PROPOSED RESIDENTIAL DEVELOPMENT ON ERF 271 BAKKERSHOOGTE, SOMERSET WEST, WESTERN CAPE PROVINCE.

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1 PROPOSED RESIDENTIAL DEVELOPMENT ON ERF 271 BAKKERSHOOGTE, SOMERSET WEST, WESTERN CAPE PROVINCE. SPECIALIST FRESHWATER ASSESSMENT Prepared for: Headland Town Planning Prepared by: Natasha van de Haar SACNASP Reg. no /11 Date: February 2018

2 KHULA Page 2 Executive Summary KHULA Environmental Consultants (hereafter KHULA ) has been appointed by Headland Town Planners to undertake a specialist assessment of the impact of the proposed residential development on Erf 271 Bakkershoogte (the proposed site) on the site s freshwater features. The specialist assessment is required as part of the Basic Assessment process in terms of the National Environmental Management Act (NEMA) Environmental Impact Assessment (EIA) Regulations, 2014 as well as the application for water use authorisation in terms of Section 21 of the National Water Act (NWA). A field survey was undertaken within the proposed site and immediate surroundings on the 18 th of March 2017 and two freshwater features were identified. A seep wetland within the proposed site and a larger valley bottom wetland located on the south-eastern boundary of the proposed site. Both these features were assessed as part of the Freshwater Specialist Study. Freshwater features located within 500 m of the proposed site were discussed on a desktop level only. Two layout alternatives are being considered, namely the Applicant s Preferred Layout Plan and an Alternative Layout Plan. The Applicant s Preferred Layout Plan incorporates 7 residential units and one private driveway which will allow access to all the units, as well as a private open space extending over approximately 1053 m 2 wherein wetland rehabilitation is proposed. Approximately 623 m 2 of the 856 m 21 seep wetland will need to be infilled in order for the proposed development to prove feasible. The private open space will incorporate the remaining portion of the seep wetland and will not encroach onto the valley bottom wetland. In addition, the current wetland habitat will be expanded (an additional wetland area of approximately 864 m 2 ) within the area earmarked for private open space, and the immediate surroundings will be rehabilitated (total area extending 1053 m 2 2 including retained wetland habitat). A 15 m buffer is required for the valley bottom wetland 3 which will overlap with the area proposed for rehabilitation. The Alternative Layout Plan proposes the development of 7 larger units and one private driveway. No wetland habitat will be conserved and the 15 m buffer required for the valley bottom wetland will also be developed. Summary of background Information: The proposed site falls within the quaternary catchment G22J, within the Berg Water Management Area (WMA) and within the Greater Cape Town sub-water Management Area (sub-wma) as defined by the National Freshwater Ecosystem Priority Areas project (NFEPA; 2011). According to Mucina and Rutherford (2006, updated 2012), the proposed site is located within the Boland Granite Fynbos vegetation type, listed as Vulnerable by the National List of Threatened Terrestrial Ecosystems (2011). Furthermore, wetlands associated with the proposed site fall within the West Coast Granite Renosterveld wetland vegetation group (NFEPA, 2011), listed as Critically Endangered within the region. The concrete reservoir located immediately to the west of the proposed site is indicated as an artificial wetland by the NFEPA database (2011) and a natural to semi-natural valley bottom wetland is located adjacent to the eastern boundary of the proposed site (City of Cape Town s wetland layer, 2015). The valley bottom wetland was selected as a Critical Ecological Support Area (CESA) and areas along this wetland system which have been impounded were selected as Other Ecological Support Areas (OESAs). 1 Total extent of wetland within the proposed site. 2 It has been assumed that the proposed swale, refer to the rehabilitation plan for details, will result in the formation of at least temporary wetland habitat within the majority of the open space area, with the possible exclusion of the north eastern corner which is the highest portion of the terrain. 3 Determined with the use of Buffer Zone Guidelines for Rivers, Wetlands and Estuaries (Macfarlane and Bredin, 2016).

3 KHULA Page 3 Summary of freshwater assessment results: Historical imagery available on Google Earth Pro (2017) revealed that the site has been subjected to significant earthworks several times in the past decade. After the most recent earthworks the site has been left undisturbed and alien species such as Pennisetum clandestinum have established and currently dominate the majority of the site. Wetland habitat, dominated by Typha capensis, was identified within the centre of the site, however the source of the water could not be determined. For the purposes of this study it has been assumed that the wetland habitat identified historically formed part of a larger seep wetland that has been fragmented and in some areas entirely lost due to surrounding residential developments. The remaining portion of the seep wetland presently augments the larger valley bottom wetland located on the south-eastern boundary of the site. WET-Health 4 is defined as a measure of the similarity of a wetland to a natural or reference condition. The overall wetland health 5 score calculated for the seep wetland falls within a Present Ecological State (PES) Category E (The change in ecosystem processes and loss of natural habitat and biota is great but some remaining natural habitat features are still recognizable) and for the valley bottom wetland a PES Category C was calculated (Moderately modified. A moderate change in ecosystem processes and loss of natural habitats has taken place but the natural habitat remains predominantly intact). The WET-Ecoservices tool was applied to both wetland features and both features calculated the highest scores for the assimilation of solutes due to the urban setting, followed by stream flow regulation and erosion control. All Ecosystem Services will be lost from the portion of the seep wetland that will need to be infilled should the development of the Applicant s Preferred Layout Plan be authorised. However, it is the opinion of the specialist that a wetland system with similar functions and services can be recreated within the eastern portion of the proposed site, provided that the area receives sufficient volumes of water throughout the year to successfully sustain a wetland floral community. With the introduction of indigenous floral species with high assimilation capability, it is even considered possible to increase the extent to which the Ecosystem Services are currently provided within the proposed site. The overall Ecological Importance and Sensitivity (EIS) score calculated for the seep wetland falls within the low category implying that the wetland is not ecologically important and sensitive at any scale. However, the overall EIS score calculated for the valley bottom wetland falls within a high category implying that the wetland is sensitive and ecologically important. Depending on the layout alternative authorised, either a portion of the seep wetland or the entire feature will need to be infilled if the development proceeds. Therefore, the application of a buffer to the seep wetland is therefore not deemed practical. It is however considered important that the eastern portion of the proposed site, wherein rehabilitation as part of the Applicant s Preferred Alternative Plan is proposed, is managed to ensure an ecological category of at least C is maintained for the remaining extent of wetland habitat within this portion of the development for the remainder of the operational phase. The buffer zone width for the valley bottom wetland was determined with the use of the Buffer Zone Guidelines for Rivers, Wetlands and Estuaries (Macfarlane and Bredin, 2016). The required construction and operational phase buffers were determined to be 15 m. Impact assessment: Two layout alternatives were proposed by the proponent and assessed as part of the impact assessment. Direct impacts considered probable during the construction phase include: Loss of wetland habitat. Disturbance of wetland habitat. 4 Macfarlane et al., 2007 WRC Report No TT 340/09 5 (hydrology score) x 3 + (geomorphology score) x 2 + (vegetation score) x 2 / 7 = overall wetland health

4 KHULA Page 4 Alteration of the hydrological regime. Water quality impairment. Direct impacts considered probable during the operational phase include: Transformation of wetland habitat. Disturbance of wetland habitat (only applicable to the Alternative Layout Plan) Increase in wetland biodiversity and function (only applicable to the Applicant s Preferred Layout Plan). Potential direct impacts expected to occur as a result of the construction and operation of both development alternatives as well as potential impacts associated with the no go alternative are summarised in the tables below. Table A: Impact assessment results for the No Go Scenario. Extent Intensity Duration Consequence Probability Significance Status Confidence Low Long term Low Definite Low -ve Medium Table B: Impact assessment results for the construction phase applicable to the Applicant s Preferred Layout Plan. without without with without with without with Extent Intensity Duration Consequence Probability Significance Status Confidence Loss of wetland habitat Long Medium term Medium Definite Medium -ve High (2) High Medium (2) Medium (2) Low Medium (2) Low (2) Disturbance of wetland habitat Long term High Definite High -ve High Short term Very Low Definite Very Low -ve High Alteration of the hydrological regime Long term Medium Definite Medium -ve High Long term Low Definite Low -ve Medium Long term Short term Water quality impairment Medium Definite Medium -ve Medium Very Low Probable Very Low -ve Medium Table C: Impact assessment results for the construction phase applicable to the Alternative Layout Plan. without Extent Intensity Duration Consequence Probability Significa nce Statu s Confidence Loss of wetland habitat High Long term High Definite High -ve High Disturbance of wetland habitat

5 KHULA Page 5 without with without without with Extent Intensity Duration Consequence Probability Significa nce Statu s Confidence Medium Long term (2) Medium Definite Medium -ve High Low Short term Very Low Definite Very Low -ve High Alteration of the hydrological regime Medium Long term (2) Medium Definite Medium -ve High Water quality impairment Medium Long term (2) Medium Definite Medium -ve High Low Short term Very Low Definite Very Low -ve Medium Table D: Impact assessment results for operational phase applicable to the Applicant s Preferred Layout Plan. without with without with Extent Intensity Duration Consequence Probability Significance Status Confidence Increased stormwater runoff into retained wetland habitat from hard surfaces Long Medium Highly term Medium Medium -ve Medium (2) Probable Low Low Medium (2) Long term Low Probable Low -ve Medium Increase in wetland biodiversity and function Short term Long term Very Low Probable Very Low +ve Medium Medium Highly probable Medium +ve High Table E: Impact assessment results for the operational phase applicable to the Alternative Layout plan. without with without with Extent Intensity Duration Consequence Probability Significance Status Confidence Increase in velocity and volume of stormwater entering wetland habitat Long Medium term Medium Definite Medium -ve High (2) Low Medium (2) Low Long term Low Probable Low -ve Medium Disturbance of wetland habitat Long term Medium Definite Medium -ve High Long term Low Probable Low -ve Medium

6 KHULA Page 6 Conclusion and recommendation: One seep wetland was identified within the centre of the proposed site. A portion of the seep wetland will need to be infilled in order for the proposed residential development to prove feasible. The proponent did however commit to the rehabilitation of the eastern portion of the proposed site, in an effort to recreate the area of wetland habitat that will be lost as well as to rehabilitate and by so doing, improve the 15m buffer required for the valley bottom wetland. The proposed development will however require Environmental Authorisation in terms of the NEMA Environmental Impact Assessment Regulations (2014) as well as authorisation from the Department of Water and Sanitation (DWS) in terms of section 21 (c) and (i) of the National Water Act (NWA). Two alternative layouts have been proposed for the proposed residential development, namely the Applicant s Preferred Layout Plan and the Alternative Layout Plan. The loss of wetland habitat as a result of the extensive infilling associated with the Alternative Layout Plan, was rated to be of high (negative) impact significance and no measure would decrease the significance of the impact. The layout and design of the Applicant s Preferred Layout Plan has accommodated both the measures recommended in this report as well as the comments received from DWS following the pre-application meeting, it is therefore the opinion of the specialist that wetland biodiversity and function can be increased with the development of this alternative to the extent that a net gain in wetland function and wetland service provision is achieved. It is therefore the opinion of the specialist that authorisation for the development of the Applicants Preferred Alternative, from a freshwater ecological perspective, may be granted, provided that all essential measures listed within this report are strictly adhered too.

7 KHULA Page 7 TABLE OF CONTENTS EXECUTIVE SUMMARY... 2 LIST OF FIGURES... 8 LIST OF TABLES... 8 DISCLAIMER... 9 SPECIALIST DECLARATION... 9 GLOSSARY ACRONYMS INTRODUCTION PROJECT BACKGROUND LIMITATIONS AND ASSUMPTIONS APPLICABLE LEGISLATION National Water Act (Act no.36 of 1998) General Notice 509 of the NWA (2016) National Environmental Management Act (Act no. 107 of 1998) SCOPE OF WORK METHOD OF ASSESSMENT DESKTOP ASSESSMENT WATERCOURSE IDENTIFICATION AND DELINEATION FRESHWATER FEATURE CLASSIFICATION WETLAND ECOSERVICES AND FUNCTION ASSESSMENT PRESENT ECOLOGICAL STATE (PES) - WET-HEALTH ECOLOGICAL IMPORTANCE AND SENSITIVITY (EIS) RECOMMENDED ECOLOGICAL CATEGORY (REC) BUFFER DETERMINATION IMPACT ASSESSMENT OFFSET REQUIREMENTS RESULTS OVERVIEW OF BACKGROUND INFORMATION DESCRIPTION OF THE PROPOSED SITE AQUATIC ECOSYSTEM CLASSIFICATION WATERCOURSE DELINEATION PRESENT ECOLOGICAL STATE ECOSYSTEM SERVICES ECOLOGICAL IMPORTANCE AND SENSITIVITY (EIS) RECOMMENDED ECOLOGICAL CATEGORY AND BUFFER ZONE DETERMINATION ACTIVITY DESCRIPTION ASSESSMENT OF IMPACTS IMPACT IDENTIFICATION Applicant s Preferred Alternative Alternative Layout Plan NO GO SCENARIO INDIRECT IMPACTS CUMULATIVE IMPACTS... 47

8 KHULA Page 8 6. OFFSET REQUIREMENTS CONCLUSION AND RECOMMENDATION REFERENCES APPENDIX 1 IMPACT ASSESSMENT CRITERIA APPENDIX 2 OFFSET CALCULATION List of Figures Figure 1: Topo-Cadastral map dated 2010 presenting the proposed site in relation to the surrounding areas Figure 2: Proposed site, presented in green, in relation to surrounding areas (Google Earth Pro, 2017). 14 Figure 3: Classification System for wetlands and other aquatic ecosystems in South Africa Figure 4: Wetlands in relation to the proposed site (NFEPA, 2011 and City of Cape Town wetland layer, 2017) Figure 5: Areas where the most significant historical disturbance has taken place presented with yellow Figure 6: Overview of the proposed site, the photograph on the left was taken in a north-eastern direction and the photograph on the right taken in a south-eastern direction Figure 7: Freshwater features identified within proposed site and immediate surrounding area (seep wetland presented in blue and the valley bottom wetland presented in red) Figure 8: Valley bottom wetland located to the east of the proposed site Figure 9: Severely disturbed seep wetland identified within the centre of the proposed site Figure 10: Channelled valley bottom Figure 11: Representative photos of soils investigated by means of hand auguring Figure 12: WET-EcoServices results Figure 13: Valley bottom wetland (presented with red) with 15m buffer (presented with orange) (Google Earth Pro, 2017) Figure 14: Applicant s Preferred Layout Plan Figure 15: Alternative Layout Plan Figure 16: The hierarchy List of Tables Table 1: Main attributes for the Southern Folded Mountains Ecoregion (State of the Rivers, 2011) Table 2: Aquatic ecosystem classification (Ollis et. al. 2013) Table 3: WET-Health results table Table 4: PES categories used by WET-Health for describing the integrity of wetlands (after Macfarlane et al., 2007) Table 5: Classes for determining the likely extent to which a benefit is being supplied based on the overall score for that benefit (after Kotze et al., 2007) Table 6: WET-EcoServices results table Table 7: EIS results Table 8: Ecological Importance and Sensitivity Categories Table 9: Impact assessment results for the construction phase Table 10: Impact assessment results for operational phase Table 11: Impact assessment results for the construction phase Table 12: Impact assessment results for operational phase Table 13: Impact assessment results for the No Go Scenario Table 14: Wetland Offset Results summary Table 15: Criteria used to determine the consequence of the impact Table 16: Method used to determine the consequence score Table 17: Probability classification Table 18: Impact significance rating

