivers and operators before the vehicles and equipment are used. Vehicles and equipment must be turned off when not in use. Drip-trays must be placed under vehicles and equipment when not in use. All vehicles and equipment will be kept in good working order and serviced regularly. Leaking equipment will be repaired immediately or removed from the site. Suitable storage and disposal of hydraulic fluids and other vehicle oils. Emergency on-site maintenance should be done over appropriate drip trays and all oil or fuel must be disposed of according to waste regulations. No washing of plant may occur on the construction site. Plant to be washed in dedicated areas. All machinery and equipment should be inspected regularly for faults and possible leaks, these should be serviced off-site. All vehicle parking areas are to be inspected carefully for diesel, oil and other spillages weekly. Noise The provisions of SANS 10103:2008 will apply to all areas at the perimeter of the site, within audible distance of residents. Working hours to be restricted to normal working hours, so as to minimise disturbance to landowners and community members. No work will be permitted on Saturdays, Sundays, or public holidays without prior notification of the affected residents. No amplified music will be allowed on the site. The use of radios, tape recorders, compact disc players, television sets etc. will not be permitted unless at a level that does not serve as an intrusion to adjacent land-owners. Construction activities generating output levels of 85 db or more will be confined to the hours during normal working hours. The Contractor must inform local communities and residents of any activity that could cause a nuisance to them. Noise rules must be established for construction areas. The Contractor will take preventative measures (e.g. screening, muffling, timing, prenotification of affected parties) to minimise complaints regarding noise and vibration nuisances from sources such as power tools. All construction vehicles must be serviced on a frequent basis as a means of limiting excessive noise levels. The contractor must ensure the silencers of all construction vehicles and machinery are working. The Contractor will take preventative measures to minimise complaints regarding noise nuisances and will address any complaints received. - 48

59 A complaints register to be maintained and any complaints from the public must be Dust addressed immediately. Speed limits of 40 km/h must be implemented in all areas to limit the levels of dust pollution. Dust must be suppressed on access roads and construction sites by the regular application of water or a biodegradable soil stabilisation agent. Water used for this purpose must be used in quantities that must not result in the generation of run-off. Water must be sourced from a legal connection. No water must be abstracted from streams or wetlands or other illegal sources. The Contractor must notify the Principal of all schools within 50m of the site of proposed activities. The Principal must in turn ensure that children with allergies and respiratory ailments take the necessary precautionary measures during the construction period. The Contractor must ensure that construction activities do not disturb school activities e.g. dust clouds may reduce visibility affecting sports activities. Appropriate dust suppression measures or temporary stabilising mechanisms must be used when dust generation is unavoidable (e.g. dampening with water, chemical soil binders, straw, brush packs, chipping), particularly during prolonged periods of dry weather. Dust suppression to be undertaken for all bare areas, including construction area, access roads, borrow pits, etc. Fine materials must be covered during transportation. The Contractor will take preventative measures to minimise complaints regarding dust nuisances (e.g. screening, dust control, timing, and pre-notification of affected parties) and will address any complaints received. A complaints register to be maintained and any complaints from the public must be addressed immediately. Lights Prior to construction the position and type of lighting will be planned to ensure unnecessary light pollution will be eliminated. All lighting installed on site must not lead to unacceptable light pollution to the surrounding community and natural environment (e.g. use of down-lighters). Erosion Protect areas of the construction site that are susceptible to erosion through suitable measures (e.g. planting, retaining structures, erosion prevention measures such as fibre blankets, commercial anti-erosion compounds). Care must be taken to prevent carrying of sediment onto roadways and stormwater drains. - 49

