Cape Environmental Assessment Practitioners (Pty) Ltd

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1 Cape Environmental Assessment Practitioners (Pty) Ltd Reg. No. 2008/004627/07 Telephone: (044) st Floor Eagles View Building Facsimile: (044) Progress Street, George Web: PO Box 2070, George 6530 DRAFT SCOPING REPORT & PLAN OF STUDY FOR ENVIRONMENTAL IMPACT ASSESSMENT for RICHTERSVELD SOLAR PROJECT on Portion 10 (Arris) of the Farm Korridor Wes No. 2, Portion 9 of the Farm Korridor Wes No.2 and Remainder of Farm Groot Derm Farm No.10 (Namakwaland District) In terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998), as amended & Environmental Impact Regulations 2010 Prepared for Applicant: Richtersveld Sunspot (Pty) Ltd By: Cape EAPrac Report Reference: RIC277/05 Department Reference: 14/12/16/3/3/3/2/624 Department Enquiries: Mmatlala Rabothata Date: 25 August 2014 D.J. Jeffery Directors L. van Zyl

2 RIC277/05 APPOINTED ENVIRONMENTAL ASSESSMENT PRACTITIONER: Cape EAPrac Environmental Assessment Practitioners PO Box 2070 George 6530 Tel: Fax: Report compiled by: Louise-Mari van Zyl (MA Geography & Environmental Science [US]; Registered Environmental Assessment Practitioner with the Interim Certification Board for Environmental Assessment Practitioners of South Africa, EAPSA; Mrs van Zyl has over twelve years experience as an environmental practitioner. PURPOSE OF THIS REPORT: Stakeholder Review APPLICANT: Richtersveld Sunspot (Pty) Ltd CAPE EAPRAC REFERENCE NO: RIC277/05 DEPARTMENT REFERENCE: 14/12/16/3/3/2/624 SUBMISSION DATE 25 August 2014

3 RIC277/05 DRAFT SCOPING REPORT & PLAN OF STUDY FOR EIR in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998), as amended & Environmental Impact Regulations 2010 RICHTERSVELD SOLAR PROJECT Portion 10 (Arris) of the Farm Korridor Wes No. 2, Portion 9 of the Farm Korridor Wes No.2 and Remainder of Farm Groot Derm Farm No.10 (Namakwaland District) Submitted for: Stakeholder Review & Comment This report is the property of the Author/Company, who may publish it, in whole, provided that: Written approval is obtained from the Author and that Cape EAPrac is acknowledged in the publication; Cape EAPrac is indemnified against any claim for damages that may result from any publication of specifications, recommendations or statements that is not administered or controlled by Cape EAPrac; The contents of this report, including specialist/consultant reports, may not be used for purposes of sale or publicity or advertisement without the prior written approval of Cape EAPrac; Cape EAPrac accepts no responsibility by the Applicant/Client for failure to follow or comply with the recommended programme, specifications or recommendations contained in this report; Cape EAPrac accepts no responsibility for deviation or non-compliance of any specifications or recommendations made by specialists or consultants whose input/reports are used to inform this report; and All figures, plates and diagrams are copyrighted and may not be reproduced by any means, in any form, in part or whole without prior written approved from Cape EAPrac. Report Issued by: Cape Environmental Assessment Practitioners Tel: PO Box 2070 Fax: Progress Street Web: George 6530 Cape EAPrac Draft Scoping Report

4 RIC277/05 REPORT DETAILS Title: DRAFT SCOPING REPORT for proposed Purpose of this report: This DRAFT Scoping Report forms part of a series of reports and information sources that are being provided during the Environmental Impact Assessment (EIA) for the proposed in the Namakwaland District. In accordance with the EIA Regulations, the purpose of the Scoping Report is to: Provide a description of the proposed project, including a sufficient level of detail to enable stakeholders to identify relevant issues and concerns; Describe the local environmental and developmental context within which the project is proposed, to assist further identifying issues and concerns; Provide an overview of the process being followed in the Scoping Phase, in particular the public participation process, as well as present the Plan of Study for EIA that would be followed in the subsequent EIA phase; Present the issues and concerns identified to date from the baseline specialist studies and the initial stakeholder engagement process, as well as an explanation of how these issues will be addressed through the EIA process. This Draft Scoping Report is made available to all stakeholders for a 40 day review & comment period, Friday 29 August to Friday 10 October This final Scoping Report will reflect on all comments received and be made available for a further 21 day comment period. Prepared for: Published by: Authors: Cape EAPrac Ref: DEA Contact person Ref. No: Richtersveld Sunspot (Pty) Ltd Cape Environmental Assessment Practitioners (Pty) Ltd. (Cape EAPrac) Mrs Louise-Mari van Zyl RIC277/05 Mrs Mmatlala Rabothata 14/12/16/3/3/2/624 Date: 25 August 2014 To be cited as: Cape EAPrac, Draft Scoping Report for the proposed Richtersveld Solar Project. Report Reference: RIC277/05. George. Cape EAPrac Draft Scoping Report

5 RIC277/05 ORDER OF REPORT Executive Summary Draft Scoping Report Main Report Appendix A : Location, Topographical & Development Site Plans Appendix B : Site Photographs Appendix C : Solar Facility Layout Alternatives & Layout Report Appendix D : Specialist Reports Annexure D1 : Ecological Scoping Report (Todd, 2014) Annexure D2 : Agricultural Potential Study (Lubbe, 2014) Annexure D3 : Heritage Scoping Report (Townsend, 2014) Annexure D4 : Archaeology Report (Hart, 2014) Annexure D5 : Visual (O Donaghue, 2014) Annexure D6 : Social (Barbour, 2014) Annexure D7 : Planning (Saunders, 2014) Appendix E : Public Participation Process Appendix F : Other Information Annexure F1 : Correspondence with Authorities Acceptance of Application Annexure F2 : NPAES Map, BGIS LUDS Evaluation Appendix G : Sida!HUB CPA consent letter for 200ha alternative Appendix H : Background Information Document (BID) Cape EAPrac Draft Scoping Report