9 KHULA Page 9 Table 19: Impact status and confidence classification Table 20: Determining Offset Requirement Table 21: Assessing receiving areas Disclaimer KHULA Environmental Consultants has exercised all due care in the reviewing of all available information and the delineation of the watercourse boundary. The accuracy of the results and conclusions from the assessment are entirely reliant on the accuracy and completeness of available desktop information, site conditions at the time of the assessment and professional judgment. KHULA does not accept responsibility for any errors or omissions in the assessment and therefore does not accept any consequential liability arising from commercial decisions made, which are based on the information contained in this report. Opinions presented in this report apply to conditions/site conditions applicable at time of review and those conditions which are reasonably foreseeable. Specialist Details and Experience Natasha van de Haar Natasha is a registered Professional Natural Scientist (Pr.Sci.Nat) with the South African Council for Natural Scientific Professions (SACNASP). She also holds a Masters Degree in Science (M.Sc.) in the field of Botany. Over the course of Natasha s career, she completed a number of floral identification short courses and also obtained a certificate of competence for wetland assessments from Rhodes University. She is also a member of the South African Wetland Society, Botanical Society of SA as well as the Western Cape Wetlands Forum. Her career kicked off as a field ecologist in 2009, focusing on floral biodiversity and ecological functioning, with special mention of wetland ecology and functioning within South Africa (all provinces). She further worked as a specialist project member in Mauritius, Lesotho and Ghana. During the course of her career she obtained extensive experience in conducting terrestrial as well as wetland related surveys in the mining, residential and infrastructure development industries as well as development of several alternative energy facilities. Natasha also gained experience in Biodiversity Offset Initiatives as well as RDL/protected plant permit applications. Presently her main focus is wetland assessments including delineation as well as present ecological state and function assessments. Specialist Declaration I, Natasha van de Haar, as the appointed independent specialist, in terms of the 2014 EIA Regulations, hereby declare that I: I act as the independent specialist in this application; I perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant; regard the information contained in this report as it relates to my specialist input/study to be true and correct, and do not have and will not have any financial interest in the undertaking of the activity, other than remuneration for work performed in terms of the NEMA, the Environmental Impact Assessment Regulations, 2014 and any specific environmental management Act; I declare that there are no circumstances that may compromise my objectivity in performing such work; I have expertise in conducting the specialist report relevant to this application, including knowledge of the Act, Regulations and any guidelines that have relevance to the proposed activity; I will comply with the Act, Regulations and all other applicable legislation;

10 KHULA Page 10 I have no, and will not engage in, conflicting interests in the undertaking of the activity; I have no vested interest in the proposed activity proceeding; I undertake to disclose to the applicant and the competent authority all material information in my possession that reasonably has or may have the potential of influencing - any decision to be taken with respect to the application by the competent authority; and - the objectivity of any report, plan or document to be prepared by myself for submission to the competent authority; I have ensured that information containing all relevant facts in respect of the specialist input/study was distributed or made available to interested and affected parties and the public and that participation by interested and affected parties was facilitated in such a manner that all interested and affected parties were provided with a reasonable opportunity to participate and to provide comments on the specialist input/study; I have ensured that the comments of all interested and affected parties on the specialist input/study were considered, recorded and submitted to the competent authority in respect of the application; all the particulars furnished by me in this specialist input/study are true and correct; and I realise that a false declaration is an offence in terms of regulation 48 and is punishable in terms of section 24F of the Act. Signature of the specialist: Name of Specialist: Natasha van de Haar Date: 2018/02/01

11 KHULA Page 11 Glossary 6 Alluvial soil: Biodiversity: Buffer: Catchment: Chroma: A deposit of sand, mud, etc. formed by flowing water, or the sedimentary matter deposited thus within recent times, especially in the valleys of large rivers. The number and variety of living organisms on earth, the millions of plants, animals and micro-organisms, the genes they contain, the evolutionary history and potential they encompass and the ecosystems, ecological processes and landscape of which they are integral parts. A strip of land surrounding a wetland or riparian area in which activities are controlled or restricted, in order to reduce the impact of adjacent land uses on the wetland or riparian area. The area contributing to runoff at a particular point in a river system. The relative purity of the spectral colour which decreases with increasing greyness. Critical Biodiversity Areas: Areas of the landscape that need to be maintained in a natural or nearnatural state in order to ensure the continued existence and functioning of species and ecosystems and the delivery of ecosystem services. Delineation (of a wetland): Ecoregion: Ephemeral stream: Groundwater: Habitat: Hue (of colour): Hydromorphic soil: Hydrology: Hydrophytes: Halophytes: Helophytes: Indicator species: Intermittent flow: Macrophyte: Perennial: Riparian area delineation: Riparian habitat: Shrub: Temporary zone: Terrain unit morphological classes: To determine the boundary of a wetland based on soil, vegetation and/or hydrological indicators. A recurring pattern of ecosystems associated with characteristic combinations of soil and landform that characterise that region. A stream that has transitory or short-lived flow. Subsurface water in the saturated zone below the water table. The natural home of species of plants or animals. The dominant spectral colour. A soil that, in its undrained condition, is saturated or flooded long enough to develop anaerobic conditions favouring the growth and regeneration of hydrophytic vegetation (vegetation adapted to living in anaerobic soils). The study of the occurrence, distribution and movement of water over, on and under the land surface. Also called obligate wetland plants - plants that are physiologically bound to water where at least part of the generative cycle takes place in the water or on the surface. Salt tolerant plants. Also called facultative wetland plants - essentially terrestrial plants of which the photosynthetically active parts tolerate long periods of submergence or floating on water. A species whose presence in an ecosystem is indicative of particular conditions (such as saline soils or acidic waters). Flows only for short periods. A large plant - in wetland studies usually a large plant growing in shallow water or waterlogged soils. Permanent - persisting from year to year. The determination and marking of the boundary of the riparian area. Includes the physical structure and associated vegetation of the areas associated with a watercourse which are commonly characterized by alluvial soils (deposited by the current river system) 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 areas. A shrub is a small to medium-sized woody plant. The zone that is alternately inundated and exposed. Areas of the land surface with homogenous form and slope. 6 As provided by DWA (2005) and WRC Report No. TT 434/09.

12 KHULA Page 12 A watercourse is defined by the National Water Act: (a) A river or spring; (b) A natural channel in which water flows regularly or intermediately; (c) A wetland, lake or dam into which or from which water flows; and (d) Any collection of water which the Minister may, by notice in the Gazette, declare to be a watercourse. Water table: The upper surface of groundwater or that level below which the soil is saturated with water. The water table feeds base flow to the river channel network when the river channel is in contact with the water table. Wetland: An area of marsh, peatland or water, whether natural or artificial, permanent or temporary, with water that is static or flowing, fresh, brackish or salt, including areas of marine water the depth of which at low tide does not exceed ten metres. Acronyms CBA DWA DWAF DWS EIS ESA FEPA GPS HGM MAP NEMA NFEPA NWA OESA PES QDS REC SANBI Critical Biodiversity Area Department of Water Affairs Department of Water Affairs and Forestry Department of Water and Sanitation Ecological Importance and Sensitivity Ecological Support Area Freshwater Ecological Support Area Global Positioning System Hydrogeomorphic Mean Annual Participation National Environmental Management Act National Freshwater Ecosystem Priority Areas National Water Act Other Ecological Support Area Present Ecological State Quarter Degree Square Recommended Ecological Category South African National Biodiversity Institute Sub-WMA Sub - Water Management Area VEGRAI WCBF WMA WUL Riparian Vegetation Response Assessment Index Western Cape Biodiversity Framework Water Management Area Water Use Licence

13 KHULA Page Introduction 1.1. Project Background KHULA Environmental Consultants (hereafter KHULA ) has been appointed by Headland Town Planners to undertake a specialist assessment of the impact of the proposed residential development on Erf 271 Bakkershoogte (the proposed site) on the site s freshwater features. The specialist assessment is required as part of the Basic Assessment process in terms of the National Environmental Management Act (NEMA) Environmental Impact Assessment (EIA) Regulations, 2014 as well as the application for water use authorisation in terms of Section 21 of the National Water Act (NWA). The proposed site is located 80 m west of Broadway Boulevard within the suburb Heldervue, Somerset West. The location of the proposed site with general surroundings is presented in Figure 1 and 2 below. Figure 1: Topo-Cadastral map dated 2010 presenting the proposed site in relation to the surrounding areas.

14 KHULA Page 14 Figure 2: Proposed site, presented in green, in relation to surrounding areas (Google Earth Pro, 2017) Limitations and Assumptions Only those freshwater features within the proposed site and immediate surroundings were assessed and delineated during the field survey. All other freshwater features located within 500m of the proposed site as presented by the National Freshwater Ecosystem Priority Areas project (NFEPA, 2011) and City of Cape Town s wetland layer (2015) were discussed on a desktop level only. The infield delineation was undertaken in March 2017, following a very dry summer. The onsite delineation of natural watercourses was made difficult due to the disturbed nature of the areas investigated as well as wetland indicators being indistinct in some areas due to persisting drought conditions. As a result, only the seasonal wetland zone could be determined during the site survey and not the temporary wetland zone. However, the Department of Water Affairs and Sanitation (DWS) considered the delineation presented within this report as sufficient in order to ascertain the applicable requirements relating to Notice 509 of 2016 in terms of Section 39 of the National Water Act (NWA) for water uses as defined in Section 21(c) or Section 21(i). The accuracy of the Global Positioning System (GPS) utilised will affect the accuracy of the delineation. A Garmin GPSMap 64 was used which has an estimated accuracy rating of 3-5 metres. KHULA is of the opinion however that this limitation is of no material significance and that the wetland-related constraints have been adequately identified. WET-Health is a rapid assessment tool which relies on expert opinion and judgement and which relies on qualitative rather than quantitative information. That being said, WET-Health is currently the most suitable technique available to undertake the assessment of wetland Present Ecological State (PES). For the purposes of this study only WET-Health level 1 was undertaken and it is the opinion of the specialist that the method of assessment used, provides a true reflection of the PES as well as human benefit associated with the wetlands.

15 KHULA Page 15 A single field survey was undertaken in March Seasonal variation was therefore not considered as part of this assessment. There is therefore the possibility that some aspects may have been missed, however general findings and results were considered sufficient to inform the assessment of any potential impact that could occur as a result of the proposed development activities. The assessment was confined to the top 50 cm of soil, in line with the delineation guideline provided by Department of Water Affairs and Forestry (DWAF, updated 2008). Therefore, groundwater was not considered as part of this assessment Applicable Legislation National Water Act (Act no.36 of 1998) The purpose of the NWA is to ensure that the nation's water resources are protected, used, developed, conserved, managed and controlled in ways which take into account amongst other factors - (g) protecting aquatic and associated ecosystems and their biological diversity; and (h) reducing and preventing pollution and degradation of water resources. In order to understand and interpret the NWA correctly, the following definitions are applicable to this project: ``pollution'' means the direct or indirect alteration of the physical, chemical or biological properties of a water resource; ``protection'', in relation to a water resource, means - (a) maintenance of the quality of the water resource to the extent that the water resource may be used in an ecologically sustainable way; (b) prevention of the degradation of the water resource; and (c) the rehabilitation of the water resource; ``resource quality'' means the quality of all the aspects of a water resource including - (a) the quantity, pattern, timing, water level and assurance of instream flow; (b) the water quality, including the physical, chemical and biological characteristics of the water; (c) the character and condition of the instream and riparian habitat; and (d) the characteristics, condition and distribution of the aquatic biota; watercourse'' means - (a) a river or spring; (b) a natural channel in which water flows regularly or intermittently; (c) a wetland, lake or dam into which, or from which, water flows; and (d) any collection of water which the Minister may, by notice in the Gazette, declare to be a watercourse, and a reference to a watercourse includes, where relevant, its bed and banks; and ``water resource'' includes a watercourse, surface water, estuary, or aquifer. The NWA deals with pollution prevention, and in particular the situation where pollution of a water resource occurs or might occur as a result of activities on land. The person who owns, controls, occupies or uses the land in question is responsible for taking measures to prevent pollution of water resources. The measures may include measures to - (a) cease, modify or control any act or process causing the pollution; (b) comply with any prescribed waste standard or management practice; (c) contain or prevent the movement of pollutants; (d) eliminate any source of the pollution; (e) remedy the effects of the pollution; and (f) remedy the effects of any disturbance to the bed and banks of a watercourse.

16 KHULA Page 16 Water use is defined broadly, and includes taking and storing water, activities which reduce stream flow, waste discharges and disposals, controlled activities (activities which impact detrimentally on a water resource), altering a watercourse, removing water found underground for certain purposes, and recreation. In general, a water use must be licensed unless it is listed in Schedule I, is an existing lawful use, is permissible under a general authorisation, or if a responsible authority waives the need for a licence. It is important to note that Altering the beds, banks, characteristics of a watercourse means any change affecting the resource quality within the riparian habitat or 1:100-year flood line, whichever is the greater distance General Notice 509 of the NWA (2016) According to GN509 of 2016 the extent of a watercourse means: a) a river, spring or natural channel in which water flows regularly or intermittently within the outer edge of the 1 in 100 year floodline or riparian habitat measured from the middle of the watercourse from both banks, and for b) wetlands and pans within a 500 m radius from the boundary (temporary zone) of any wetland or pan (when the temporary zone is not present then the seasonal zone is delineated as the wetland boundary), and for c) lakes and dams purchase line plus a buffer of 50 m. According to the GN509 a General Authorisation (GA) may be acquired for the use of water in terms of section 21 c and i within the extent of a watercourse where the Risk Class as determined by the new Risk Assessment Matrix is Low National Environmental Management Act (Act no. 107 of 1998) The National Environmental Management Act (NEMA) states the following: Every person who causes, has caused or may cause significant pollution or degradation of the environment must take reasonable measures to prevent such pollution or degradation from occurring, continuing or recurring, or, in so far as such harm to the environment is authorised by law or cannot reasonably be avoided or stopped, to minimise and rectify such pollution or degradation of the environment. The NEMA also makes special mention of the importance of the protection of wetlands: Sensitive, vulnerable, highly dynamic or stressed ecosystems, such as coastal shores, estuaries, wetlands and similar systems require specific attention in management and planning procedures, especially where they are subject to significant human resource usage and development pressure Scope of Work The scope of work included the following: Gathering of background information as defined by provincial and national databases. Identification, delineation and assessment of the watercourses as defined by the NWA within the proposed site. Identification and assessment of all freshwater impacts likely to occur during the construction and operational phase. Recommendation of measures to reduce any negative freshwater impacts. Comment on and conduct a comparative analysis of the freshwater impacts associated with the no-go alternative.