60 Any erosion channels caused by construction activities to be suitably stabilised and rehabilitated. All efforts to prohibit ponding on surface and ensure stormwater runoff is channelled from the site must be made. The method used will be appropriate to the expected stormwater flows and the topography and geology of the site. Cement and Concrete Batching Cement mixing to take place on an impervious surface (e.g. cement mixing pit). Batching operations to take place in a designated area, which will be kept clean at all times. Location of batching plant to be approved by the Applicant, with due consideration of the relevant management measures. Ensure separation of clean and dirty water from batching plant. Wastewater from batching operations to be suitably disposed of or reused in the batching process. Waste concrete and cement sludge to be removed on a regular basis (to prevent overflowing) and to be disposed of at a suitable facility. Unused cement bags will be stored in an area not exposed to the weather and packed neatly to prevent hardening or leakage of cement. Used cement bags will be stored so as to prevent windblown dust and potential water contamination. Used bags should be made wet and allowed to dry before disposal at a licenced waste disposal facility. Limit concrete batching to single sites where possible. Concrete transportation must not result in spillage. Cleaning of equipment and flushing of mixers will not result in pollution, with all contaminated wash water should be contained and allowed to evaporate (with the solid residue being disposed). Water contaminated with cement must not be disposed to the environment or down stormwater drains. Suitable screening and containment will be in place to prevent windblown contamination from cement storage, mixing, loading and batching operations. All contaminated water and fines from exposed aggregate finishes will be collected and stored in sumps and will be adequately disposed of. All visible remains of excess concrete will be physically removed on completion of the plastering or concrete pouring and disposed of in an acceptable manner. Any spilled concrete to be cleaned up immediately. In practice all wastes arising from construction activities are to be handled; transported and disposed of in accordance with the relevant regulations. All efforts should be made to minimise, reclaim or recycle waste, and failing that, dispose of it in a manner licensed by the government for that purpose. - 50

61 Pollution Control Remove from site all pollution containment structures. Remove from site all temporary sanitary infrastructure and waste water disposal systems. Take care to avoid leaks, overflows and spills and dispose of any waste in the approved manner. Sewage The Contractor shall provide sanitation facilities at all camps, offices, workshops and construction sites for staff and visitors. Wastewater All contaminated waste water (e.g. with cement or hydrocarbons or chemicals) must be suitably stored and disposed of by a licenced facility. No wastewater is to be disposed of on site. Solid waste Definition: "Refuse" refers to all construction waste (such as rubble, cement bags, waste cement, timber, can, other containers, wire and nails), household and office waste. Suitable litter receptacles to be positioned strategically across the site at all working areas. Waste must be separated at source (e.g. containers for glass, paper, metals, plastics, organic waste and hazardous wastes). The Contractor shall dispose of all refuse generated on site or from the activities of construction or its related activities. The contractor shall on a weekly basis dispose of all refuse at an approved refuse disposal site. Proof of disposal must be kept on record. Littering by the workers is prohibited. Clearly marked litterbins must be provided on site. Monitor the presence of litter on site. All staff shall be sensitised to this effect. The entire site will be cleared of construction material, metal, tins, glass bottles, and food packaging or any other type of empty container or waste material or waste equipment used by the construction team on a daily basis. Waste material that may harm man or animals should be removed immediately. No refuse or litter is allowed to be burnt on site. The recycling of all waste is to be encouraged of both the contractor and staff. Hazardous Substances The Contractor must ensure that: Employees receive the necessary information and training to be able to use and store hazardous chemical substances safely. Employees obey lawful instructions regarding: - 51

62 o The wearing and use of protective equipment o The use and storage of hazardous chemical substances o The prevention of the release of hazardous chemical substances o The wearing of exposure monitoring and measuring equipment o The cleaning up and disposal of materials containing hazardous chemical substances o Housekeeping, personal hygiene and the protection of the environment The risk assessments required in terms of Construction Regulations include employee exposure to hazardous chemical substances and that the necessary measures be taken to protect persons from being detrimentally affected by hazardous chemical substances present or used in the workplace. Suppliers provide the necessary information in the form of a material safety data sheet regarding a hazardous chemical substance required to ensure the safe use and storage of that substances. An up-to-date list is kept on site of hazardous chemical substances stored and used together with the material safety data sheet of the hazardous chemical substances. Hazardous chemical substances containers be clearly marked with the contents and main hazardous category e.g. Flammable or Corrosive and the reference number of the hazardous chemical substances on the list indicated above. Hazardous chemical substances, for example asbestos dust, are not cleared by using compressed air but should be vacuumed. No person eats or drinks in a hazardous chemical substances workplace. Hazardous chemical substances waste is disposed of safely in terms of hazardous waste disposal requirements. Responsibilities: ECO to monitor compliance. Contractor to implement management actions. Contractor to conduct environmental monitoring for air quality (dust) and noise. Monitoring Requirements: Public complaints register. Evidence of pollution. Contractor s method statement. Disposal certificates. Proof of notification of adjacent landowners Management of Topsoil Management Objective: Ensure suitable removal, storage, transportation of topsoil for reuse during rehabilitation. - 52