6 RIC277/05 TABLE OF CONTENTS REPORT SUMMARY1... PROJECT OVERVIEW I 2 NEED AND DESIRABILITY... I 3 ENVIRONMENTAL REQUIREMENTS... II 5 SITE DESCRIPTION... III 6 DEVELOPMENT PROPOSAL & ALTERNATIVES... III 7 SPECIALIST STUDIES... IV 8 PLANNING CONTEXT... IV 10 PROCESS TO DATE... V 11 CONCLUSIONS & RECOMMENDATIONS... VII 1 INTRODUCTION Overview of Alternative Energy in South Africa and the Northern Cape LEGISLATIVE AND POLICY FRAMEWORK The Constitution of the Republic of South Africa National Environmental Management Act (NEMA) National Environmental Management: Biodiversity (ACT 10 OF 2004) National Forests Act (No. 84 of 1998): Conservation of Agricultural Resources Act CARA (Act 43 of 1983): Northern Cape Nature Conservation Act, No. 9 of 2009: Nature and Environmental Conservation Ordinance (19 of 1974) National Heritage Resources Act National Water Act, NO 36 OF National Protected Area Expansion Strategy (NPAES) for S.A (2010) Namaqua District Biodiversity Sector Plan, Sustainability IMPERATIVE ACTIVITY CONSIDERATION OF ALTERNATIVES Activity Alternatives Site Alternatives grid connection alternatives No-Go Alternative ENGINEERING OVERVIEW Basic understanding of solar plants Site development components Position of solar facilities Foundation footprint CPV System/PV Panel height Access road to site Internal roads On-site substations and transformers Cable routes and trench dimensions Connection routes to the distribution/transmission network Security fence Auxiliary buildings Cut and fill areas Cape EAPrac Draft Scoping Report

7 RIC277/ Borrow pits Soil heaps Construction of the proposed facility Transportation of solar components and equipment to site Establishment of internal access roads on the farm Site preparation Erecting of solar PV panels Construct ion of on-site substation Establishment of additional infrastructure Connect on-site substation to power grid Undertake site remediation Water Use Requirements Water Sources Water buffer Water-use permission Erosion and storm water control Project operation and maintenance phase Project decommission phase Waste effluent, emission and noise management (Construction, Operation & DECOMMISSIONING) SOCIO-ECONOMIC CONTEXT Project cost overview Project specific costs Operational Revenue streams EMPLOYMENT OPPORTUNITIES SITE DESCRIPTION AND ATTRIBUTES location & built environment Geology & Climate Geology Climate SOILS topography Vegetation Scope of Study Sensitivity Mapping & Assessment Baseline Description of the Affected Environment Faunal Communities PLANNING CONTEXT AGRICULTURAL POTENTIAL STATEMENT Objectives Approach and Methodology Desktop Study Field Investigation Assumptions and Limitations Past and Current Agricultural Activities on Site Agricultural Structures on site Agricultural study findings Identification of possible impacts on agricultural potential ECOLOGICAL SENSITIVITY ANALYSIS Cape EAPrac Draft Scoping Report

8 RIC277/ Potential impacts impacts to be assessed Conclusion & Preliminary Recommendations HERITAGE CONSIDERATIONS Purpose of study Heritage features of the region Pre-Colonial Heritage Colonial Heritage Living Heritage: The Nama Impact on power lines Paleaontology Recommendations for further HERITAGE study VISUAL CHARACTER AND IMPACT key visual issues SUMMARY OF SITE CONSTRAINTS SOCIO-ECONOMIC Flora: Fauna: Agricultural Potential: Heritage: Visual: PUBLIC PARTICIPATION PROCESS TO DATE ASSUMPTIONS & LIMITATIONS PLAN OF STUDY FOR ENVIRONMENTAL IMPACT REPORT Criteria for Specialist Assessment of Impacts Brief for Specialist Studies to be Undertaken as Part of the EIA TERMS OF REFERENCE FOR SPECIALIST STUDIES PROCESS TO BE FOLLOWED CONCLUSION & RECOMMENDATIONS REFERENCES FIGURES Figure 1: Solar radiation map of South Africa... 3 Figure 2: Flow diagram for Scoping & EIA Process... 5 Figure 3: Vegetation type and Ecosystem Status for Richtersveld Solar Farm... 7 Figure 4: Map indicating proximity of solar site to known watercourses as per National Freshwater Ecosystem Priority Areas Figure 5: Proposed solar facility with associated infrastructure ito NPAES Figure 6: Map showing project in relation to CBA and ESA areas Figure 7: A typical layout of the components of a solar facility Figure 8: Typical overveiw of solar power generation facility Figure 9: Showing typical examples of PV (left) and CPV (right) foundation footprints Figure 10: Typical example of on-site substation and transformer Figure 11: Examples or typical cable trenching used to connect the panels to the on-site substation Figure 12: Showing typical examples of site preparation during the construction phase of a solar project Cape EAPrac Draft Scoping Report