17 KHULA Page Method of Assessment 2.1. Desktop Assessment The scope of work included a desktop assessment using available national and provincial databases such as municipal Fine Scale Plans and NFEPA (2011) Watercourse Identification and Delineation A field survey was undertaken on the 18 th of March For the purpose of the identification of water resources, the definition as provided by the NWA (Act no. 36, 1998) was used to guide the site survey. The NWA defines a water resource as a watercourse, surface water, estuary or aquifer, of which the latter two are not applicable to this assessment due to an estuary being associated with the sea and, in line with best practice guidelines, wetland and riparian assessments only include the assessment of the first 50 cm from the soil surface, therefore aquifers are excluded. In addition, reference to a watercourse as provided above includes, where relevant, its bed and banks. In order to establish if the watercourse in question can be classified as wetland habitat or river habitat, the definitions as drafted by the NWA (Act no. 36, 1998) 7, the proposed national wetland classification system 8 for South Africa and the DWAF (2008) were taken into consideration. Wetland habitat and riparian habitat are defined in the NWA as the following: A wetland is land which is transitional between terrestrial and aquatic systems where the water table is usually at or near the surface, or the land is periodically covered with shallow water, and which land in normal circumstances supports or would support vegetation typically adapted to life in saturated soil; and Riparian habitat includes the physical structure and associated vegetation of the areas associated with a watercourse which are commonly characterized 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 areas. Whereas wetlands generally display more diffuse flow and are lower energy environments, riparian areas are commonly found along streams and rivers that reflect the high-energy conditions associated with the water flowing in a strongly defined channel (DWAF, 2008). Both rivers and wetlands are listed as types of watercourses and are afforded appropriate protection under the NWA. Freshwater habitat was identified with the use of the definitions provided above and the delineation took place according to the method supplied by DWAF (2008) in combination with the wetland soil characteristics guidelines drafted by Job (2009) Freshwater Feature Classification Ecosystems included within the Classification System for Wetlands and other Aquatic Ecosystems in South Africa (hereafter referred to as the Classification System ) developed by Ollis et al., (2013) encompass those that the Ramsar Convention defines, rather broadly, as wetlands, namely areas of marsh, fen, peatland or water, whether natural or artificial, permanent or temporary, with water that is static or flowing, fresh, brackish or salt, including areas of marine water the depth of which at low tide does not exceed six 7 The definitions as provided by the NWA (Act No. 36 of 1998) are the only legislated definitions of wetlands in South Africa. 8 SANBI 2009.

18 KHULA Page 18 metres (cited by Ramsar Convention Secretariat, 2011). The inland component of the Classification System has a six-tiered structure presented in the figure below. LEVEL 1 Marine Estuarine Inland LEVEL 2 REGIONAL SETTING DWA Level 1 Ecoregion NFEPA WetVeg Groups Other spatial framework LEVEL 6 DESCRIPTORS LEVEL 3 LANDSCAPE UNIT Natural vs artificial Salinity Substratum type Vegetation cover type Geology Valley floor Slope Plain Bench (hilltop/saddle/shelf) LEVEL 5 HYDROLOGICAL REGIME Rivers = Perenniality Period and depth of inundation Period of saturation LEVEL 4 HYDROGEOMORPHIC (HGM) UNIT River Floodplain Channelled valley-bottom wetland Unchannelled valley-bottom wetland Depression Seep Wetland flat Figure 3: Classification System for wetlands and other aquatic ecosystems in South Africa Wetland EcoServices and Function Assessment WET-EcoServices 9 was designed for inland palustrine wetlands 10 and has been developed to help assess 15 key goods and services that individual wetlands provide in order to allow for more informed planning and decision making. Central to WET-EcoServices is the characterisation of Hydrogeomorphic (HGM) units (refer to section 2.3. above). The rationale behind characterising the HGM units of a wetland is that areas belonging to the same HGM type and falling within a similar geological and climatic setting are likely to have a similar structure and exhibit similar processes. In addition, WET-EcoServices allows for the assessment of potential and actual ecosystem service outcomes of rehabilitation projects by applying the assessment to with rehabilitation and without rehabilitation situations and comparing the difference between the two. 9 Kotze et al., 2007 WRC Report No TT 339/08 10 marshes, floodplains, vleis and seeps.

19 KHULA Page Present Ecological State (PES) - Wet-Health WET-Health 11 is a tool designed to assess the health or integrity of a wetland. Wetland health is defined as a measure of the deviation of wetland structure and function from the wetland s natural reference condition. This technique attempts to assess hydrological, geomorphological and vegetation health in three separate modules. A Level 1 WET-Health assessment was undertaken as part of this assessment Ecological Importance and Sensitivity (EIS) The EIS method applied to wetlands is based on the assessment tool developed by Rountree et. al. (2013) and was utilised in order to determine the importance and sensitivity of wetlands associated with the proposed site. Note that hydro-functional importance and Direct Human Benefits have been assessed as part of the WET- EcoServices and were therefore excluded from the assessment of EIS Recommended Ecological Category (REC) The Recommended Ecological Category (REC) is determined by the PES score as well as importance and/or sensitivity. Water resources which have a PES falling within an E or F ecological category are deemed unsustainable. In such cases the REC must automatically be increased to a D. Where the PES is determined to be within an A, B, C or D ecological category, the EIS components must be evaluated to determine if any of the aspects of importance and sensitivity are high or very high. If this is the case, the feasibility of increasing the PES (particularly if the PES is in a low C or D category) should be evaluated and either set at the same ecological category or higher depending on feasibility. This is recommended to enable important and/or sensitive water resources to maintain their functionality and continue to provide the goods and services for the environment and society Buffer Determination An important outcome for a freshwater specialist study is the determination of an appropriate buffer to ensure watercourses are adequately protected during both the construction and operational phase of a proposed development. The Buffer Zone Guidelines for Rivers, Wetlands and Estuaries (Macfarlane and Bredin, 2016) has been developed to assist with this process. The practicality of implementing a buffer area around the remnant seep wetland area, has been considered for this project, however after examining the two proposed layout plans it was found that the incorporation of a buffer zone would render the project unfeasible Impact Assessment A method of assessment summary is provided below; the detailed method is provided in Appendix 1. The following criteria were taken into consideration when determining the impact of the proposed activities: The nature of the impact i.e. positive, negative, direct, indirect; The extent and location of the impact; The duration of the impact i.e. short term, long term, intermittent or continuous; The magnitude/intensity of the impact i.e. high, medium, low; and The likelihood or probability of the impact actually occurring. 11 Macfarlane et al., 2007 WRC Report No TT 340/09 Level 1 assessment

20 KHULA Page 20 Mitigation measures were subsequently identified and recommended for all impacts to reduce the overall impact significance to an acceptable level, where and if possible. Mitigation measures were aimed to ensure that: More environmentally sound designs / layouts / technologies, etc., are investigated and implemented, if feasible; Environmental benefits of a proposed activity are enhanced; Negative impacts are avoided, minimised or remedied; and Residual negative impacts are within acceptable levels Offset Requirements The National Wetland Offset Guidelines (Macfarlane et. al. 2014) and the accompanying wetland offset calculator are used to evaluate the degree of wetland damage and determine the nature and scale of the offset required for the residual impacts once all feasible and effective actions and alternatives to avoid or prevent, minimise and rehabilitate damage caused by development have been investigated. This method accounts for the number hectares of wetland affected by the development, the impact on function and habitat as well as the rarity and conservation status of the wetland type. It determines a value for the wetland loss using hectare equivalents as a currency. The intended offset activity is then similarly evaluated in terms of hectare equivalents, and if the hectare equivalents of the proposed offset are greater than or equal to the hectare equivalents calculated for the development impact, then the offset is considered appropriate. 3. Results 3.1. Overview of Background Information The proposed site falls within the quaternary catchment G22J, within the Berg Water Management Area (WMA) and within the Greater Cape Town sub-water Management Area (sub-wma) as defined by NFEPA (2011). According to Mucina and Rutherford (2006, updated 2012), the proposed site is located within the Boland Granite Fynbos vegetation type, listed as Vulnerable by the National List of Threatened Terrestrial Ecosystems (2011). Furthermore, wetlands associated with the proposed site fall within the West Coast Granite Renosterveld wetland vegetation group (NFEPA, 2011), listed as Critically Endangered within the region. The proposed site falls within the Southern Folded Mountains Ecoregion (Kleynhans, 2005). The main attributes listed for the ecoregion are provided in the table below. Table 1: Main attributes for the Southern Folded Mountains Ecoregion (State of the Rivers, 2011). Main Attributes Vegetation Landscape Mean altitude Rainfall seasonality Mean annual precipitation Southern Folded Mountains Fynbos (Sandstone and Shale) Moderate/high relief mountains and closed hills 300 to 1900m Very late summer to winter, to all year 200 to 1500mm

21 KHULA Page 21 Main Attributes Mean annual runoff Southern Folded Mountains Less than 5 to more than 250mm Mean annual temperature 10 C to 20 C Geology Soils Shale, tillite, sandstone and quartzitic sandstone Sand-clay-loam, clay-loam, sand-loam and sand-clay The concrete reservoir located immediately to the west of the proposed site is indicated as an artificial wetland by the NFEPA database (2011), and a natural to semi-natural valley bottom wetland is located adjacent to the eastern boundary of the proposed site (City of Cape Town s wetland layer, 2015). The valley bottom wetland was selected as a Critical Ecological Support Area (CESA) and areas along this wetland system which have been impounded were selected as Other Ecological Support Areas (OESAs). OESAs are lower ranking artificial wetlands and the lowest ranking natural or semi-natural wetlands. The objectives for these features are to maintain natural ecosystems, restore degraded land to natural and to manage for no further degradation. CESAs are middle ranking natural wetlands and high ranking artificial wetlands, but are not wetlands that are considered important for connectivity or as support areas for Critical Biodiversity Areas (CBAs) wetlands. CBA wetlands are high ranking natural or semi-natural wetlands which require protection from any further degradation. Two additional freshwater features are located within 500m from the proposed site, also presented in Figure 4. However, extensive residential housing and roads are located between the features and the proposed site. It is therefore not considered possible for the proposed development to pose any risk to these features. Figure 4: Wetlands in relation to the proposed site (NFEPA, 2011 and City of Cape Town wetland layer, 2017).

22 KHULA Page Description of the Proposed Site Historical imagery available on Google Earth Pro (2017) revealed that the site has been subjected to significant earthworks several times in the past decade. After the most recent earthworks the site has been left undisturbed and alien species such as Pennisetum clandestinum have established and currently dominate the majority of the site. Wetland habitat, dominated by Typha capensis, was identified within the centre of the site, however the source of the water could not be determined. For the purposes of this study it has been assumed that the wetland habitat identified historically formed part of a larger seep wetland that has been fragmented and in some areas entirely lost due to surrounding residential developments. The remaining portion of the seep wetland presently augments the larger valley bottom wetland located on the south-eastern boundary of the site. Figure 5: Areas where the most significant historical disturbance has taken place presented with yellow.

23 KHULA Page 23 Figure 6: Overview of the proposed site, the photograph on the left was taken in a north-eastern direction and the photograph on the right taken in a south-eastern direction. Figure 7: Freshwater features identified within proposed site and immediate surrounding area (seep wetland presented in blue and the valley bottom wetland presented in red).

24 KHULA Page 24 Figure 8: Valley bottom wetland located to the east of the proposed site. Figure 9: Severely disturbed seep wetland identified within the centre of the proposed site Aquatic Ecosystem Classification An in-depth investigation into the origin of the hillslope seep wetland was undertaken by Headland Town Planning, the appointed chief consultant for this project. However, no evidence could be found that the feature was artificially created. As a result, the precautionary principle was applied and the wetland habitat was considered to be a naturally occurring freshwater feature. The points below provide an indication of the key characteristics which were most likely representative of the reference condition. The two watercourses are inland systems located within the West Coast Granite Renosterveld wetland vegetation group (Critically Endangered) (NFEPA, 2011) and fall within the Southern Folded Mountains Ecoregion (DWAF, Level 1 Ecoregions, 2005). The table below summarises the results from Level 3 through to Level 6. Table 2: Aquatic ecosystem classification (Ollis et. al. 2013). Level 3 Seep wetland Slope: an inclined stretch of ground typically located on the side of a mountain, hill or valley, not forming part of a valley floor. Includes scarp slopes, midslopes and foot-slopes. Valley bottom wetland Valley floor: the base of a valley, situated between two distinct valley side-slopes, where alluvial or fluvial processes typically dominate.

25 KHULA Page 25 Level 4 Level 5 Level 6 Seep: a wetland area located on gently to steeply sloping land and dominated by colluvial (i.e. gravitydriven), unidirectional movement of water and material down-slope. Intermittently inundated: holding surface water for irregular periods of less than one season. Seasonally saturated: with all the spaces between the soil particles filled with water for extended periods (generally between 3 to 9 months). Natural: existing in, or produced by nature; not made or caused by humankind. Unchannelled valley bottom: a valley bottom wetland without a river channel running through it. riparian zone as a unit. Seasonally inundated: with surface water present for between 3 to 9 months duration, but drying up annually. Permanently saturated: where all the spaces between the soil particles are filled with water throughout the year, in most years. Natural: existing in, or produced by nature; not made or caused by humankind Watercourse Delineation A site survey was undertaken on the 18 th of March 2017, during which the wetland indicators as mentioned in section 2.2 were utilised in order to delineate wetland habitat within the proposed site and immediate surroundings. Vegetation The higher lying area of the seep wetland is dominated by Pennisetum clandestinum, followed by a Typha capensis community which dominates an artificially created depressional area where surface water tends to pool for an extended period of time. Water then seeps from the depressional area into the valley bottom wetland via a portion of wetland dominated by Scirpus sp., Juncus sp., Psoralea aphylla, Persicaria sp. and the alien Rubus fruticosus. All the floral species identified within these three wetland portions are considered to be indicative of permanent to seasonal wetland conditions (DWAF, 2008, Esler et al., van Oudtshoorn, 2004). Vegetation was therefore utilised as the primary indicator of the boundary of the seasonal wetland zone of the seep wetland. It is considered possible that the temporary zone could extent over a larger portion of the site, however the season in which the site visit was undertaken did not allow for the confident use of vegetation as an indicator for the boundary of the temporary zone (refer to limitation discussed in Section 1.2). The abundance of R. fruticosus increases significantly within the temporary zone of the channelled valley bottom and would continue to spread if not eradicated. Alien proliferation within the seasonal and permanent wetland zones was not considered as severe, with a continuous indigenous wetland vegetation community still evident (Refer to Figure 9). Vegetation was used as the primary indicator of the western temporary boundary of the valley bottom wetland bordering the proposed site. The remainder of the feature was delineated with the use of Google Earth Pro (2017).