63 Target: Adequate volume of recovered topsoil from disturbed areas to be stored for future use. No visual evidence of erosion from topsoil stockpiles. No visual evidence of erosion from areas where topsoil has been reinstated. Management Actions: During backfilling, all soils must be replaced in the same order as they were removed. Remove, stockpile and preserve topsoil for re-use during rehabilitation as the final soil layer. Topsoil should be stripped to a depth of at least 150 mm and temporarily stockpiled, separately from subsoil and rocky material, when areas are cleared. If mixed with sub-soil the usefulness of the topsoil for rehabilitation of the site will be lost. Stockpiled soil should be protected with erosion-control berms if exposed for a period of greater than 14 days during the wet season. The need for such measures will be indicated in consultation with the ECO. Topsoil stockpiles must not exceed 1.5 m in height to minimise the wind erosion effects. Topsoil stripped from different sites must be stockpiled separately and clearly identified as such, and returned to the same sites during backfill operations. Topsoil obtained from sites with different soil types must not be mixed. Topsoil stockpiles must not be contaminated with oil, diesel, petrol, waste or any other foreign matter, which may inhibit the later growth of vegetation and microorganisms in the soil. Topsoil stockpiles must be kept free of weeds and alien invasive vegetation at all times. Soil must not be stockpiled on drainage lines or near watercourses. Soil should be exposed for the minimum time possible. The timing of clearing and grubbing should be coordinated well with construction activities to avoid prolonged disturbance and exposure of soils. Topsoil from the construction camp should be stored for post-construction rehabilitation work and should not be disturbed more than is absolutely necessary. Topsoil should also be stored in such a way that does not compromise its plant-support capacity. Identify suitable areas to store topsoil. Stockpiled topsoil should not be compacted. No vehicles are allowed access onto the stockpiles after they have been placed. Stockpiled soil should be protected by erosion-control berms if exposed for a period of greater than 14 days during the wet season. The need for such measures will be indicated in the site-specific report. Topsoil stripped from different sites must be stockpiled separately and clearly identified as such. Topsoil obtained from sites with different soil types must not be mixed. - 53

64 Topsoil to be adequately protected from contamination from construction activities and by aggregate, cement, concrete, fuels, litter, oils, domestic and industrial waste. Following the construction phase, the topsoil should be used in rehabilitation of affected areas and landscaping around the development. Responsibilities: ECO to monitor compliance. Contractor to implement management actions. Monitoring Requirements: Contractor s method statement. Specialist Studies Management of Erosion Potential Management Objective: Minimise environmental impacts associated with soil erosion. Target: No visual evidence of erosion as a result of construction activities. Management Actions: Suitable erosion protective measures to be implemented for access roads. Stabilisation of cleared areas to prevent and control erosion. Monitoring to be conducted to detect erosion. Rehabilitate all areas disturbed during construction. The Contractor shall take measures to the approval of the Engineer to ensure that there is no undue stormwater damage and soil erosion resulting from the construction activities outside the construction camp and works areas. During construction, water diversion soil berms will be constructed to divert surface and stormwater from traversing the disturbed areas. Cross and side stormwater drainage measures shall be constructed on access and haul roads to the site and roads within the site. The Contractor shall ensure that run off from access and haul roads, and water diverted into cross and side drains, does not cause erosion. Manage stormwater from construction site to avoid environmental contamination and erosion. Settling will be allowed for in a high-capacity attenuation pond downstream of the site. At all stages of the project lifespan, stormwater control measures as specified by the Engineer and ECO shall be applied to keep soil on site by minimising: - 54

65 o o o o erosion of temporary stockpiles of topsoil; erosion from construction roads, excavations and other cleared areas; silt-laden run off from all areas stripped of vegetation, including excavation surfaces and stockpiles of spoil and topsoil; contaminated run off from storage areas. Responsibilities: ECO to monitor compliance. Contractor to implement management actions. Monitoring Requirements: Contractor s method statement Management of Excavations Management Objective: Minimise environmental impacts associated with excavations. Target: No damage to sensitive environmental features outside construction area during excavations. Management Actions: Construction activities to remain within the designated construction areas. Subsoil and topsoil should be stockpiled separately to be returned for backfilling in the correct soil horizon order. Suitable barricading to be erected around open excavations/trenches, as per the Construction Regulations (2014). Provide signage as a warning of open excavations. Divert runoff away from excavations, where necessary. Trench lengths will be kept as short as practically possible. Trench walls are to be stabilised using battering, shoring and bracing or similar techniques depending on the stability of the trench sides (where relevant). Inspect open trenches at least daily basis to ensure that animals have not become trapped. Such animals will be safely removed and released, where possible. Special equipment for handling of venomous snakes should be available on site to ensure safe removal. Filing of trenches to make provision for subsidence. Responsibilities: ECO to monitor compliance. Contractor to implement management actions. - 55