9 RIC277/05 Figure 13: Showing typical erection of panels during the construction phase Figure 14: Showing typical example of on-site substation Figure 15: Area on the bank of the Orange river where abstrction is being considered showing sparse vegetation and rock banks within the flood line Figure 16: Images indicate the track(s) running from the Beesbank substation to the study site. Disturbance along these tracks is notable as it appears between one and three tracks follow the same route Figure 17: Existing borehole situated (off-site) east of the solar site Figure 18: The Oranjemund Substation (left) has sufficient capacity to absorb the electricity generated by the proposed project. The proposed 132kV line will run alongside the 66kV (right) line connecting to the substation Figure 19: Soil land use map for RE for Portion 10 of Farm Korridor Wes No Figure 20: Broad-scale overview of the vegetation in and around the Richtersveld Solar Farm (Todd, 2014) Figure 21: Critical Biodiversity Areas indicated for the study area Figure 22: The character of the site is unfragmented and situate in the flatlands Figure 23: Location of site in context to the Richtersveld Natural and Cultural landscapes Figure 24: Location of the site in context to Richtersveld World Heritage Site and its buffer areas (note that the site falls outside of the core and buffer areas) Figure 25: A Nama stock post close to the study area Figure 26: The palaeontological sensitivity map produced by SAHRA indicates that the study area lies in the dark blue zone which has very low palaetontological sensitivity (Townsend 2014) Figure 27: Viewshed analysis for the proposed solar facility with associated infrastructure Figure 28: Proof of notifications placed at the Port Nolloth Library (left) and Richtersveld Municipal office (right) TABLES Table 2: NEMA 2010 listed activities for the Richtersveld Solar Farm... 5 Table 3: Showing typical data associated with the RE of Portion 10 Farm Korridor Wes No Table 4: Vegetation types that occur within or near the site with their basic conservation statics and status according to the National List of Threatened Ecosystems (2011), Todd Table 5: Summary of the conservation status of plant species known from the two quarter degree squares affected by the development Table 6: Veld condition assessment outcome of the study site Table 7: Overview of process followed to date Cape EAPrac Draft Scoping Report

10 1 PROJECT OVERVIEW REPORT SUMMARY Cape EAPrac has been appointed by Richtersveld Sunspot (Pty) Ltd, hereafter referred to as the Applicant, as the independent Environmental Assessment Practitioner EAP), to facilitate the Scoping & Environmental Impact Reporting (S&EIR) process required in terms of the National Environmental Management Act (NEMA, Act 107 of 1998) for the proposed east of Alexander Bay in the Northern Cape, Namakwaland District (Richtersveld Municipal area). Amongst others this project requires the owner of the property, Richtersveld Sida!Hub Communal Property Association (CPA) to sub-lease a portion of Remainder of Portion 10 (Arris) of the Farm Korridor Wes No.2 for the purposes of developing the proposed solar facility. The total generation capacity of the solar facility will not exceed 75MW for input into the national Eskom grid via a new 132kV power line that must connect to the grid at the existing Oranjemund Substation situated west of the study site 1. In terms of Regulation 56(6) of NEMA registered I&APs must be presented the opportunity to review submit comments on all relevant environmental reports directly to the Environmental Assessment Practitioner (EAP). Thus, should you have any comments on this Draft Scoping Report please submit these within the 40-day comment period, extending from Friday, 29 August 2014 to Friday, 10 October Cape EAPrac ATTN: Louise-Mari van Zyl PO Box 2070, George, 6530 Tel: Fax: louise@cape-eaprac.co.za with specific mention of the project reference number: 14/12/16/3/3/2/624. All comments and/or queries received will be responded to by the EAP, as well as reflected in the Final Scoping Report (FSR) that will be made available for further review and comment for a period of 21-day days following the closing of the 40-day comment period on this Draft Scoping Report. 2 NEED AND DESIRABILITY The supply of electricity in South Africa has become constrained, primarily because of insufficient generation capacity, but also due to constraints on the transmission and distribution of electricity. Considering this situation and the impact that carbon emissions from existing (and future) coal-fired power stations have on the environment (Climate Change), this renewable energy project will contribute to the generation of clean or so-called green renewable electricity for input into the national grid to augment Eskom s power supply. In order to meet the increasing power demand within South Africa, Eskom has set a target of 30% of all new power generation to be derived from independent power producers (IPPs). 1 Despite the name of this substation it must be noted that it is situated south of the Orange River within South African borders. Cape EAPrac i Draft Scoping Report

11 Richtersveld Sunspot (Pty) Ltd is one such IPP which intends to generate electricity from the proposed. This will contribute to South Africa s commitment to the Convention on Climate Change through emission-free generation of electricity and working towards an investor-friendly climate in the energy sector. The study site falls within an area with high solar radiation which makes it ideal for investigating a renewable energy solar facility. Similarly the area has a well-established electrical grid system, with capacity at an existing substation which enables a project of this nature to be considered in the area. 3 ENVIRONMENTAL REQUIREMENTS The proposed solar energy facility project is subject to the requirements of the Environmental Impact Assessment Regulations (2010 EIA Regulations) in terms of the National Environmental Management Act (NEMA, Act 107 of 1998, as amended) This Act makes provision for the identification and assessment of activities that are potentially detrimental to the environment and which require authorisation from the competent authority (in this case, the National Department of Environmental Affairs, DEA) based on the findings of an Environmental Impact Assessment (EIA). An application for authorisation has been accepted by the DEA 2 (under the Application Reference number 14/12/16/3/3/2/538). A Scoping and Environmental Impact Assessment process is required in terms of NEMA, The listed activities associated with the proposed development, as stipulation under Regulations 544, 545 and 546, where applied for as follows: Regulation 544 (Basic Assessment): 10(i), 11 (xi), & 22(ii) Regulation 545 (Scoping & EIA): 1, 15 and Regulation 546 (Basic Assessment): 4(aa & gg), 13 (aa & gg), 16 (iv)(hh), 19(gg) Before any of the above mentioned listed activities may be undertaken, authorisation must be obtained from the relevant authority, in this case, the National Department of Environmental Affairs (DEA). Together with the formal Application the Applicant applied for deviation from the following specifications ito Regulation 543 ito public participation: fixing a notice board at a place conspicuous to the public at the property boundary, or on the fence of the site where the activity is to be undertaken (the study area is very remote and site notices are unlikely to attract the attention of travellers, as an alternative notices were placed at the Port Nolloth Library and Port Nolloth Municipal offices which are both frequented by local residents); giving written notice to the occupiers of the site or any alternative sites (the site is not permanently occupied although members of the CPA do frequent the greater area as nomadic small stock farmers the CPA is a beneficiary of this project and its members are informed of the project); giving written notice to the owners and occupiers of land adjacent to the site (with the exception of one property to the west), the study site is surrounded by cadastral units in all 2 The Applicant s application to downscale from a Full Scoping & Impact Assessment process to a Basic Assessment process was rejected by the DEA, thus a Full Scoping & Impact Assessment process is being followed. Cape EAPrac ii Draft Scoping Report