26 KHULA Page 26 Valley bottom wetland The proposed site Figure 10: Channelled valley bottom. Redoxymorphic features Hand augering was attempted throughout the proposed site to aid in the identification of the boundary of the temporary zone of the seep wetland. However, augering proved unsuccessful due the soil being impenetrable at the time of the assessment as a result of high clay content and lack of soil moisture. Indicators of hydromorphic soils 12 such as gleying and mottling 13 were encountered within the first 50 cm of the soil surface of seasonal and permanent wetland zones of both wetland features. Figure 11: Representative photos of soils investigated by means of hand auguring. 12 A soil that, in its undrained condition, is saturated or flooded long enough to develop anaerobic conditions favouring the growth and regeneration of hydrophytic vegetation (vegetation adapted to living in anaerobic soils). 13 Wetland indicators defined by DWAF, 2008 and Job, 2009.

27 KHULA Page Present Ecological State WET-Health 14 is defined as a measure of the similarity of a wetland to a natural or reference condition. This technique 15 attempts to assess hydrological, geomorphological and vegetation health in three separate modules for each HGM unit identified. The two HGM units applicable to this assessment was the seep wetland and the valley bottom wetland, which form part of one extensive wetland system. The WET-Health method was developed in order to obtain a combined score for all applicable HGM units within one extensive wetland system, should this be required. This approach was however not considered suitable for this assessment, due to the severely degraded nature of the seep wetland when compared to the valley bottom wetland. It is the opinion of the specialist that combining the two results will not give an accurate reflection of the current state of the features. The assessment of the seep wetland proved difficult due to the uncertainty of the historical extent of natural wetland habitat, however, the final result is considered representative of the PES of the remaining wetland habitat. In order for the development to prove feasible, the seep wetland will need to be relocated to the eastern portion of the proposed site. The proponent committed to the rehabilitation of approximately 1053m 2 within the eastern portion, of which approximately 856m 2 will be wetland habitat. The probable trajectory of change was therefore also considered should development proceed as well as if the project does not prove feasible. The key findings and considerations for the WET-Health assessment are summarised below: Seep wetland: o The hydrological regime of the seep wetland has been significantly altered due to the development of roads and residential housing within its catchment. It is expected that surface runoff from these hardened surfaces would have increased substantially resulting in an increase in flood peaks within the wetland. In addition, earth moving activities within the proposed site would have also resulted in changes to natural runoff patterns and inundation intervals. o Alien vegetation encroachment is considered severe and indigenous species diversity and abundance was considered to be very low at the time of the site survey. It is expected that without eradication and ongoing management, alien vegetation proliferation will result in complete loss of indigenous species over time. o Erosion and sedimentation is not considered severe at present, mainly as a result of Pennisetum clandestinum dominating the western portion. Although not preferred, P. clandestinum does have good soil binding capability, and if not mowed, slows down surface runoff entering the site. o The proposed rehabilitation of the eastern portion of the proposed site provides the opportunity to increase indigenous floral species abundance and diversity within the proposed site. Valley bottom wetland: o Historical Topo-Cadastral maps all indicate the origin of this feature near the proposed site. It is therefore assumed that the feature was mainly augmented by seeps originating within the surrounding hills prior to urban development within the catchment. o In order to obtain a representative result of the PES of the portion of the valley bottom wetland, only the vegetated area of approximately 1.2 km; roughly located between Dennehoek Street and Magnolia Street, was taken into consideration. o Informal roads have been created through the feature which have resulted in the impoundment of water immediately upstream of the roads. 14 Macfarlane et al., 2007 WRC Report No TT 340/09 15 A Level 1 WET-Health assessment was undertaken as part of the wetland PES assessment.

28 KHULA Page 28 o o Infilling as part of construction of the R44 as well as residential developments along the western boundary of the valley bottom wetland have altered the natural topography and have resulted in the loss of temporary wetland habitat. Alien vegetation encroachment was only considered significant along the periphery of the wetland system. Areas where soil remains saturated for an extended period of time are dominated by indigenous species known to proliferate within urban settings. Table 3: WET-Health results table. Hydrology Geomorphology Vegetation Seep wetland Valley bottom wetland Seep wetland Valley bottom wetland Seep wetland Impact category F C D C E D Ecological state without development Ecological state with development Potential improvement State is likely to remain stable over the next 5 years. State is likely to deteriorate slightly over the next 5 years. State is expected to deteriorate substantially over the next 5 years. Valley bottom wetland The overall wetland health 16 score calculated for the seep wetland falls within a PES Category E and for the valley bottom wetland within a PES Category C, refer to the table below for Category definitions. Considering the extent to which both features have already been impacted as a result of surrounding urban development, it is doubtful that the hydrology or geomorphology would deteriorate further, should development not take place. However, the hydrological and geomorphological regimes of the seep wetland would decrease should the proposed development proceed. It is however considered possible to improve the diversity and abundance of indigenous floral species as part of rehabilitation proposed within the eastern portion of the proposed site. Table 4: PES categories used by WET-Health for describing the integrity of wetlands (after Macfarlane et al., 2007). Description Unmodified, natural. Largely natural with few modifications. A slight change in ecosystem processes is discernible and a small loss of natural habitats and biota may have taken place. Moderately modified. A moderate change in ecosystem processes and loss of natural habitats has taken place but the natural habitat remains predominantly intact Largely modified. A large change in ecosystem processes and loss of natural habitat and biota and has occurred. The change in ecosystem processes and loss of natural habitat and biota is great but some remaining natural habitat features are still recognisable. Modifications have reached a critical level and the ecosystem processes have been modified completely with an almost complete loss of natural habitat and biota. PES Category A B C D E F 16 (hydrology score) x 3 + (geomorphology score) x 2 + (vegetation score) x 2 / 7 = overall wetland health

29 KHULA Page Ecosystem Services The WET-Ecoservices tool was applied to the seep wetland and the valley bottom wetland, separately. The results are presented in Table 6 and Figure 11. All Ecosystem Services will be lost from the portion of the seep wetland that will need to be infilled should the development be authorised. However, it is the opinion of the specialist that a wetland system with similar functions and services can be recreated within the eastern portion, provided that the area receives sufficient volumes of water throughout the year to successfully sustain a wetland floral community. With the introduction of indigenous floral species with high assimilation capability, it is even considered possible to increase the extent to which the Ecosystem Services are currently provided within the proposed site. It is expected that increased stormwater runoff from hard surfaces would be the primary aspect of the proposed development that would influence the ability of the valley bottom wetland in providing the assessed Ecosystem Services. However, with adherence to the City of Cape Town Sustainable Stormwater Drainage Systems guidelines and proposed expansion of wetland habitat within the eastern portion of the proposed site, the impact would be marginal. Fifteen Ecosystem Services were assessed and the results are presented in Table 6 below. Brief explanations of the most noteworthy attributes are provided below: The potential nitrate, phosphate and toxicant sources are considered high due to the urban setting of the wetlands, in turn increasing the importance of both wetlands in terms of assimilation. Presently, the seasonal and permanent zones are considered the most represented hydrological zones along both wetlands, increasing importance in terms of regulation of streamflow as well as removal of nitrate and toxicants. The wetlands mainly comprise of well vegetated permanent and seasonal zones. This enhances the potential of the features in providing functions such as erosion control. Results indicate that the wetlands can be considered of greater importance in terms of indirect benefits compared to direct benefits. The scores reflect the extent to which the wetland features as well as the catchments of the features have been disturbed, which in turn increases the potential for the wetlands to provide indirect benefits which would not necessarily be required in a pristine setting. It is considered possible to marginally increase the importance of the seep wetland in terms of maintenance of biodiversity as well as tourism and recreation with the implementation of a wetland rehabilitation plan. Table 5: Classes for determining the likely extent to which a benefit is being supplied based on the overall score for that benefit (after Kotze et al., 2007). Score (range 0-4) Rating of the likely extent to which a benefit is being supplied < >2.8 Low Moderately Low Intermediate Moderately High High

30 KHULA Page 30 Table 6: WET-EcoServices results table. Indirect benefits (Regulating and supporting benefits) Seep wetland Valley bottom wetland Flood attenuation**** Streamflow regulation** Sediment trapping**** Phosphate removal**** Nitrate removal*** Toxicant removal*** Erosion control*** Carbon storage*** Direct benefits 17 Maintenance of biodiversity** Water supply for direct human use** Harvestable natural resources** Provision of cultivated foods*** Cultural significance* Tourism, recreation, scenic value** Education and research* Size is seldom important * Size is usually moderately important** Size is usually very important*** Size is always very important**** Seep wetland Valley bottom wetland Cultural significance Provision of cultivated food Education and research Tourism and recreation Flood attenuation 3,5 3,0 2,5 2,0 1,5 1,0 0,5 0,0 Streamflow regulation Sediment trapping Phosphate removal Nitrate removal Provision of harvestable natural resources Provision of water for direct human use Maintenance of biodiversity Carbon storage Toxicant removal Erosion control Figure 12: WET-EcoServices results. 17 Level of poverty and location within rural communal area has been omitted from the calculation for harvestable natural resources, cultivated foods and cultural significance in order to obtain a true reflection of the extent to which these services are presently being supplied by the wetland.

31 KHULA Page Ecological Importance and Sensitivity (EIS) The overall EIS score calculated for the seep wetland falls within the low category implying that the wetland is not ecologically important and sensitive at any scale. However, the overall EIS score calculated for the valley bottom wetland falls within a high category implying that the wetland is sensitive and ecologically important. The key aspects considered during this EIS assessment are summarised below and in the table to follow: In its current impacted state, the likelihood of the seep wetland providing breeding or foraging habitat for a diverse community of wetland dependent faunal species is considered to be very low. One of the aims of rehabilitation should therefore be to recreate and expand habitat for wetland dependent faunal and avifaunal species as far as practically possible. Ongoing anthropogenic activity has resulted in the loss of indigenous floral species diversity within the valley bottom wetland. However, the seasonal and permanent zones are still well vegetated and dominated by hardier indigenous hydrophytic vegetation that provides habitat for more common faunal species that are adapted to living in close association with humans. In addition, inundated areas within the valley bottom wetland upstream of road crossings and well vegetated seasonal zones provide some habitat diversity. The proposed development is located within the Boland Granite Fynbos vegetation type, listed as Endangered (South African National Biodiversity Institute, SANBI, 2012). Wetlands associated with the proposed site fall within the West Coast Granite Renosterveld wetland vegetation group (NFEPA, 2011), listed as Critically Endangered within the region. The wetlands are not located within a formally protected nature reserve and therefore do not have any protection status. Seeps in general are considered to be less sensitive to changes in floods and low flow periods. However, unchanneled valley bottom wetlands are one of the most sensitive HGM units. Table 7: EIS results. ECOLOGICAL IMPORTANCE AND Seep wetland Valley bottom wetland Confidence SENSITIVITY Score (0-4) Biodiversity support Low (average) Low (average) Presence of Red Data species Populations of unique species Migration/breeding/feeding sites Landscape scale Low (average) Moderate (average) Protection status of the wetland Protection status of the vegetation type Regional context of the ecological integrity Size and rarity of the wetland type/s present Diversity of habitat types Sensitivity of the wetland Low (average) High (average) Sensitivity to changes in floods Sensitivity to changes in low flows/dry season Sensitivity to changes in water quality OVERALL ECOLOGICAL IMPORTANCE AND SENSITIVITY Low High

32 KHULA Page 32 Table 8: Ecological Importance and Sensitivity Categories. Ecological Importance and Sensitivity Categories Very high: Wetlands that are considered ecologically important and sensitive on a national or even international level. The biodiversity of these systems is usually very sensitive to flow and habitat modifications. They play a major role in moderating the quantity and quality of water of major rivers High: Wetlands that are considered to be ecologically important and sensitive. The biodiversity of these systems may be sensitive to flow and habitat modifications. They play a role in moderating the quantity and quality of water of major rivers. Moderate: Wetlands that are considered to be ecologically important and sensitive on a provincial or local scale. The biodiversity of these systems is not usually sensitive to flow and habitat modifications. They play a small role in moderating the quantity and quality of water of major rivers. Low/marginal: Wetlands that are not ecologically important and sensitive at any scale. The biodiversity of these systems is ubiquitous and not sensitive to flow and habitat modifications. They play an insignificant role in moderating the quantity and quality of water of major rivers. Range of EIS score >3 and <=4 >2 and <=3 >1 and <=2 >0 and <= Recommended Ecological Category and Buffer Zone Determination A portion of the seep wetland will need to be infilled and wetland habitat will need to be recreated within the eastern portion of the proposed site. The application of a buffer area to the wetland is therefore not deemed practical. It is however considered important that the wetland habitat within the eastern portion of the proposed site, where rehabilitation is proposed, is managed to ensure an ecological category of at least C is maintained within the open space for the remainder of the operational phase. The buffer zone width for the valley bottom wetland was determined with the use of the Buffer Zone Guidelines for Rivers, Wetlands and Estuaries (Macfarlane and Bredin, 2016). The required construction and operational phase buffers were determined to be 15 m. It is not considered practical to specify a REC, due to the small portion of the proposed site boundary located adjacent to the valley bottom wetland. It is however considered important that all measures listed within this report are adhered to in order to ensure potential impacts are either avoided or adequately addressed. Figure 13: Valley bottom wetland (presented with red) with 15m buffer (presented with orange) (Google Earth Pro, 2017).