66 Monitoring Requirements: Barricading of excavations. Excavation register. Contractor s method statement Management of Visual Aspects Management Objective: Minimise impacts to the aesthetics / visual quality. Ensure that the visual appearance of the construction site is not an eyesore the adjacent areas. Target: No complaints regarding impacts to visual quality. Management Actions: Advertising and lighting will be in accordance with relevant standards. Lighting must not constitute an eyesore/hazard to users of the road and the surrounding community. Lighting will be sufficient to ensure security but will not constitute light pollution to the surrounding areas. On-going housekeeping to maintain a tidy construction area. Construction camp to be positioned so as to minimize its visual impacts. Damage to the natural environment should be minimised. Vegetation should be cut only if absolutely necessary. The clearing of all sites should be kept to a minimum and surrounding vegetation should as far as possible be left intact as a natural shield. The fragmentation of stands of indigenous vegetation and straight lines on trees should as far as possible be minimized. No painting or marking of natural features shall be allowed. Marking for surveying and other purposes shall only be with pegs and beacons. Trees and all woody shrubs should be protected from damage to provide a natural visual shield. Excavated material should not be placed on such plants nor should plant drive over them. No construction rubble, construction material, refuse, litter or any other material not found naturally in the surroundings should be allowed at any time to be lying around on the construction site. Particular aspects of concern to landowners and local residents should be addressed during construction. Daily site clean-ups to prevent the build-up of litter. - 56

67 A complaints register to be maintained and any complaints from the public must be addressed immediately. Responsibilities: Engineer and ECO to monitor compliance. Contractor to implement management actions. Monitoring Requirements: Public complaints register. Contractor s method statement Management of Flora Management Objective: Control alien plants and noxious weeds. Target: Ongoing eradication of alien plants and noxious weeds. Management Actions: Comply with the requirements of the National Environmental Management: Biodiversity Act (No. 10 of 2004) and National Forests Act (No. 84 of 1998). Newly cleared soils must be re-vegetated and stabilised as soon as construction has been completed. There should be an on-going monitoring programme to control and/or eradicate newly emerging invasive species. The rehabilitation of disturbed areas should receive high priority. Plant species used during rehabilitation should be site specific and according to the surrounding vegetation composition. A permit from DAFF is required before construction commences in order to disturb, destroy or remove the Marula tree noted along the proposed road reserve. Clearly demarcate the construction area. Vegetation clearing should be kept to a minimum (restricted to construction areas), and this should only occur where it is absolutely necessary. Rehabilitate all disturbed areas as soon as the construction is completed along the proposed development routes. Ensure that all personnel have the appropriate level of environmental awareness and competence. Prevent contamination of natural areas. - 57

68 Proliferation of alien and invasive species is expected within the disturbed areas and they should be eradicated and controlled to prevent further spread. No storage of any construction material on sensitive areas. Avoid translocating stockpiles of topsoil from one place to sensitive areas in order to avoid translocating soil seed banks of alien species. Control of alien invasive species and noxious weeds for areas disturbed by the construction activities, in accordance with the requirements of the National Environmental Management: Biodiversity Act (NEMBA) (No. of 2004) Alien and Invasive Species Regulations. Eradication method to be approved by the Project Manager. To prevent unnecessary alien plant infestations, an alien plant monitoring and eradication programme needs to be in place, at least until the disturbed areas have recovered and properly stabilised. Promote awareness of all personnel. The establishment of pioneer species should be considered with the natural cycle of rehabilitation of disturbed areas, which assists with erosion control, dust and establishment of more permanent species. This can be controlled during construction phase and thereafter more stringent measures should be implemented during the rehabilitation and post rehabilitation. The most significant way to mitigate the loss of habitat is to limit the construction footprint within the natural habitat areas remaining. Disturbance of vegetation must be limited to the construction areas. Areas cleared of vegetation must be re-vegetated prior to contractor leaving the site. During site preparation, topsoil and subsoil are to be stripped separately from each other and must be stored separately from spoil material for use in the rehabilitation phase. It should be protected from wind and rain, as well as contamination from diesel, concrete or wastewater. Vehicles and construction workers should under no circumstances be allowed outside the site boundaries to prevent impact on the surrounding vegetation. All stockpiles, construction vehicles, equipment and machinery should be situated away from the natural vegetation. Prevent contamination of natural areas. Appropriate measures should be implemented in order to prevent potential soil pollution through fuel and oil leaks and spills and then compliance monitored by an appropriate person. Make sure construction vehicles are maintained and serviced to prevent oil and fuel leaks. No structures should be built outside the area demarcated for the development. Although it is unavoidable that sections of the project infrastructure development will need to traverse areas of potential sensitivity, these should be constructed in such cases so as to avoid further impact to sensitive areas. - 58