12 directions also belonging to the CPA thus it is considered excessive giving notice to neighbouring land owners/occupiers); placing and advert in any official Gazette or at least two Provincial Newspapers or National Newspapers (the project is unlikely to impact beyond the immediate environment, thus putting notices in newspapers focussing at provincial or national level (i.e. not on the immediate environment is considered unnecessary. The project was however advertised in the local newspaper. 5 SITE DESCRIPTION The property on which the solar facility is proposed, Remainder of Portion 10 (Arris) of the Farm Korridor Wes No. 2, is located in the Namakwaland District, part of the Northern Cape Province, within the jurisdictional area of the Richtersveld Local Municipality. The property is located approximately 28.4km east of the town of Alexander Bay, 8.3km south of the Orange River. The existing access also runs across this property ha (Twelve Thousand Two Hundred C and Seventeen comma nine five two five) 3 The connecting overhead powerline (132kV) that is required to link this solar facility to the existing Oranjemund Substation situated to the West, crosses two additional properties namely, Portion 9 of the Farm Korridor Wes No.2 as well as the Remainder of Farm Groot Derm No ha (Thirteen Thousand Nine Hundred and Seventy Eight) ha (Sixteen Thousand Two Hundred and Four comma nil one eight two) C C DEVELOPMENT PROPOSAL & ALTERNATIVES The Applicant s preferred development alternative involves the development of a 75MW Concentrated Photovoltaic (CPV)/Hybrid Solar plant covering an area not exceeding 200ha. The plant will most likely consist of trackers which are designed to track or follow the path of the sun to optimise solar exposure. Individual tracker units consist of the following components: A foundation which anchors the mast to the ground (likely to be buried concrete foundations or anchored piles); A mast, which supports the photovoltaic modules; A photovoltaic tracker table, which consist of an integrated array of CPV modules mounted side by side to form a table / panel; and A mechanical tracking device, which ensures that the panels is optimally aligned to the sun throughout the course of any given day. In addition to the trackers, the solar facility also includes the following within the 200ha footprint: 3 As per Title Deed. Cape EAPrac iii Draft Scoping Report

13 On-site substation(s); Auxiliary buildings (administration / security, workshop, storage and ablution); Inverters, transformers and internal electrical reticulation (underground cabling); Internal road network; Rainwater tanks; and Perimeter fencing. Off-site infrastructure includes: Overhead electrical transmission line (to connect to connect to the existing Oranjemund substation); and Existing access roads to the facility and service track along the overhead transmissions line (for maintenance purposes). Various alternatives, in terms of sites (for the overhead transmission line), technology of the solar arrays, as well as layout for the solar arrays and associated infrastructure on the development site, have been considered. The alternatives are described in detail in section 4 of this report. In the event that the scoping/impact assessment process identify any other feasible/reasonable alternatives other than the above, such will be considered and incorporated as additional alternatives. 7 SPECIALIST STUDIES The following aspects have been considered by specialists in order determine the current status of the target development site, as well as to identify potential risks and impacts associated with the development of the renewable energy park. These are described in greater detail in the main report, while the full specialist reports are available in Appendix D. The following baseline specialist studies have been undertaken and used to inform this Draft Scoping Report as well as the project layout and concept: Agriculture potential; Biophysical (Fauna and Flora); Heritage (including archaeology and palaeontology); Visual Socio-Economic conditions Planning requirements Although the various baseline studies undertaken to date have not highlighted any fatal flaws or constraints that are unlikely to be mitigated, the various issues and concerns identified through the baseline studies will be further investigated and assessed through detailed specialist impact assessments to follow in the Environmental Impact Reporting (EIR) phase in order to determine the significance of potential impacts possibly associated with the proposed project. 8 PLANNING CONTEXT The following documents establish the legal framework within which planning for the relevant study site must be considered: The Northern Cape Planning & Development Act 7 of 1998 Cape EAPrac iv Draft Scoping Report