33 KHULA Page Activity Description Two layout alternatives are being considered, namely the Applicant s Preferred Layout Plan and an Alternative Layout Plan. The two alternatives are presented in the figures below. The Applicant s Preferred Layout Plan incorporates 7 residential units and one private driveway which will allow access to all the units, as well as a private open space extending over approximately 1053 m 2 wherein wetland rehabilitation is proposed. Approximately 623 m 2 of the 856 m 218 seep wetland will need to be infilled in order for the proposed development to prove feasible. However, the private open space will incorporate the remaining portion of the seep wetland and will not encroach onto the valley bottom wetland. In addition, the current wetland habitat will be expanded (approximately 864 m 2 ) within the area earmarked for private open space, and the immediate surroundings will be rehabilitated (total area extending 1053 m 2 including retained wetland habitat). A 15 m buffer is required for the valley bottom wetland 19 and will overlap with the area proposed for rehabilitation. The Alternative Layout Plan proposes the development of 7 larger units and one private driveway. No wetland habitat will be conserved and the 15 m buffer required for the valley bottom wetland will also be developed. Rehabilitated area Figure 14: Applicant s Preferred Layout Plan. 18 Total extent of wetland within the proposed site. 19 Determined with the use of Buffer Zone Guidelines for Rivers, Wetlands and Estuaries (Macfarlane and Bredin, 2016).

34 KHULA Page 34 Figure 15: Alternative Layout Plan. 5. Assessment of Impacts 5.1. Impact Identification Direct impacts considered probable during the construction phase of both alternatives include: Loss of wetland habitat. Disturbance of wetland habitat. Alteration of the hydrology regime. Water quality impairment. Direct impacts considered probable during the operational phase include: Transformation of wetland habitat. Disturbance of wetland habitat (only applicable to the Alternative Layout Plan). Increase in wetland biodiversity and function (only applicable to the Applicant s Preferred Layout Plan).

35 KHULA Page Applicant s Preferred Alternative Construction Phase The following direct construction phase impacts are expected to occur should the Applicant s Preferred Layout be selected; with reference to Table 9 below. The area earmarked for wetland rehabilitation will be referred to as Private Open Space in the discussions below. Impact 1 - Loss of wetland habitat. In order to allow for sufficient development space, approximately 623 m 2 of the seep wetland (currently extending over approximately 856 m 2 within the proposed site) will be permanently lost due to infilling. The overall wetland health score calculated for the seep wetland falls within a PES Category E, which confirms the extent to which wetland habitat has been degraded. The degraded wetland habitat was also found to be of low EIS (refer to Section 3.7). The intensity of losing 623 m² of severely degraded wetland habitat within the proposed site is considered to be of medium intensity. The impact resulting from the permanent loss of degraded wetland habitat was therefore assessed to be of medium (negative) significance and loss will occur regardless of the implementation of measures. Essential measures: N/A Impact 2 Disturbance of wetland habitat. The remaining portion of the seep wetland will be disturbed regardless of the implementation of measures. The expected disturbance pertaining to rehabilitation is discussed in more detail below. In order to increase ecological importance and sensitivity of the retained wetland habitat within the Private Open Space, the applicant would need to remove alien vegetation and re-introduce indigenous floral species. Minor earthworks in order to create a larger wetland area will also be required. The proposed rehabilitation activities, if not carefully planned and executed, may result in a long-term impact to the wetland habitat within the Private Open Space as well as valley bottom wetland which may have a high (negative) significance. It is considered possible to decrease the intensity of the negative impact emanating from rehabilitation with the implementation of the essential measures listed below, and to ultimately achieve a positive impact long term. A long term positive impact was assessed as part of the operational phase. Impact during the construction phase considers initial disturbance of wetland habitat as part of the implementation of rehabilitation measures. The potential impact, with the implementation of measures, is expected to be short term and was rated to be of very low (negative) significance. Essential measures: Implement a Construction phase Environmental Management Programme (EMPr) that includes the following: o The Private Open Space should be cordoned off and declared a No Go area prior to commencement of site clearing activities. o Only allow construction activities within the demarcated No Go area in accordance with approved method statements. o Prohibit the dumping of excess excavated material within the valley bottom wetland or the No Go area.

36 KHULA Page 36 o Once construction has been completed all construction waste, rubble, and equipment must be removed from the construction area. o Once construction has been completed, remove alien and invasive individuals, manually as far as practically possible, from the construction footprint as well as any areas accidentally disturbed. These areas should be monitored in monthly intervals for the time period specified in the Wetland Rehabilitation Plan and seedlings removed as needed. The use of herbicides should be avoided. However, if necessary, only herbicides which have been certified safe for use in wetlands/aquatic environments by an independent testing authority may be considered. Cover removed alien plant material properly when transported, to prevent it from being blown from vehicles, and burn on a bunded surface where no stormwater runoff is expected. o Should any accidental disturbance to portions of wetland falling outside of the demarcated construction footprint area take place, immediately rip compacted soil to a depth of 300mm, reprofile the area according to natural terrain units and hand sow with Cynodon dactylon. If the disturbed area will be prone to erosion (sheet runoff or formation of gullies), it is recommended that straw bales (not Lucerne or hay) are used to intercept the bulk of the runoff. The bales should be placed strategically along contour lines and pegged. Disturbance and removal of vegetation within the immediate vicinity of the area where the bales are placed should be kept to a minimum. Sediment should be cleared manually as needed and disposed of at a registered waste facility. o Any topsoil removed from the direct construction footprint must be stored at a designated stockpile area for use in rehabilitation activities. o Spray areas where severe amounts of dust are generated lightly with water or use other appropriate dust suppression techniques (e.g. straw bales). o Cover equipment and storage piles and reduce the speed of vehicles to limit dust generation. Implement a Wetland Rehabilitation Plan which allows for the re-establishment of a diverse wetland floral community as well as increase in Ecosystem Services. Ensure that the boundary wall allows for surface and subsurface water to flow freely towards the valley bottom wetland e.g. palisade fencing. The boundary wall should also cater for the movement of smaller faunal species and amphibians. As far as practically possible, direct permanent outdoor lighting e.g. street and security lights away from the Private Open Space and valley bottom wetland. Impact 3 Alteration of the hydrological regime. The infilling of the western portion and the rehabilitation of the eastern portion of the seep wetland will result in a permanent change of the current hydrological regime, regardless of. Therefore, the present hydrological regime will be permanently altered, regardless of the implementation of measures during the construction phase. However, the strategic redirection of water entering the site and use of palisade fencing as opposed to a solid boundary wall will decrease the significance of long term impact during the operational phase. The impact resulting from the change of the hydrological regime during the construction phase was therefore assessed to be of medium (negative) significance prior to the implementation of measures and low (negative) significance with the implementation of measures. Essential measures: Implement the Wetland Rehabilitation Plan which details the manner in which the Private Open Space should be landscaped. Compile and implement a Construction phase Environmental Management Programme (EMPr) that includes the following stormwater management specifications: o Ensure that a suitable drainage system is in place before construction takes place to keep the construction footprint area as dry as possible and thereby reducing the amount of erosion. o Divert stormwater away from construction footprint areas.

37 KHULA Page 37 o Direct runoff from disturbed areas to silt traps (silt fences, sandbags etc. to remove sediment). o Water pumped from construction areas, following heavy rain, should be pumped to a demarcated settlement area and should not be discharged into the area earmarked as Private Open Space or the valley bottom wetland. o Cordon off the area where earthworks will be required within the Private Open Space prior to commencement of any activity. Disturbance of surrounding wetland habitat should be strictly prohibited. o Complete earthworks within the Private Open Space before the onset of the rainy season followed by revegetation from late April, early May shortly before the onset of the rainy season. o Thoroughly plan the required activities within the Private Open Space and discuss the method with the team before any activity commences in order to ensure the disturbance period is kept to an absolute minimum. o The ECO should inspect the Private Open Space at least on a weekly basis, in order to ensure any unnecessary disturbances are addressed timeously and effectively. Implement a Stormwater Management System in accordance with the City s Management of Urban Storm Water Impacts Policy (2009) that also achieves the following: o Strategically incorporate vegetated swales as part of the stormwater management of the proposed site in order to convey surface water towards the Private Open Space. o Use unlined vegetated swales that will allow for infiltration as appose to stormwater pipes. o Ensure that crossings over swales are adequate to enable surface water to flow freely underneath crossings. o Line or install flow control practices within swales where high runoff velocity and volume is expected. The first choice of lining is robust indigenous vegetation or sod because both reduce runoff velocities and provide water quality benefits through filtration and infiltration. If the velocity in the channel would erode the vegetation, turf reinforcement mats, riprap, concrete, or gabions can be used. o Construct energy dissipaters (such as lining with stones, concrete, grass or gabions) where surface water disperses out of a drain to reduce the water velocity and therefore erosion. o Ensure that the boundary wall allows for surface and subsurface water to flow freely towards the valley bottom wetland e.g. palisade fencing. o Use porous/permeable paving around buildings. o Install rainwater harvesting tanks at each residence. Impact 4 Water quality impairment. Sedimentation of wetland habitat will occur as a result of increased sediment loads within surface runoff originating from disturbed / infilled areas. The slope of the site will also exacerbate the impact further due to an expected increase in velocity of runoff. Spillage of fuel, chemicals and concrete utilised during construction will also pose a risk if not addressed adequately. Activities associated with rehabilitation of the Private Open Space would involve removal of alien vegetation and earthworks (sloping and grading) which would result in the disturbance of soils and an increase in the runoff of sediment. The close proximity of the construction footprint including the boundary wall, as well as rehabilitated areas to the valley bottom wetland increases the probability of impact on water quality significantly. It is however considered possible to decrease the probability as well as intensity of the impact with the implementation of sediment control measures. Restricting site preparation and construction activities to the dry summer months (November to April) would greatly decrease impact significance, however in practice this is not always achievable. As a result, in rating the impact significance, after, it was assumed that meeting this timeframe would not be feasible.

38 KHULA Page 38 The likelihood of the impact is considered to be definite and the intensity medium without the implementation of measures. The impact prior to the implementation of measures was therefore rated to be of medium (negative) significance. Although it is not considered possible to entirely avoid impact, the intensity of the impact would decrease with the implementation of the listed essential measures. The potential impact, with the implementation of measures, was therefore rated to be of very low (negative) significance. Essential measures: Ensure that measures are implemented during the construction phase that will allow for the adequate polishing of stormwater during the operational phase in line with the City of Cape Town Sustainable Stormwater Drainage Systems guidelines before it reaches the Private Open Space or the valley bottom wetland. Compile and implement a Construction phase Environmental Management Programme (EMPr) that includes the following pollution management specifications: o Complete earthworks required within the Private Open Space as well as construction of the boundary wall before the onset of the rainy season followed by revegetation of retained wetland habitat from late April, early May shortly before the onset of the rainy season. o Place sediment fences / traps along the eastern boundary of the construction footprint, upslope of the area earmarked for rehabilitation as well as immediately to the east of the construction footprint of the boundary wall. Ensure these are maintained and sediment is removed as needed. Use should be made of vegetative bundles / fibre bags or rolls, within the retained wetland habitat itself, where earthworks or the removal of vegetation could result in sedimentation of surrounding wetland habitat. In addition, the retained wetland area should be monitored by the appointed ECO, weekly, for sedimentation and erosion in order to ensure erosion and sedimentation is dealt with timeously. Removal of sediment from the retained wetland area should be done manually. o Clearing of vegetation should only be done immediately before construction commences. o Cut plants down to ground level where possible instead of being removed completely to retain stability of the soil during land-clearing operations. o Backfill excavated areas so that the surface is level with the surrounding land surface, to minimise soil erosion from the areas when the excavation is complete. o Install drainage control features such as earth dikes, perimeter swales or diversions at exposed slopes that will be highly prone to erosion to intercept and convey runoff from above disturbed areas to suitable dispersal areas or drainage systems. o Stabilise slopes (e.g. revegetation) as soon as possible. o Excavate soil one layer at a time, where practical, and store in separate stockpiles so it can be returned in its natural order when the area is backfilled to improve soil function and improve the template for plant growth. o Store the stockpiles outside areas where increased surface runoff is expected. o As far as practically possible, clear and grade the site in a phased approach. Do not clear additional portions until exposed soils from the earlier phase have been stabilized and the construction is nearly completed. o Ensure the unattended period after disturbance as a result of site preparation and ground breaking is kept to an absolute minimum. o Restrict the dumping or storage of construction material to the western portion of the construction footprint. These areas should be located outside the area earmarked for rehabilitation. o Demarcate areas where construction waste material and removed vegetation can be stored temporarily before it is disposed of appropriately. o Water pumped from construction areas, following heavy rain, should be pumped to a demarcated settlement area and should not be discharged into the Private Open Space or the valley bottom wetland. o Strategically divert stormwater runoff from the construction footprint into sediment trapping devices. All sediment trapping devices should be checked weekly by the ECO and cleared as needed.

39 KHULA Page 39 o o o o o o o o o Avoid the use of infill material or construction material with pollution / leaching potential. Clean up any spillages (e.g. concrete, oil, fuel), immediately. Remove contaminated soil and dispose of it appropriately. Service vehicles and machinery within demarcated areas, preferably off-site. Use bunded surfaces within designated areas for re-fuelling vehicles. Vehicles should preferably be refueled off site. Dispose of oils, wash water from cement and other pollutants at an appropriate licenced site. Use and dispose of concrete and cement-related mortars in an environmental sensitive manner (can be toxic to aquatic life). Fresh concrete and cement mortar should not be mixed on-site, and both dry and wet materials should be stored away from the Private Open Space, swales and stormwater drains. These materials should be covered and contained to prevent contact with rainfall or runoff. Washout should not be discharged into streets, stormwater drains, drainage ditches, or watercourses. A washout area should be designated, and wash water should be treated on-site or discharged to the sanitary sewer. Store fuel, chemicals and other hazardous substances in suitable secure weather-proof containers and within an area with impermeable and bunded floors. Provide adequate temporary toilets for the duration of the construction phase. Placement of temporary toilets within the area where wetland habitat will be retained as part of the Applicant s Preferred Alternative should be strictly prohibited. No grey water should be passed into swales, the valley bottom wetland or any other watercourses. Placement of backwash water from swimming pools into swales or watercourses should be strictly prohibited and management thereof should be addressed during the construction phase. Optional measures: o Restrict construction to the dry summer months (November to April). Table 9: Impact assessment results for the construction phase. without without with without with without with Extent Intensity Duration Consequence Probability Significance Status Confidence Loss of wetland habitat Long Medium term Medium Definite Medium -ve High (2) High Medium (2) Medium (2) Low Medium (2) Low Disturbance of wetland habitat Long term High Definite High -ve High Short term Very Low Definite Very Low -ve High Alteration of the hydrological regime Long term Medium Definite Medium -ve High Long term Low Definite Low -ve Medium Long term Short term Water quality impairment Medium Definite Medium -ve Medium Very Low Probable Very Low -ve Medium

40 KHULA Page Operational Phase The following direct operational phase impact is expected to occur should the Applicant s Preferred Layout be selected. Impact 1 Transformation of wetland habitat. The development of hard surfaces e.g. parking areas, buildings and the access road will result in an increase in the volume as well as velocity of stormwater entering wetland habitat. If not adequately addressed during the construction phase, stormwater runoff could result in erosion and sedimentation as well as pooling of stormwater within newly created temporary / seasonal wetland habitat during the operational phase. Pooling of water will ultimately result in loss of floral communities not adapted to survive extended periods of time in saturated soil. The impact will be further exacerbated if insufficient allowance is made for surface water flow from the proposed site into the valley bottom wetland during the construction phase and if outlet areas are not monitored and maintained during the operational phase. The impact expected to result due to increased stormwater volumes entering the Private Open Space and valley bottom wetland during the operation phase was rated to be of medium (negative) significance prior to the implementation of measures. With the implementation of measures listed for the construction phase it is deemed possible to adequately address and decrease the impact to a low (negative) significance. Essential measures (to be implemented during the construction phase): Implement a Stormwater Management System in accordance with the City s Management of Urban Storm Water Impacts Policy (2009) that also achieves the following: o Ensure that crossings over swales are adequate to enable surface water to flow freely underneath crossings. o Use porous/permeable paving. o Route water from downspouts to vegetated swales or vegetated open areas to increase infiltration. o Install rainwater harvesting tanks at each residence, if the expected volume of stormwater exceeds the required volume to sustain wetland habitat within the Private Open Space. o Use unlined vegetated swales that will allow for infiltration as appose to stormwater pipes. o As far as practically possible stormwater originating from hard surfaces should be passed into vegetated swales in order to decrease water volume and velocity before reaching the Private Open Space and valley bottom wetland. Otherwise, surface runoff should be diverted away from roads, pavements etc. as quickly as possible, to minimise the amount of water running directly from these areas into wetland habitat. This can be achieved with construction of multiple drains from roads, pavements etc. to ensure the least amount of surface water is discharged directly into a specific area. Essential measures (to be implemented during the operational phase): Implement the Wetland Rehabilitation Plan which details the manner in which the Private Open Space should be monitored and managed. Impact 2 - Increase in wetland biodiversity and function. It is considered possible that the positive impact resulting from alien clearing and revegetation may only persist short term within the Private Open Space without monitoring and management. However, with continued management it is expected that floral and faunal diversity as well as wetland function will continue to increase within the Private Open Space for as long as the facility remains operational. The impact significance prior to was rated to be very low (positive) and after the implementation of measures medium (positive).