69 Areas cleared of natural vegetation must be re-vegetated with indigenous vegetation prior to contractor leaving the site. All construction and maintenance vehicles must stick to properly demarcated and prepared roads. Off-road driving should be strictly prohibited. No fires should be allowed at the site. No dumping of any form is permitted. Construction activities should be restricted to the development footprint area and then the compliance in terms of footprint can be monitored by Environmental Control Officer (ECO). No unauthorised vehicles should be allowed to drive through the site during the construction activities. No damage and/or removal/trapping/snaring of indigenous plant or animal material for cooking and other purposes will be allowed. Bare surfaces should be grassed as soon as possible after construction to minimise time of exposure. Locally occurring, indigenous grasses should be used. Take appropriate remedial action where vegetation establishment has not been successful or erosion is evident. Only locally indigenous vegetation is to be used for rehabilitation. All waste generated by the construction activities will be stored in a temporary demarcated storage area, prior to disposal thereof at a licensed registered landfill site. As much vegetation growth as possible should be promoted within the proposed project area in order to protect soils and to reduce the percentage of the surface area which is left as bare ground. Responsibilities: Applicant acquire permits ECO to monitor compliance. Contractor to implement management actions. Monitoring Requirements: Permits if required. Successful rehabilitation. Contractor s method statement Management of Fauna Management Objective: Ensure the protection of animals Target: No direct / indirect harm to animals from construction activities. - 59

70 Management Actions: Comply with the requirements of the National Environmental Management: Biodiversity Act (No. 10 of 2004), Natal Nature Conservation Ordinance 15 of 1974 and Animal Protection Act (No. 71 of 1962). No wilful harm to any animals, unless a direct threat is posed to a worker s health or safety. Any fauna (mammal, bird, and reptile) that becomes trapped in the trenches or in any construction or operational related activity may not be harmed and must be placed rescued and relocated by an experienced person. No hunting/trapping or any other method of catching of any animal or bird may be performed on site. Animals residing within the designated area shall not be unnecessarily disturbed. Before construction starts, construction workers must be educated with regards to littering and poaching. The Contractor and his/her employees shall not bring any domestic animals onto site. Toolbox talks should be provided to contractors regarding disturbance to animals. Particular emphasis should be placed on talks regarding snakes. Construction areas must be demarcated but should allow for the migration of small faunal species out of the construction zone. Fencing types must be selected for minimal disturbance to animal movement corridors. Prevent contamination of natural areas. No structures should be built outside the area demarcated for the development. Although it is unavoidable that sections of the project infrastructure development will need to traverse areas of potential sensitivity, these should be constructed in such cases so as to avoid further impact to sensitive areas. If any herpetological species (amphibians and reptiles) be encountered or exposed during the construction phase, they should be removed and relocated to natural areas in the vicinity. This remedial action requires the employment of a herpetologist and or ecologist to oversee the removal of any herpetofauna during the initial ground clearing phase of construction (i.e. initial ground-breaking by earthmoving equipment). Training of construction workers to recognise animal species will reduce the probability of fauna being harmed unnecessarily. The contractor must ensure that no faunal species are disturbed, trapped, hunted or killed during the construction phase. No trapping or any other method of catching of any animal or bird may be performed on site Any fauna (mammal and reptile) that becomes trapped in the trenches or in any construction or operational related activity may not be harmed and must be placed rescued and relocated by an experienced person. - 60