14 The Land Use Planning Ordinance 15 of 1985 Existing Zoning in terms of Section 8 of LUPO The National Building Regulations and Buildings Standards Act Title Deed Conditions and Servitudes In addition, the following specific spatial planning tools are applicable to this project and where relevant the Applicant must apply for the necessary approvals / permits / amendments to allow the proposed development to be considered compatible with the relevant planning requirements: The Northern Cape Provincial Spatial Development Framework (2012) in which renewable energy supply schemes are being promoted; The Namakwa District Spatial Development Framework (2012) in which it is confirmed that the District receives the second most solar radiation in the country, thus there is significant potential for renewable energy projects to contribute to the human and economic development of the area; and The Richtersveld Municipal Spatial Development Framework (2010), although this document contains no specific information pertinent to the development of renewable energy projects, it will be consulted. According to Dave Saunders Urban & Rural Planning (2014) the proposed project appears to be consistent with the majority of spatial planning tools that govern and regulate the type of development that should be considered for the area. Please refer to Appendix D7 for a copy of the Planning Report. 10 PROCESS TO DATE As part of their pre-feasibility investigation the Applicant conducted a series of meetings that involved affected communities (mostly associated with the CPA) to inform them of the proposed project and help affected parties understand how a solar facility operates and what impacts it may have on people residing and living off the land. Although these meetings and consultation sessions was not part of the formal EIA process they are recognised as public participation and the full support admitted by these affected community is noted. As part of their pre-feasibility investigation the Applicant consulted directly with the local affected communities by presenting to them the project proposal. The project was received positively and there is general support amongst the groups the Applicant met with that the project should be implemented to ensure the much needed social and economic spin-off(s) to the Sida!HUB community. As part of the official stakeholder engagement process the following steps were taken to ensure compliance with the legislation and to allow opportunity for members of the public and key stakeholders to be involved and participate in the environmental process. Please see Appendix E for evidence of this Public Participation process. The Stakeholder Engagement Process has been undertaken according to the requirements of the new NEMA EIA regulations. The following requirements i.t.o the scoping process have been undertaken and complied with in terms of Regulation 56: Cape EAPrac v Draft Scoping Report

15 Table 1: Chronology of Events for Process CHRONOLOGY OF EVENTS DATE ACTION Consultation with local community by Applicant (prior to EIA process) 12 June June June July July 2013 Notifications of Road Show meetings in each town. Road Show with presentations (including posters and basic information flyers) at Lekkersing, Ecksteenfontein, Kuboes, Sanddrift and Alexander Bay. Sida!HUB Communal Property Association Committee presents the project at their Annual General Meeting on 29 June 2013 and it is recorded that the necessary lease agreements be consented to in terms of Section 12 of the Communal Property Association Act 28 of The Resolution for the CPA to enter into a lease and option agreement signed by all CPA committee members Lease and Option agreement signed by the Chairman of the CPA and the Directors of the Richtersveld Sunspot (Pty) Ltd FORMAL STAKEHOLDER ENGAGEMENT AS PART OF EIA PROCESS 11 December 2013 January February May June June July July 2014 Notification was sent to the Richtersveld Sida!Hub Communal Property Association (CPA) informing them, as landowner, of the Applicant s intent to undertake an EIA process for the proposed. Identify key stakeholders that may have an interest, or be affected by the proposed development and add their details to the Stakeholder Register. Newspaper advert appears in Die Plattelander local newspaper informing the public of the proposed project, the process to be followed, calling on I&APs to register and informing of deviations applied for. Notice Boards were placed at the Port Nolloth Municipal office and Port Nolloth Public Library. A Background Information Document (BID) is distributed to members on the Stakeholder Register informing of the project and process to be followed, requesting preliminary comment and confirmation of registration as Interested & Affected Parties (I&APs). Meeting with representatives from the Richtersveld Local Municipality to ascertain process requirements and note any issues/concerns they may have regarding the project. Meeting with the Northern Cape Provincial Department of Environmental Affairs to ascertain process requirements and note any issues/concerns they may have regarding the project. Registered I&APs appearing on the Stakeholder Register will receive notifications of the availability of this Draft Scoping Report (DSR). The comment period on the DSR is 40-day to be followed by a further 21-day comment period on the Final Scoping Report (FSR). Cape EAPrac vi Draft Scoping Report

16 11 CONCLUSIONS & RECOMMENDATIONS This scoping exercise is currently being undertaken to present concept proposals to the public and potential Interested & Affected Parties and to identify environmental issues and concerns raised as a result of the proposed development alternatives to date. This will allow Interested & Affected Parties (I&APs), authorities, the project team, as well as specialists to provide input and raise issues and concerns, based on baseline / scoping studies undertaken. The development site has been analysed from an Ecological, Agricultural Potential, Heritage, Archaeological, Paleontological, Visual and Mobility perspective. This DSR summarises the process to date, reports on the findings of relevant baseline studies. Cape EAPrac is of the opinion that the information contained in this Draft Scoping Report, Plan of Study for EIR and the documentation attached hereto is sufficient to allow the general public and key stakeholders to apply their minds to the potential negative and/or positive impacts associated with the development, in respect of the activities applied for. In terms of Regulation 56(6) of NEMA registered I&APs must submit comments to the EAP responsible for facilitating the EIA process. All comments must be submitted in writing to the below contact person to reach Cape EAPrac no later than 10 October Cape EAPrac ATTN: Mrs Louise-Mari van Zyl P.O. Box 2070, George, 6530 Tel: ; Fax: louise@cape-eaprac.co.za Cape EAPrac vii Draft Scoping Report