41 KHULA Page 41 Essential measures: Implement the Wetland Rehabilitation Plan that addresses the requirement for monitoring and management of the Private Open Space. Alien vegetation must be eradicated and monitored for the remainder of the lifespan of the development within the Private Open Space. A suitably qualified landscape architect or contractor should be consulted in order to establish the most effective means of ongoing removal of Pennisetum clandestinum. The use of Pennisetum clandestinum for lawns should be strictly prohibited. Compile and implement an Operation phase Environmental Management Programme (EMPr) that includes the following specifications: o Implementation of fines by the development body for dumping by residents. Special mention is made of dumping of garden refuse into surrounding areas, this will result in spread of non-preferred species. o Use indigenous vegetation for residential gardens and inform residents of the importance for the use of indigenous vegetation within private gardens. o Provide assistance to residents with the purchase of fertiliser as well as application thereof. o Manage irrigation to prevent over-application. This helps prevent nutrient runoff and leaching into ground water. Table 10: Impact assessment results for operational phase. without with without with Extent Intensity Duration Consequence Probability Significance Status Confidence Increased stormwater runoff into retained wetland habitat from hard surfaces Long Medium Highly term Medium Medium -ve Medium (2) Probable Low Low Medium (2) Long term Low Probable Low -ve Medium Increase in wetland biodiversity and function Short term Long term Very Low Probable Very Low +ve Medium Medium Highly probable Medium +ve High Alternative Layout Plan Construction Phase The following direct construction phase impacts are expected to occur should the Alternative Layout Plan be selected; with reference to Table 9 below: Impact 1 - Loss of wetland habitat. The development of the Alternative Layout Plan will result in total loss of the wetland seep (approximately 856 m 2 ) as well as approximately 100 m 2 of the valley bottom wetland located within the southern corner of the proposed site. In addition, it will not be possible to implement the required 15 m buffer needed to adequately safeguard the valley bottom wetland from impact posed by the construction and operational related activities. The intensity of losing the entire seep permanently as well as not incorporating the 15 m buffer as part of the layout was considered to be of higher intensity compared to the Applicant s Preferred Alternative and

42 KHULA Page 42 was calculated to be of a high (negative) significance. The potential impact is unavoidable and it is not considered possible to mitigate. Essential measures: N/A Impact 2 Disturbance of wetland habitat. Edge effects of construction related activities such as the indiscriminate movement of vehicles and personnel and the dumping of excavated materials may result in the disturbance of wetland vegetation and in the compaction/disturbance of soils located within the immediate vicinity of the eastern boundary of the proposed site. Disturbance may also result in the proliferation of the alien and invasive species already present. Habitat associated with the valley bottom wetland has already been impacted as a result of alien and invasive species proliferation within the temporary wetland zone as well as infilling and increased runoff from surrounding roads and residential developments. These impacts have decreased the PES and EIS of the valley bottom wetland. The intensity of potential impact resulting from additional disturbance of wetland habitat is therefore considered to be medium and if not prevented or adequately mitigated, the impact could remain for a long-term duration. The overall impact was therefore rated as a medium (negative) significance. However, with the implementation of the measures as listed below, the intensity and duration of the impact can be decreased in turn decreasing the overall impact significance to very low (negative). Essential measures: Implement the Construction phase Environmental Management Programme (EMPr) that includes the following: o Physically demarcate the construction footprint boundary within the immediate vicinity of the valley bottom wetland and declare the valley bottom wetland as a No Go area prior to commencement of site clearing activities. o Only allow essential construction activities within the demarcated No Go area in accordance with approved method statements. o Prohibit the dumping of excess excavated material within the valley bottom wetland. o Once construction has been completed all construction waste, rubble, and equipment must be removed from the construction area. o Once construction has been completed, remove alien and invasive individuals, manually as far as practically possible, from the construction footprint as well as any areas accidentally disturbed. The use of herbicides should be avoided. However, if necessary, only herbicides which have been certified safe for use in wetlands/aquatic environments by an independent testing authority may be considered. Cover removed alien plant material properly when transported, to prevent it from being blown from vehicles, and burn on a bunded surface where no stormwater runoff is expected. o Should any accidental disturbance to portions of wetland falling outside of the demarcated construction footprint area take place, immediately rip compacted soil to a depth of 300mm and reprofile the area according to natural terrain units. If the disturbed area will be prone to erosion (sheet runoff or formation of gullies), it is recommended that straw bales (not Lucerne or hay) are used to intercept the bulk of the runoff. The bales should be placed strategically along contour lines and pegged. Disturbance and removal of vegetation within the immediate vicinity of the area where the bales are placed should be kept to a minimum. Sediment should be cleared manually as needed and disposed of at a registered waste facility. o Spray areas where severe amounts of dust are generated lightly with water or use other appropriate dust suppression techniques (e.g. straw bales). o Cover equipment and storage piles and reduce the speed of vehicles to limit dust generation.

43 KHULA Page 43 Optional measures: Restrict construction to the dry summer months (November to April). Impact 3 Alteration of the hydrological regime. The entire seep wetland will be infilled which will result in a permanent alteration of the hydrological regime within the proposed site as well as the immediate surrounding area and it would not be possible to mitigate this medium (negative) impact. Impact resulting from alteration of the hydrological regime of the valley bottom wetland will mainly be restricted to the operational phase of the development. As a result, construction related impact was considered insignificant and not assessed. However, alteration of the hydrological regime of the valley bottom wetland was considered as part of Impact 1 of the operational phase. Essential measures: N/A Impact 4 Water quality impairment. Vegetation clearing and construction related activities will be required in very close proximity to the valley bottom wetland. The extent of the development also does not allow for the advocated 15m buffer. The impact resulting from increased sediment loads reaching the valley bottom wetland within surface runoff originating from disturbed areas is therefore deemed definite if not adequately managed. Although the valley bottom wetland is already disturbed, large volumes of deposited sediment may be detrimental to wetland habitat resulting in loss of vegetation, habitat as well as function from affected areas. Spillage of fuel, chemicals and concrete utilised during construction will also pose a risk if not prevented or timeously addressed. Therefore, an impact intensity of medium and a duration of long term is considered applicable, prior to the implementation of measures. It would be difficult to entirely avoid the impact with the implementation of measures due to close proximity of construction areas to wetland habitat. However, with timeous removal of sediment deposited, the duration of the impact can be reduced. The potential impact was rated to be of medium (negative) significance prior to the implementation of measures and very low (negative) significance with the implementation of measures. Restricting site preparation and construction activities to the dry summer months (November to April) would decrease impact significance, however in practice this is not always achievable. As a result, in rating the impact significance, after, it was assumed that this will not be feasible. Essential measures: Ensure that measures are implemented during the construction phase that will allow for the adequate polishing of stormwater during the operational phase in line with the City of Cape Town Sustainable Stormwater Drainage Systems guidelines before it reaches the valley bottom wetland. Compile and implement a Construction phase Environmental Management Programme (EMPr) that includes the following pollution management specifications: o Place sediment fences / traps along the eastern boundary of the construction footprint, upslope of the valley bottom wetland. Ensure these are maintained and sediment is removed as needed. In addition, the wetland habitat associated with the valley bottom wetland should be monitored by the appointed ECO, weekly, for sedimentation and erosion in order to ensure erosion and sedimentation is dealt with timeously. Removal of sediment from wetland habitat should be done manually. o Clear and grade the site in a phased approach. Do not clear additional portions until exposed soils from the earlier phase have been stabilized and the construction is nearly completed.

44 KHULA Page 44 o o o o o o o o o o o o o o Ensure the unattended period after disturbance as a result of site preparation and ground breaking is kept to an absolute minimum. Restrict the dumping or storage of construction material to the western portion of the construction footprint. Demarcate areas where construction waste material and removed vegetation can be stored temporarily before it is disposed of appropriately. Water pumped from construction areas, following heavy rain, should be pumped to a demarcated settlement area and should not be discharged into the valley bottom wetland. Strategically divert stormwater runoff from the construction footprint into sediment trapping devices. All sediment trapping devices should be checked weekly by the ECO and cleared as needed. Avoid the use of infill material or construction material with pollution / leaching potential. Clean up any spillages (e.g. concrete, oil, fuel), immediately. Remove contaminated soil and dispose of it appropriately. Service vehicles and machinery within demarcated areas, preferably off-site. Use bunded surfaces within designated areas for re-fuelling vehicles. Vehicles should preferably be refueled off site. Dispose of oils, wash water from cement and other pollutants at an appropriate licenced site. Use and dispose of concrete and cement-related mortars in an environmental sensitive manner (can be toxic to aquatic life). Fresh concrete and cement mortar should not be mixed on-site, and both dry and wet materials should be stored away from green belt corridors and storm drains. These materials should be covered and contained to prevent contact with rainfall or runoff. Washout should not be discharged into streets, storm drains, drainage ditches, or watercourses. A washout area should be designated, and wash water should be treated on-site or discharged to the sanitary sewer. Store fuel, chemicals and other hazardous substances in suitable secure weather-proof containers and within an area with impermeable and bunded floors. Provide adequate temporary toilets for the duration of the construction phase. Temporary toilets should be located at least 20 m from the eastern boundary of the proposed site. No grey water should be passed into swales, valley bottom wetland or any other watercourses. Placement of backwash water from swimming pools into swales or watercourses should be strictly be prohibited and management thereof should be addressed during the construction phase. Table 11: Impact assessment results for the construction phase. Extent Intensity Duration Consequence Probability Significance Statu s without without with without without with High Medium (2) Low Medium (2) Medium (2) Low Confidence Loss of wetland habitat Long term High Definite High -ve High Disturbance of wetland habitat Long term Medium Definite Medium -ve High Short term Very Low Definite Very Low -ve High Alteration of the hydrological regime Long term Medium Definite Medium -ve High Water quality impairment Long term Medium Definite Medium -ve High Short term Very Low Definite Very Low -ve Medium

45 KHULA Page Operational Phase The following direct operational phase impact is expected to occur should the Alternative Layout Plan be selected. Impact 1 Transformation of wetland habitat. The development of hard surfaces e.g. parking areas, roads and buildings will result in an increase in the volume as well as velocity of stormwater entering the valley bottom wetland. Without the incorporation of swales and stormwater detention ponds as part of the layout plan, it would be difficult to manage stormwater runoff successfully during the operational phase. In addition, stormwater runoff from roads and buildings also has the potential to impact water quality of the valley bottom wetland. It is however considered possible to decrease the probability as well as significance of the impact with the implementation of the listed measures as part of the construction phase. The potential impact was rated to be of medium (negative) significance prior to the implementation of measures and low (negative) significance with the implementation of measures. Essential measures, to be implemented during the construction phase: Implement a Stormwater Management System in accordance with the City s Management of Urban Storm Water Impacts Policy (2009) that also achieves the following: o Install rainwater harvesting tanks at each residence. o Ensure that the post development runoff from the proposed site will not exceed pre-development runoff. o Use porous/permeable paving. o Use unlined vegetated swales that will allow for infiltration as appose to stormwater pipes. o Ensure that crossings over swales are adequate to enable surface water to flow freely underneath crossings. o If possible, convey stormwater into small detention ponds that are earth-lined, to allow filtration of water into the ground. o Line or install flow control practices within runoff conveyance channels where high runoff velocity and volume is expected. The first choice of lining is robust indigenous vegetation or sod because both reduce runoff velocities and provide water quality benefits through filtration and infiltration. If the velocity in the channel would erode the vegetation, turf reinforcement mats, riprap, concrete, or gabions can be used. o Route water from downspouts to vegetated swales or vegetated open areas to increase infiltration. o As far as practically possible stormwater originating from hard surfaces should be passed into vegetated swales in order to decrease water volume and velocity as well as increase water quality before reaching the valley bottom wetland. Otherwise, surface runoff should be diverted away from roads, pavements etc. as quickly as possible, to minimise the amount of water running directly from these areas into wetland habitat. This can be achieved with construction of multiple drains from roads, pavements etc. to ensure the least amount of surface water is discharged directly into a specific area. o Revegetate swales with indigenous fynbos as far as practically possible. Preferably, swales should not be mowed, therefore species with good ground covering capability which would not impede flow would need to be introduced. Species selection will need to be undertaken with guidance from the landscape architect in order to identify species that will be commercially available. o Stormwater runoff released from the proposed development into the valley bottom wetland should be discharged gradually over a large area as opposed to being channelled and passed into the wetland at one specific point. Energy dissipaters (such as lining with stones, concrete, grass or gabions) should be constructed where surface water discharged to reduce the water velocity and erosion potential.