71 Toolbox talks should be provided to contractors regarding disturbance to animals. Particular emphasis should be placed on talks regarding snakes. Illegal hunting is prohibited. No damage and/or removal/trapping/snaring of indigenous plant or animal material for cooking and other purposes will be allowed. The fauna on site should not be unnecessarily disturbed. Responsibilities: Applicant acquire permits (if applicable) ECO to monitor compliance. Contractor to implement management actions. Monitoring Requirements: Permits (if applicable). Contractor s method statement Management of Archaeological and Cultural Features Management Objective: To have no adverse impact on the historical inheritance of the area. The protection of land considered to be of traditional cultural value. The protection of known archaeological sites against vandalism, destruction and theft during the construction phase. To avoid damage to or destruction of previously unknown or excavated archaeological artefacts during construction. The preservation and appropriate management of new findings should these be discovered during construction. Management Target: No archaeological and cultural resources or graves to be damaged during construction. Actions: In the unlikely event of any unmarked human burials, burial pits, potsherds or stone tools being uncovered during earthworks for the proposed development, these must be reported immediately to the South African Heritage Resources Agency Burials and Graves Unit (Mrs Thinghangwi Thivhase / 4968). Should any remains be found on site that is potentially human remains, the South African Police Service and archaeologist should also be contacted. Under no circumstances shall archaeological artefacts be removed, destroyed or interfered with by the Contractor, his employees, his sub-contractors or his sub

72 contractors' employees. Any person who causes intentional damage to archaeological or historical sites and artefacts could be penalised or legally prosecuted in terms on the Act. Responsibilities: Project Manager and ECO to monitor compliance. Contractor to implement management actions. Monitoring Requirements: Contractor s method statement Management of Water on Site Management Objective: Minimise environmental impacts associated with storm water as well as water services for construction workers. Minimise stormwater runoff from the site onto neighbouring roads. Minimise water use through recycling and water efficient practices. Target: No visual evidence of erosion caused by wastewater or stormwater practices. No environmental contamination associated with wastewater or stormwater practices. Management Actions: All construction activities to comply with National Water Act (Act No. 36 of 1998) (NWA). During the construction stage, water will be required for various purposes, such as concrete batching, washing of plant and equipment in dedicated areas, dust suppression, potable use by construction workers, etc. Water tankers will supply water to the site. Manage stormwater from construction site to avoid environmental contamination and erosion. No vehicle maintenance or wash-bay will be allowed on site. These activities must take place off-site at a well-managed facility.. Stormwater runoff from potential pollution sources shall be collected and disposed of as hazardous contaminated water.. Measures must be taken to divert unpolluted water and runoff away from the site. All discharges to comply with legal requirements associated with NWA. All wastewater discharges to comply with legal requirements associated with the National Water Act (Act No. 36 of 1998), including the General Authorisation that specifically deals with S21 (f) and (g) water uses. - 62

73 Ensure proper storage of material (including fuel, paint) that could cause water pollution. Ensure proper storage and careful handling of hazardous substances with spill prevention materials at hand. Reduce sediment loads in water from dewatering operations. All dewatering must be done through temporary sediment traps (e.g. straw bales, silt fences, bidum, etc.). These are to be maintained regularly and removed when no longer in use. Materials can be re-used. Responsibilities: Project Manager and ECO to monitor compliance. Contractor to implement management actions. Monitoring Requirements: Public complaints register. Contractor s method statement Management of Watercourses Management Objective: Ensure that the watercourses (including affected rivers, natural channels, and drainage lines) are protected and incur minimal negative impact to resource quality (i.e. flow, water quality, riparian habitat, morphology, and aquatic biota). Existing water use entitlements not to be affected. Target: Minimise the habitat unit destruction and potential loss of wetland/aquatic-dependent biodiversity. Unaltered downstream flow regime. Downstream water quality to remain within acceptable ranges, as determined through baseline monitoring. Ecological category not to be influenced by construction activities. Management Actions: Construction of Roads and Stormwater Systems o The footprint area of the road should be kept a minimum. The footprint area must be clearly demarcated to avoid unnecessary disturbances to adjacent areas; o All construction activities and access must make use of the existing road; o Silt traps and fences must be placed in the preferential flow paths along the road to prevent sedimentation of the watercourse; o Temporary stormwater channels should be filled with aggregate and/or logs (branches included) to dissipate flows; and - 63

74 o A suitable stormwater plan must be compiled for the road. This plan must attempt to displace and divert stormwater from the road and discharge the water into adjacent areas without eroding the receiving areas. It is preferable that run-off velocities be reduced with energy dissipaters and flows discharged into the local watercourses. Operation of Stormwater Systems o In the case of stormwater systems leading into wetland and terrestrial areas, a gabion or reno mattress must be installed at the end of the stormwater system to ensure that overland flow channelled into the wetland does erode into the soil profile. The width of this erosion mitigation feature must exceed the width of the stormwater system by 50cm on each side and be 200cm in length. Figure 6, labels A to F indicates the locations where erosion mitigation is applicable to the stormwater systems. - 64

75 Figure 6: Location for erosion mitigation features (The Biodiversity Company, 2019) - 65