17 1 INTRODUCTION DRAFT SCOPING MAIN REPORT Cape EAPrac has been appointed by Richtersveld Sunspot (Pty) Ltd, hereafter referred to as the Applicant, as the independent Environmental Assessment Practitioner EAP), to facilitate the Scoping & Environmental Impact Reporting (S&EIR) process required in terms of the National Environmental Management Act (NEMA, Act 107 of 1998) for the proposed development of the near Alexander Bay in the Northern Cape Province. Richtersveld Sunspot (Pty) Ltd has entered into an agreement with the land owner (Richtersveld Sida!Hub Communal Property Association 4 ) allowing it to utilise 200ha of the Remainder of Portion 10 (Arris) of the Farm Korridor Wes No. 2 (Namakwa District). A copy of the CPAs letter confirming this is included in Appendix G. The total generation capacity of the solar facility will not exceed 75MW for input into the national Eskom grid via a new 132kV overhead transmission line that will feed into the existing Oranjemund Substation. The purpose of this Draft Scoping Report is to describe the environment to be affected, the proposed project, the process followed to date (focussing on the outcome of the initial public participation process and baseline specialist studies), to present the site constraints identified by the various specialist during their initial site assessments, and provide Plan of Study for the Impact Assessment phase of this development. In terms of Regulation 56(6) of NEMA registered I&APs must submit comments on the all relevant reports directly to the Environmental Assessment Practitioner (EAP). Thus, should you have any additional comments on the Draft Scoping Report please submit these within the 40-day comment period, extending from Friday, 29 August 2014 to Friday, 10 October OVERVIEW OF ALTERNATIVE ENERGY IN SOUTH AFRICA AND THE NORTHERN CAPE South Africa has for several years been experiencing considerable constraints in the availability and stability of electrical supply. Load shedding procedures have been applied since December 2005 due to multi-technical failures, as well as capacity and transmission constraints. Eskom generates about 95% of South Africa s electricity supply, and has undertaken to increase capacity to meet growing demands. At the moment, the country s power stations are 90% coalfired, and two huge new facilities are being built to add to this capacity. However, Eskom s plans to increase its national capacity by megawatts in the period to 2025 have had to be scaled down due to the global economic recession (Northern Cape Business website). International best-practice requires a 15% electricity reserve margin to deal with routine maintenance requirements and unexpected shutdowns in electricity supply systems. South Africa has historically enjoyed a large reserve margin (25% in 2002, 20% in 2004 and 16% in 2006), but that has declined over the recent past to 8% - 10%, as a result of robust economic growth, the associated demand for and a lack of maintenance of upgrade of facilities The spare power available to provide supply at any time of the day is known as the reserve capacity and the spare plant available when the highest demand of the year is recorded is known 4 Sida!Hub translates to Our Land. Cape EAPrac 1 Draft Scoping Report

18 as the reserve margin (National Response to South Africa s Electricity Shortage, 2008). This has resulted in limited opportunities for maintenance and necessitated that power stations are run harder. This results in station equipment becoming highly stressed and an increase in unplanned outages and generator trips. The expected demand growth will rapidly erode this margin, as well as Eskom s ability to recover after it s already stressed systems shutdown. This necessitates the additional generation of at least 3 000MW in the shortest possible time, to allow the reserve necessary to bring Eskom s system back into balance (bid). This need can either be addressed from the supply or the demand side. Where the demand side interventions include short, medium and long term aspects of a national Power Conservation Programme to incentivise the public to use less electricity (as mentioned above), one of the supply side options (besides Eskom building new plants and returning old plants to service) is to allow Independent Power Producers (IPPs) to contribute electricity to the national grid (National Response Document, 2008). Richtersveld Sunspot (Pty) Ltd is one such body, which intends generating electricity from a renewable energy resource, namely solar. In March 2011, the Cabinet approved South Africa's Integrated Resource Plan 2010, in terms of which energy from renewable sources will be expected to make up a substantial 42% of all new electricity generation in the country over the next 20 years. The government's New Growth Path for the economy also envisages up to jobs being created in the "green" economy by 2020 (South Africa info website). The Northern Cape is suggested by many to be the ideal location for various forms of alternative energy. This has resulted in a number of feasibility studies being conducted, not least of which an investigation by the Industrial Development Corporation in 2010 (R33-million spent) into potential for photo-voltaic, thermal, solar and wind power (Northern Cape Business website). The area of the Northern Cape that borders on the Gariep (Orange) River and Namibia boasts the highest solar radiation intensity anywhere in southern Africa. Solar energy is therefore likely to be the most viable alternative energy source for the Northern Cape, although wind-power potential is generally good along the coast (State of the Environment, S.A.) Cape EAPrac 2 Draft Scoping Report

19 Figure 1: Solar radiation map of South Africa The Northern Cape area is considered to have extremely favourable solar radiation levels over the majority of the year, making it ideal for the production of solar-power via Photovoltaic (fixed and tracking panels) and Concentrated (solar thermal) Solar systems. Several solar irradiation maps have been produced for South Africa, all of which indicate that the Northern Cape area has high solar radiation levels. A solar-investment conference was held in November 2010 at Upington and was attended by 400 delegates from all over the world. Dipuo Peters, the national Minister of Energy, outlined the competitive advantages of the Northern Cape, over and above its extremely high irradiation levels, amongst others: relative closeness to the national power grid compared to other areas with comparable sunshine; water from the Orange River; access to various airports; and good major roads and a flat landscape (Northern Cape Business website solar power). The Northern Cape is not too dusty, the land is flat and sparsely populated, and there are little to no geological or climate risks, meaning that the sun can be used year-round (BuaNews online). A Cape EAPrac 3 Draft Scoping Report

20 Clinton Climate Initiative (CCI) pre-feasibility study has found that South Africa has one of the best solar resources on the planet (Northern Cape Business website solar power). The Applicant has indicated that the site is considered ideal, primarily due to: The flat topography of the proposed development site and it s the availability for use for an alternative energy generation facility; The grid connection potential based in proximity to existing transmission and substation with sufficient spare capacity to absorb the electricity supplied by the Plant; and Isolation of the site which increases the security level and limits the exposure to visual receptors. 2 LEGISLATIVE AND POLICY FRAMEWORK The legislation relevant to this study is briefly outlined below ( ). These environmental requirements are not intended to be definitive or exhaustive, but serve to highlight key environmental legislation and responsibilities only. 2.1 THE CONSTITUTION OF THE REPUBLIC OF SOUTH AFRICA The Constitution of the Republic of South Africa (Act 108 of 1996) states that everyone has a right to a non-threatening environment and that reasonable measure are applied to protect the environment. This includes preventing pollution and promoting conservation and environmentally sustainable development, while promoting justifiable social and economic development. 2.2 NATIONAL ENVIRONMENTAL MANAGEMENT ACT (NEMA) The current assessment is being undertaken in terms of the National Environmental Management Act (NEMA, Act 107 of 1998) 5. This Act makes provision for the identification and assessment of activities that are potentially detrimental to the environment and which require authorisation from the competent authority (in this case, the national Department of Environmental Affairs, DEA) based on the findings of an Environmental Assessment. The proposed scheme entails a number of listed activities, which require a Scoping & Environmental Impact Reporting (S&EIR) process, which must be conducted by an independent environmental assessment practitioner (EAP). Figure 2 depicts a summary of the S&EIR process. 5 On 18 June 2010 the Minister of Water and Environmental Affairs promulgated new regulations in terms of Chapter 5 of the National Environmental Management Act (NEMA, Act 107 of 1998), viz, the Environmental Impact Assessment (EIA) Regulations These regulations came into effect on 02 August 2010 and replace the EIA regulations promulgated in Cape EAPrac 4 Draft Scoping Report