46 KHULA Page 46 Impact 2 Disturbance of wetland habitat. No Wetland Rehabilitation and Management Plan are allowed for as part of the Alternative Layout Plan, as a result it is considered likely that the valley bottom wetland could be continuously disturbed during the operational phase due to ineffective management of alien and invasive vegetation, due to the potential proliferation of ornamental species and due to fertilisation and overwatering of gardens. The potential impact was rated to be of medium (negative) significance prior to the implementation of measures and low (negative) significance with the implementation of measures. Essential measures: Compile and implement an Operation phase Environmental Management Programme (EMPr) that includes the following specifications: o Implementation of fines by the development body for dumping by residents. Special mention is made of dumping of garden refuse into surrounding areas, this will result in spread of non-preferred species. o Use indigenous vegetation for residential gardens and inform residents of the importance for the use of indigenous vegetation within private gardens. o Provide assistance to residents with the purchase of fertiliser as well as application thereof. o Manage irrigation to prevent over-application. This helps prevent nutrient runoff and leaching into ground water. Table 12: Impact assessment results for operational phase. without with without with Extent Intensity Duration Consequence Probability Significance Status Confidence Increase in velocity and volume of stormwater entering wetland habitat Long Medium term Medium Definite Medium -ve High (2) Low Medium (2) Low Long term Low Probable Low -ve Medium Disturbance of wetland habitat Long term Medium Definite Medium -ve High Long term Low Probable Low -ve Medium 5.2. No Go Scenario Decades of anthropogenic activity within the proposed site has resulted in the severe modification of the natural hydrological regime as well as transformation of the natural vegetation assemblage. As a result, an improvement of wetland EIS is considered to be unlikely without significant efforts to rehabilitate. Therefore, without development, alien vegetation will persist and will continue to suppress the establishment of indigenous floral species throughout the proposed site. It is therefore highly likely that the current significance of impact on wetland related aspects such as hydrology and biodiversity will remain unchanged should the development not prove feasible. Table 13: Impact assessment results for the No Go Scenario.

47 KHULA Page 47 Extent Intensity Duration Consequence Probability Significance Status Confidence Low Long term Low Definite Low -ve Medium 5.3. Indirect Impacts No indirect impacts are deemed probable, provided that measures as listed for the direct impacts are adhered too Cumulative Impacts Cumulative impacts are impacts that result from the incremental impact of the proposed activity on freshwater systems within a greater catchment, ecoregion and wetland vegetation group when added to the impacts of other past, present or reasonably foreseeable future activities. The primary cumulative impacts in respect of the proposed development include: Loss of wetland habitat. Alteration of flow regime in the catchment. Proliferation of alien vegetation in turn outcompeting indigenous vegetation. Impairment of water quality in the catchment. The proposed construction of infrastructure within wetland habitat would add to the cumulative loss of wetland habitat from the region. However, the wetland habitat in its present state is no longer considered representative of the Critically Endangered West Coast Granite Renosterveld wetland vegetation group. Furthermore, the rehabilitation and landscaping of remaining wetland areas within the eastern portion of the proposed site could add to functional wetland habitat in the region which is more representative of the natural wetland vegetation type. 6. Offset Requirements The guideline emphasises that wetland offsets are applied within the hierarchy and are only aimed at compensating for significant residual impacts of project development on the environment after all appropriate steps have first been taken to avoid/prevent, minimise/reduce and remediate/rehabilitate impacts. Wetlands offsets cannot, therefore, be applied as the only or first option; the prior sequence of steps must first be exhausted (taken from the wetland offset guideline 2016). Figure 16: The hierarchy.

48 KHULA Page 48 1) Investigation of alternative sites: TDV Developments (PTY) Ltd already purchased ERF 271 and a team of consultants have been appointed. Consideration of another property in order to avoid impact on wetland entirely is not feasible. 2) Investigation of alternative types and scales of development: The site is located within the urban edge within an established residential area and promotes the densification. Access to the site exists and the Municipality has sufficient available capacity to service the development. The proposed development is in keeping with the surrounding land use (primarily single residential). 3) Investigation of alternative layouts for the development: The Basic Assessment process has entailed the assessment for the following alternatives in equal detail: Applicants Preferred Layout Plan (incorporating 7 residential units, a private driveway and a private open space where wetland rehabilitation is proposed); Alternative Layout Plan (comprising 7 residential units and a private driveway no wetland rehabilitation area is proposed); The No-Go Alternative (i.e. status quo). No site alternatives, technology alternatives or operational alternatives have been considered nor are any warranted. The two layout alternatives both present economically viable alternatives but environmentally the Applicants Preferred Layout Plan will not encroach onto the valley bottom wetland located to the south east of the site and will also expand the current wetland habitat within the area earmarked for private open space (approximately 864 m² total wetland habitat conserved), and the immediate surroundings will be rehabilitated (total area extending 1053 m² including retained wetland habitat). The Applicants Preferred Layout Plan also includes a 15m buffer which is required from the valley bottom wetland to reduce any potential impacts on this feature. Given that there are no layout-related requirements for the identified potentially significant impact (loss of wetland) no further amendments to the Applicants Preferred Layout Plan are required. As such the environmentally preferred layout is, in terms of potential freshwater impacts considered to be the most environmentally preferred alternative (extract from the Basic Assessment Report, 2018). 4) Effort to minimise negative impacts and to rehabilitate or remediate affected areas: The layout and design of the Applicant s Preferred Alternative has been extensively workshopped with involvement of the freshwater specialist in order to attain the most environmentally sensitive layout which could also accommodate the proposed development. Rehabilitation (improvement in wetland condition, function, and associated biodiversity) is listed as one of the means by which a wetland offset can be achieved (The national guidelines for wetland offsets by Macfarlane et. al., 2014). The proposed rehabilitation of the remaining wetland areas was therefore assessed as an onsite offset. The guiding principles used during the offset determination are provided below: ASSESSING OFFSET REQUIREMENTS: It should be noted that it is impossible to determine the exact extent of transformation of wetland habitat following development, the offset calculator was applied based on the specialists understanding of the proposed rehabilitation plan and proposed stormwater management guidelines. It is however the opinion of the specialist that the approach followed are sufficient to estimate the offset requirements.

49 KHULA Page 49 Approximately 623 m 2 of the 856 m 2 seep wetland will need to be infilled in order for the proposed development to prove feasible. The private open space will incorporate the remaining portion of the seep wetland and will be expanded by approximately 864 m 2 within the area earmarked for private open space, and the immediate surroundings will be rehabilitated (total area extending 1053 m 2 including retained wetland habitat). The overall WET-Health score calculated falls within a PES Category E (The change in ecosystem processes and loss of natural habitat and biota is great but some remaining natural habitat features are still recognisable). Which places the functional value percentage, prior to development at 34% 20. The proposed internal road for the development will be graded towards the lowest point of the development where stormwater runoff will be collected via concrete kerbs and channels and a stormwater catch pit with an underground pipe towards a new stormwater swale area, between the development and the new wetland area. The internal stormwater network will be designed to safely accommodate and covey the 1:2 and 1:5 year storm events towards the new stormwater sale area while allowance must be made for larger storm events to safely discharge stormwater above ground towards the stormwater sale areas. The swale area will allow for the detention of stormwater as well as the treatment of stormwater before it is released. Extract from the civil engineering services report. As a result, the infilled portion would not be functional after development which equals a percentage of 0. The score calculated for the WET-Health vegetation module falls within a Category E (The change in ecosystem processes and loss of natural habitat and biota is great but some remaining natural habitat features are still recognisable). Which places the habitat intactness percentage, prior to development at 38% 21. The low percentage was confirmed during the botanical investigation undertaken by Bergwind in Vegetation will be permanently lost within the area to be infilled which equates to a percentage of 0, after development. Wetlands associated with the proposed site fall within the West Coast Granite Renosterveld wetland vegetation group (NFEPA, 2011), listed as critically endangered within the region and is considered to be not protected 22. Two freshwater features are located within 500m from the proposed site (NFEPA, 2011 and City of Cape Town wetland layer, 2015). However, extensive residential housing and roads are located between the features and the proposed site. It is therefore not considered possible for the proposed development to pose any risk to these features. The degraded wetland habitat, that will be lost due to development, was not considered of significant importance in terms of faunal or floral conservation. The Wetland EcoServices assessment indicated that only 5 of the 15 Ecosystem services assessed for the severely degraded wetland habitat are of intermediate or higher importance. The degraded wetland habitat within the proposed site was found to be of greatest importance in terms of the provision of indirect benefits such as enhancement of water quality and erosion control. The extent to which these services are provided will increase substantially following the proposed rehabilitation of remaining wetland habitat. No Species of Conservational Concern were identified or were considered to have a high probability of occurrence within the proposed development area. No assessment for Species of Conservational Concern was therefore undertaken. ASSESSING THE OFFSET RECEIVING SITE: Total rehabilitated area extending 1053 m 2 is included as part of the Applicants Preferred Layout Plan (including retained wetland habitat). 20 Overall WET-Health score =6,6. 21 WET-Health vegetation module score =6, SANBI 2012, Wetlands Offset Calculator.

50 KHULA Page 50 Functional value of the retained wetland habitat would increase substantially after successful implementation of the Wetland Rehabilitation Plan. The City of Cape Town s wetland layer (2017) indicates the valley bottom wetland as a CESA and areas along this wetland system which have been impounded as OESAs. The wetland to be infilled was excluded from the layer. The WET-Health assessment was not repeated for a potential post rehabilitation scenario, however it is the opinion of the specialist that a Category of at least C (Moderately modified. A moderate change in ecosystem processes and loss of natural habitats has taken place but the natural habitat remains predominantly intact) will be achieved; which places the habitat intactness and functional value percentages, following rehabilitation, roughly at 74%. A summary of the results is presented in the table below and the comprehensive results are presented in Appendix 2. Table 14: Wetland Offset Results summary. Offset Requirement Receiving Area Wetland Functionality Target 0,0 Functional hectare equivalents 0,0 Functional hectare equivalents Ecosystem Conservation Target 0,2 Habitat hectare equivalents 0,1 Habitat hectare equivalents Species Conservation Target N/A N/A The portion of wetland lost is small enough to equate to a functional hectare equivalent of 0. The habitat hectare equivalents target calculated for the receiving area are slightly lower compared to the offset requirements. Acquiring an additional portion of land which can be secured into perpetuity in order to meet the remaining targets, in the opinion of the specialist, is not practical. It is therefore recommended that the proposed onsite rehabilitation, be considered sufficient to make up the shortfall. 7. Conclusion and Recommendation Historical imagery available on Google Earth Pro (2017) revealed that the site has been subjected to significant earthworks several times in the past decade. After the most recent earthworks the site has been left undisturbed and alien species such as Pennisetum clandestinum have established and currently dominate the majority of the site. Wetland habitat, dominated by Typha capensis, was identified within the centre of the site, however the source of the water could not be determined. For the purposes of this study it has been assumed that the wetland habitat identified historically formed part of a greater seep wetland that has been fragmented and in some areas entirely lost due to development. The seep wetland presently augments the larger valley bottom wetland located on the south-eastern boundary of the site. The overall PES score calculated for the seep wetland falls within a Category E and for the valley bottom wetland within a Category C. The overall EIS score calculated for the seep wetland falls within the low category implying that the wetland is not ecologically important and sensitive at any scale. However, the overall EIS score calculated for the valley bottom wetland falls within a high category implying that the wetland is sensitive and ecologically important. At least a portion of the seep wetland will need to be infilled in order for the proposed residential development to prove feasible. The proponent did however commit to the rehabilitation of the eastern portion of the proposed site, in an effort to recreate the area of wetland habitat that will be lost as well as to rehabilitate and by so doing improve the 15 m buffer required to safeguard the valley bottom wetland. The proposed development will however require Environmental Authorisation in terms of the NEMA Environmental Impact Assessment Regulations (2014) as well as authorisation from the Department of Water and Sanitation (DWS) in terms of section 21 (c) and (i) of the National Water Act (NWA).

51 KHULA Page 51 Two alternative layouts have been proposed for the proposed residential development, namely the Applicant s Preferred Layout Plan and the Alternative Layout Plan. The loss of wetland habitat as a result of the extensive infilling associated with the Alternative Layout Plan was rated to be of high (negative) impact significance and no measure would decrease the significance of the impact. The layout and design of the Applicant s Preferred Layout Plan has accommodated both the measures recommended in this report as well as the comments received from DWS following the pre-application meeting. As such it is the opinion of the specialist that wetland biodiversity and function can be increased with the development of this alternative to the extent that a net gain in wetland function and wetland service provision is achieved. It is therefore the opinion of the specialist that authorisation for the development of the Applicants Preferred Alternative, from a freshwater ecological perspective may be granted, provided that all essential measures listed within this report are strictly adhered too. 8. References Bromilow, C Revised Edition, First Impression. Problem Plants of South Africa. Briza Publications, Pretoria, RSA. Dada, R., Kotze D., Ellery W. and Uys M WET-RoadMap: A Guide to the Wetland Management Series. WRC Report No. TT 321/07. Water Research Commission, Pretoria. De Villiers, C., Driver, A., Clark, B., Euston-Brown, D., Day, L., Job, N., Helme, N., Van Ginkel, CE., Glen, RP., Gordon-Gray, KD., Cilliers, CJ., Muasya, M and van Deventer, PP Easy identification of some South African Wetland Plants. WRC Report No TT 479/10. Department of Water and Sanitation A Desktop Assessment of the Present Ecological State, Ecological Importance and Ecological Sensitivity per Sub Quaternary Reaches for Secondary Catchments in South Africa. Department of Water Affairs and Forestry Resource Directed Measures for Protection of Water Resources. Volume 3: River Ecosystems Version 1.0, Pretoria. Department of Water Affairs and Forestry A practical field procedure of identification and delineation of wetlands and riparian areas. DWA, Pretoria, RSA. Department of Water Affairs and Forestry Updated Manual for the Identification and Delineation of Wetlands and Riparian Areas, prepared by M. Rountree, A. L. Batchelor, J. MacKenzie and D. Hoare. Stream Flow Reduction Activities, Department of Water Affairs and Forestry, Pretoria, South Africa. Du Preez, L. and Carruthers, V A complete guide to the frogs of Southern Africa. Struik Nature, Cape Town. Esler, K.J., Pierce, S.M. and de Villiers, C Fynbos: Ecology and Management. Briza Publications, Pretoria. Google Earth Pro '21.04"S, 18 49'41.42"E. < [Viewed July 2017]. Kemper, N., Resource Directed Measures for Protection of Water Resources: River Ecosystem. Intermediate Habitat Integrity Assessment for use in the rapid and intermediate assessments. Kirkwood, D., Pence, G.Q.K. & von Hase, A Western Cape Biodiversity Framework: Critical Biodiversity Areas and Ecological Support Areas of the Western Cape. A C.A.P.E. Land-use planning project. Unpublished Project Report. Kleynhans, C.J., Thirion, C. and Moolman, J A Level I River Ecoregion Classification System for South Africa, Lesotho and Swaziland. Report No. N/0000/00/REQ0104. Resource Quality Services, Department of Water Affairs and Forestry, Pretoria, South Africa. Kotze, D.C., Marneweck, G.C., Batchelor, A.L., Lindley, D.S., and Collins, N.B., Wet-EcoServices: A technique for rapidly assessing ecosystem services supplied by wetlands. WRC Report No TT 339/09, Water Research Commision, Pretoria.