21 Figure 2: Flow diagram for Scoping & EIA Process The listed activities associated with the proposed development, as stipulation under 2010 Regulations 544, 545 & 546 are as follows: Table 2: NEMA 2010 listed activities for the Richtersveld Solar Farm e.g. 544, 18 1(a) Construction of a 600 mw generator June 2010 R The construction of facilities or infrastructure for the transmission and distribution of electricity (i) outside urban areas or industrial complexes with a capacity of more than 33kV but less than 275kV. 132kV overhead line connecting the proposed solar plant to existing Oranjemund substation. R545 1 The construction of facilities or infrastructure for the generation of electricity where the electricity output is 20MW or more. Construction of a solar facility with an electricity generation capacity of 75MW. R Physical alteration of undeveloped, vacant or derelict land for commercial use where the total area to be transformed is 20ha or more. Study area for the proposed solar plant approximately is an estimated 200ha excluding external linear services which include the overhead power line, water pipeline and access road(s). R546 4 The construction of a road wider than 4m with a reserve less than 13m - outside urban areas, in (aa) a protected area identified ito NEMPAA; (gg) areas within 10km from a World Heritage Site. Construction of access road and internal service tracks within the development footprint area. The study site is located approximately 14km West of the closest point of the Richtersveld World Heritage Site (WHS) and the Richtersveld Community Conservancy. R The clearance of an area of 1ha or more of vegetation where 75% or more of the vegetative cover constitutes indigenous vegetation outside urban areas in (aa) a protected area identified in terms of NEMPAA, (gg) areas within 10km from a World Heritage Site. Cape EAPrac 5 Draft Scoping Report

22 The study site is located approximately 14km West of the closest point of the Richtersveld World Heritage Site (WHS) and the Richtersveld Community Conservancy. R The clearance of an area of 5ha or more of vegetation where 75% or more of the vegetative cover constitutes indigenous vegetation outside urban areas. The development will result in the removal of indigenous vegetation to provide for the solar facility, access roads and overhead power line. R The widening of a road by more than 4m, or the lengthening of a road by more than 1km in all areas outside urban areas. Potential upgrade and widening of the existing jeep tracks that allows access to the site. Before any of the above mentioned listed activities can be undertaken, authorisation must be obtained from the relevant authority, in this case the National Department of Environmental Affairs (DEA). Should the Department approve the proposed activity, the Environmental Authorisation does not exclude the need for obtaining relevant approvals from other Authorities who has a legal mandate. 2.3 NATIONAL ENVIRONMENTAL MANAGEMENT: BIODIVERSITY (ACT 10 OF 2004) The National Environmental Management: Biodiversity Act (Act 10 of 2004) (NEMBA) provides for listing threatened or protected ecosystems, in one of four categories: critically endangered (CR), endangered (EN), vulnerable (VU) or protected. The Draft National List of Threatened Ecosystems (Notice 1477 of 2009, Government Gazette No 32689, 6 November 2009) has been gazetted for public comment. The list of threatened terrestrial ecosystems supersedes the information regarding terrestrial ecosystem status in the NSBA NEMBA also deals with endangered, threatened and otherwise controlled species. The Act provides for listing of species as threatened or protected, under one of the following categories: Critically Endangered: any indigenous species facing an extremely high risk of extinction in the wild in the immediate future. Endangered: any indigenous species facing a high risk of extinction in the wild in the near future, although it is not a critically endangered species. Vulnerable: any indigenous species facing an extremely high risk of extinction in the wild in the medium-term future; although it is not a critically endangered species or an endangered species. Protected species: any species which is of such high conservation value or national importance that it requires national protection. Species listed in this category include, among others, species listed in terms of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). Certain activities, known as Restricted Activities, are regulated by a set of permit regulations published under the Act. These activities may not proceed without environmental authorization. According to the national SANBI BGIS data of 2012 (based on the vegetation map of Mucina & Rutherford 2006), the different components of the project fall within the following vegetation types: The solar site itself lies within a single distinct vegetation types namely Upper Annisvlakte Succulent Shrubland which is considered Least Threatened; Cape EAPrac 6 Draft Scoping Report

23 90% of the new 132kV powerline runs through Richtersveld Red Duneveld also with a Least Threatened conservation status. The remaining 10% runs through Upper Annisvlakte Succulent Shrubland which is considered Least Threatened; The main access road which follows existing jeep tracks is mostly situated within Richtersveld Red Duneveld (Least Threatened), with only the very last portion approaching the solar site running through Upper Annisvlakte Succulent Shrubland (also Leaste Threatened). Figure 3: Vegetation type and Ecosystem Status for Richtersveld Solar Farm 2.4 NATIONAL FORESTS ACT (NO. 84 OF 1998): The National Forests Act provides for the protection of forests as well as specific tree species, quoting directly from the Act: no person may cut, disturb, damage or destroy any protected tree or possess, collect, remove, transport, export, purchase, sell, donate or in any other manner acquire or dispose of any protected tree or any forest product derived from a protected tree, except under a licence or exemption granted by the Minister to an applicant and subject to such period and conditions as may be stipulated. To date no protected tree species have been identified within the proposed Richtersveld Solar Farm development area. The biodiversity specialist will provide further confirmation this during the Environmental Impact Assessment Phase of the project. Please refer to the Ecological Scoping Report in Appendix D, Annexure D1 for a detailed description of the plant species found to occur in the area. Cape EAPrac 7 Draft Scoping Report