52 KHULA Page 52 Kotze, D., Ellery, W., Rountree, M., Grenfell, M., Marneweck, G., Nxele, I., Breen, C., Dini, J., Batchelor, A., Sieben, E WET-RehabPlan. Guidelines for planning wetland rehabilitation in South Africa. WRC Report TT 336/09. Water Research Commision, Pretoria. Macfarlane, D.M. and Bredin, I.P Buffer zone guidelines for rivers, wetlands and estuaries. Part 2: Practical Guide. WRC Report No (tbc), Water Research Commission, Pretoria. Macfarlane, D.M., Kotze, D.C., Ellery, W.N., Walters, D., Koopman, V., Goodman, P. and Goge, C WET-Health: A technique for rapidly assessing wetland health. WRC Report No TT 340/09, Water Research Commision, Pretoria. Mucina, L. and Rutherford, M.C. (EDS.) The vegetation of South Africa, Lesotho and Swaziland. Strelitizia 19. South African National Biodiversity Institute, Pretoria, South Africa. Nel, JL, Driver, A., Strydom W.F., Maherry, A., Petersen, C., Hill, L., Roux, D.J, Nienaber, S., Van Deventer, H., Swartz, E. & Smith-Adao, L.B. 2011a. Atlas of Freshwater Ecosystem Priority Areas in South Africa: Maps to support sustainable development of water resources. Water Research Commission Report No. TT 500/11, Water Research Commission, Pretoria, RSA. Ollis, D.J., Day J.A., Malan, H.L., Ewart-Smith J.L., and Job N.M. (2014) Development of a decision-support framework for wetland assessment in South Africa and a decision-support protocol for the rapid assessment of wetland ecological condition. WRC Report No. TT 609/14 Ollis, D.J., Snaddon, C.D., Job, N.M. and Mbona, N Classification System for Wetlands and other Aquatic Ecosystems in South Africa. User Manual: Inland Systems. SANBI Biodiversity Series 22. South African National Biodiversity Institute, Pretoria. Pence, Genevieve Q.K C.A.P.E. Fine-Scale Systematic Conservation Planning Assessment: Technical Report. Produced for CapeNature as part of the GEF-funded C.A.P.E. Fine-Scale Biodiversity Planning Project. Cape Town, South Africa. Pence, G Q.K Western Cape Biodiversity Framework 2014 Status Update: Critical Biodiversity Areas of the Western Cape. Unpublished CapeNature project report. Cape Town, South Africa. Rountree, M.W., Malan, H.L., Weston, B.C Manual for the Rapid Ecological Reserve Determination of Inland Wetlands (Version 2.0). WRC Report No. 1788/1/12 Rowntree, K.M., Wadeson, R.A. and O Keeffe, J The Development of a Geomorphological Classification System for the Longitudinal Zonation of South African Rivers. Russel, W.B., WET-RehabMethods. National guidelines and methods for wetland rehabilitation. WRC Report No 341/09. Water Research Commission, Pretoria. South African National Biodiversity Institute, Vegetation Map of South Africa, Lesotho and Swaziland. Available from the Biodiversity GIS website, downloaded on the 21 June The South African National Biodiversity Institute - Biodiversity GIS (BGIS) [online]. URL: Van Oudtshoorn, F Second Edition, Third Print. Guide to Grasses of South Africa. Briza Publications, Pretoria, RSA.

53 KHULA Page 53 Appendix 1 Impact Assessment Criteria The significance of an impact was defined as a combination of the consequence of the impact occurring and the probability that the impact will occur. The criteria used to determine impact consequence are presented in Table 15 below. Table 15: Criteria used to determine the consequence of the impact. Rating Definition of Rating Score A. Extent the area over which the impact will be experienced. None 0 Regional Confined to project or study area or part thereof (e.g. site) The region, which may be defined in various ways, e.g. cadastral, catchment, topographic (Inter) national Nationally or beyond 3 B. Intensity the magnitude of the impact in relation to the sensitivity of the receiving environment None 0 Low Medium High Natural and/or social functions and processes are negligibly altered Natural and/or social functions and processes continue albeit in a modified way Natural and/or social functions or processes are severely altered C. Duration the time frame for which the impact will be experienced None 0 Short-term Up to 2 years 1 Medium-term 2 to 15 years 2 Long-term More than 15 years The combined score of these three criteria corresponds to a Consequence Rating, as set out in Table 16. Table 16: Method used to determine the consequence score. Combined Score (A+B+C) Consequence Rating Not significant Very low Low Medium High Very high Once the consequence was derived, the probability of the impact occurring was considered, using the probability classification presented in Table 17.

54 KHULA Page 54 Table 17: Probability classification. Probability of impact the likelihood of the impact occurring Improbable Probable Highly probable Definite <40% chance of occurring 40% - 70% chance of occurring >70% - 90% chance of occurring >90% chance of occurring The overall significance of the individual impacts was determined by considering consequence and probability using the rating system as prescribed in Table 18. Table 18: Impact significance rating. Significance Rating Consequence Probability Insignificant Very Low & Improbable Very Low & Possible Very Low Very Low & Probable Very Low & Definite Low & Improbable Low & Possible Low Low & Probable Low & Definite Medium & Improbable Medium & Possible Medium Medium & Probable Medium & Definite High & Improbable High & Possible High High & Probable High & Definite Very High & Improbable Very High & Possible Very High Very High & Probable Very High & Definite The impacts were also considered in terms of their status (positive or negative impact) and the confidence in the ascribed impact significance rating. The prescribed system for considering impact status and confidence (in assessment) is laid out in Table 19.

55 KHULA Page 55 Table 19: Impact status and confidence classification. Status of impact Indication whether the impact is adverse (negative) or beneficial (positive). Confidence of assessment The degree of confidence in predictions based on available information, judgement and knowledge. +ve (positive a benefit) -ve (negative a cost) Neutral Low Medium High The impact significance rating should be considered by the authority in their decision making process based on the implications of ratings described below: Insignificant: the potential impact is negligible and will not have an influence on the decision regarding the proposed activity/development. Very Low: the potential impact should not have any meaningful influence on the decision regarding the proposed development/activity. Low: the potential impact may not have any meaningful influence on the decision regarding the proposed development/activity. Medium: the potential impact should influence the decision regarding the proposed development/activity. High: the potential impact will influence the decision regarding the proposed development/activity. Very High: The proposed activity should only be approved under special circumstances. In the impact assessment practicable measures will be recommended and impacts rated in the prescribed way both without and with the assumed effective implementation of measures. Mitigation measures provided are either: Essential: must be implemented (as they minimise potential significant negative impacts) and are non-negotiable. Optional / Recommended: nice to have s as they do little to minimise a key potentially significant impact and or improve benefits.

56 Offset Calculation Determining offset ratios Impact Assessment Offset calculation Impact Assessment KHULA Page 56 Appendix 2 Offset Calculation Table 20: Determining Offset Requirement. Wetland Functionality Targets Prior to development Post development Wetland size (ha) Functional v alue (%) Functional v alue (%) Change in functional v alue (%) 0,06 34,00 0,00 34,00 Key Regulating and Supporting Services Identified Development Impact (Functional hectare equivalents) pollutant assimilation, flood attenuation and erosion control 0,0 Offset Ratios Triggers for potential adjustment in exceptional circumstances Functional Importance Ratio None 1,0 Functional Offset Target (Functional hectare equivalents) 0,0 Ecosystem Conservation Targets Prior to development Post development Wetland size (ha) Habitat intactness (%) Habitat intactness (%) Change in habitat intactness (%) 0, Development Impact (Habitat hectare equivalents) Wetland Vegetation Group (or type based on local clasification) 0,02356 West Coast Granite Renosterv eld Ecosystem Status Threat status of wetland Protection level of wetland Threat status CR Threat status Score 15 Protection lev el Not Protected Protection lev el Score 2 Ecosystem Status Muliplier 30 Regional and National Conservation context Priority of wetland as defined in Regional and National Conserv ation Plans Not specifically identiifed as important 0,5 Regional & National Context Multiplier 0,5 Uniqueness and importance of biota present in the wetland Low biodiversity value 0,5 site attributes Buffer zone integrity (within 500m of wetland) Buffer compatability score 0 connectiv ity Moderate connectiv ity 0,75 Context Multiplier Ecosystem Conservation Ratio 0,4 6,38 Development Impact (Habitat hectare equivalents) 0,0 Ecosystem Conservation Ratio 6,4 Ecosystem Conservation Target (Habitat hectare equivalents) 0,2

57 KHULA Page 57 Table 21: Assessing receiving areas. Contribution Towards Wetland Functionality Targets Wetland attributes Wetland Reference ERF 271 Bakkershoogte Criterion Relevance Site attributes Acceptability Guidelines Wetland type Targeted wetlands should typically be of the same type to ensure that similar serv ices to those impacted are improv ed through offset activ ities. Wetland is of the same type as the impacted wetland. Ideal Alignment with site selection guidelines Key serv ices targeted Targeted wetlands should be prioritised and selected based on their ability to compensate for key regulating and supporting serv ices impacted by the proposed dev elopment. Selected wetland is well placed to contribute meaningfully towards improv ing key regulating and supporting serv ices identified. Ideal Offset site location relativ e to Targeted wetlands should ideally be located as close to the Selected wetland is located within the same local Ideal impacted wetland impacted site as possible. catchment as the impacted wetland. Overall comment on alignment with site selection guidelines Preliminary Offset Calculation Final Offset Calculation Prior to offset activities Following sucessful offset implimentation Wetland size (ha) 0,062 Functional v alue (%) 34 Functional v alue (%) 74 Change in functional v alue (%) 40 Preliminary Offset Contribution (Functional hectare equivalents) 0,0 Criterion Relevance Offset activity Adjustment factor Types of offset activ ities proposed The risk of offset failure is linked to the type of offset activ ity planned with wetland establishment considered less preferable and more risky Rehabilitation & Protection 0,66 than rehabilitation or averted loss activities. Final Offset Contribution (Functional hectare equivalents) 0,0 Contribution Towards Ecosystem Conservation Targets Wetland attributes Wetland Reference Wetland Vegetation Group (or type based on local clasification) ERF 271 Bakkershoogte West Coast Granite Renosterv eld Threat status of wetland Threat status CR Alignment with site selection guidelines Criterion Relevance Site attributes Targeted wetlands should be aligned with "like-for-like" criteria to Wetland is of the same wetland type within the same Like for Like ensure that gains associated with wetland protection are wetland v egetation group commensurate with losses. To what degree is wetland selection aligned with Regional and Wetlands hav e not been specifically identified as Landscape planning National Conserv ation Plans important in landscape planning The habitat condition of the wetland should ideally be as good / Final habitat condition is likely to be better than that of Wetland condition better that that of the impacted site prior to dev elopment (or at the impacted wetland. least B PES Category in the case of largely un-impacted wetlands) Wetlands that are unique or that are recognised as hav ing a high The wetland is charachterised by habitat and / species biodiv ersity v alue local biodiv ersity v alue should be prioritised for wetland protection. of moderate biodiversity value. Acceptability Guidelines Ideal May be acceptable Ideal Acceptable Viability of maintaining conserv ation v alues Connectiv ity and consolidation with other intact ecosystems together with the potential for linkage between existing protected areas is preferable. The wetland is well connected to other intact natural areas Acceptable Overall comment on alignment with site selection guidelines Wetland size (ha) 0,1 Wetland areas to be secured Habitat intactness (%) 74 Preliminary Offset Calculation Wetland habitat contribution (hectare equivalents) Area of wetland buffer zone included in the wetland offset site 0,1 0,01 Buffer zones to be secured Integrity of buffer zone Buffer zone hectare equiv alents 0,5 0,0 Buffer zone contribution (hectare equivalents) 0,0 Criterion Relevance Site attributes Adjustment factor Final Offset Calculation Security of tenure Offset activ ities that formally secure offset sites for longer than the minimum requirement are more likely to be maintained in the longterm and are therefore preferred. Wetland habitat contribution (hectare equiv alents) Minimum acceptable security of tenure for a longer period 0,1 1,5 Offset Contributions Buffer zone contribution (hectare equiv alents) 0,0 Functional Offset Contribution (hectare equivalents) 0,1

58 P O Box Scarborough June 2018 Dear Mrs. M. Sham This letter as well as the Water Use Licence technical document provided serves as confirmation that KHULA is in the process of completing the Water Use Licence Application in line with the requirements set in the procedural requirements for Water Use Licence Applications promulgated on the 27 March Proof of submission to the Department of Water and Sanitation will be provided as soon as it becomes available. Regards, Natasha van de Haar Pri.Sci.Nat (400229/11)

59 June 2018 Department of Water and Sanitation (DWS) Sanlamhof Bellville Western Cape Tel: (021) To whom it may concern, RE: WATER USE LICENSE APPLICATION IN RESPECT OF ERF 271 BAKKERSHOOGTE, SOMERSET WEST, WESTERN CAPE PROVINCE This document serves as the technical document in line with the requirements set in the procedural requirements for Water Use Licence Applications promulgated on the 27 March Table 1: Applicant and Property Information. Applicant details Name of applicant (Company) TDV Developments (Pty) Ltd Business registration number 2017/011733/07 Contact details of applicant Postal address PO Box 2113 Somerset West 7130 City Somerset West Phone number Property details Water management area Berg Olifants Sub water management area Greater Cape Town Quaternary catchment G22J Property name ERF 271 Bakkershoogte Project description The Applicant s Preferred Layout Plan incorporates 7 residential units and one private driveway which will allow access to all the units, as well as a private open space extending over approximately 1053m 2 wherein wetland rehabilitation is proposed. Approximately 623m 2 of the 856m 2 seep wetland will need to be infilled in order for the proposed development to prove feasible. However, the private open space will incorporate the remaining portion of the seep wetland and will not encroach onto the valley bottom wetland. In addition, the current wetland habitat will be expanded (approximately 864m 2 ) within the area earmarked for private open space, and the immediate surroundings will be rehabilitated (total area extending 1053m 2 including retained wetland habitat). A15 m buffer is required for the valley bottom wetland and will overlap with the area proposed for rehabilitation. Water Use License Application - ERF 271, Bakkershoogte