24 The Department of Agriculture, Forestry and Fisheries (DAFF) was registered as a key stakeholder on this environmental process and will be given an opportunity to comment on this DSR At the stage of publishing this DSR, comment had not been received from DAFF forestry directorate. 2.5 CONSERVATION OF AGRICULTURAL RESOURCES ACT CARA (ACT 43 OF 1983): CARA provides for the regulation of control over the utilisation of the natural agricultural resources in order to promote the conservation of soil, water and vegetation and provides for combating weeds and invader plant species. The Conservation of Agricultural Resources Act defines different categories of alien plants: Category 1 - prohibited and must be controlled; Category 2 must be grown within a demarcated area under permit; and Category 3 - ornamental plants that may no longer be planted, but existing plants may remain provided that all reasonable steps are taken to prevent the spreading thereof, except within the flood lines of water courses and wetlands. The abundance of alien plant species on the Richtersveld Solar Farm site is very low, which can be ascribed mostly to the aridity of the site. 2.6 NORTHERN CAPE NATURE CONSERVATION ACT, NO. 9 OF 2009: The Northern Cape Nature Conservation Act provides inter alia for the sustainable utilisation of wild animals, aquatic biota and plants as well as permitting and trade regulations regarding wild fauna and flora within the province. In terms of this act the following section may be relevant with regards to any security fencing the solar development may require. Manipulation of boundary fences: 19. No Person may (a) erect, alter, remove or partly remove or cause to be erected, altered, removed or partly removed, any fence, whether on a common boundary or on such person s own property, in such a manner that any wild animal which as a result thereof gains access or may gain access to the property or a camp on the property, cannot escape or is likely not to be able to escape therefrom. It is recommended that the perimeter fencing around the solar development site must be constructed in a manner which allows for the passage of small and medium sized mammals. The biodiversity specialist will make recommendations with regard to the specific fencing configuration during the EIA phase of this project. Further detailed of protected species on site will be provided in the EIA phase of the project. The Northern Cape Department of Environmental Affairs and Nature conservation is registered as a key stakeholder on this process and will be given an opportunity to comment on the DSR. 2.7 NATURE AND ENVIRONMENTAL CONSERVATION ORDINANCE (19 OF 1974) This legislation was developed to protect both animal and plant species within the various provinces of the country which warrant protection. These may be species which are under threat or which are already considered to be endangered. The provincial environmental authorities are responsible for implementing the provisions of this legislation, which includes the issuing of permits etc. In the Northern Cape, the Department of Environment and Nature Conservation fulfils this mandate. The Northern Cape Department of Environmental Affairs and Nature conservation is registered as a key stakeholder on this process and will be given an opportunity to comment on the DSR. Cape EAPrac 8 Draft Scoping Report

25 2.8 NATIONAL HERITAGE RESOURCES ACT The protection and management of South Africa s heritage resources are controlled by the National Heritage Resources Act (Act No. 25 of 1999). South African National Heritage Resources Agency (SAHRA) is the enforcing authority in the Northern Cape, and is registered as a Stakeholder for this environmental process. In terms of Section 38 of the National Heritage Resources Act, SAHRA will comment on the detailed Heritage Impact Assessment (HIA) where certain categories of development are proposed. Section 38(8) also makes provision for the assessment of heritage impacts as part of an EIA process. The National Heritage Resources Act requires relevant authorities to be notified regarding this proposed development, as the following activities are relevant: the construction of a road, wall, power line, pipeline, canal or other similar form of linear development or barrier exceeding 300m in length; any development or other activity which will change the character of a site exceeding m² in extent; the re-zoning of a site exceeding m ² in extent. Furthermore, in terms of Section 34(1), no person may alter or demolish any structure or part of a structure, which is older than 60 years without a permit issued by the SAHRA, or the responsible resources authority. Nor may anyone destroy, damage, alter, exhume or remove from its original position, or otherwise disturb, any grave or burial ground older than 60 years, which is situated outside a formal cemetery administered by a local authority, without a permit issued by the SAHRA, or a provincial heritage authority, in terms of Section 36 (3). In terms of Section 35 (4), no person may destroy, damage, excavate, alter or remove from its original position, or collect, any archaeological material or object, without a permit issued by the SAHRA, or the responsible resources authority. Given the proximity of this site to the Richtersveld World Heritage Site, as well as the historic land use of the property being used by migration herders the following investigations will have to be undertaken: A full Heritage Impact Assessment, consisting of an Archaeological and Paleontological input, must be compiled for this application. The archaeological component will identify archaeological sites and assess their significance. It should also make recommendations (as indicated in section 38 of the NHRA) about the process to be followed. For example, there may need to be a mitigation phase (Phase 2) where the specialist will collect or excavate material and date the site if any sites of significance are found. The paleontological overview must be undertaken to assess whether or not the development will impact upon paleontological resources - or at least a letter from a Palaeontologist motivating for an exemption is needed to indicate that this is unnecessary. 2.9 NATIONAL WATER ACT, NO 36 OF 1998 Section 21c & i of the National Water Act (NWA) requires the Applicant to apply for authorisation from the Department of Water Affairs for an activity in, or in proximity to any watercourse. Based on the information available at this stage in the process the solar facility itself does not impact on Cape EAPrac 9 Draft Scoping Report

26 any watercourses. The impact assessment phase will determine whether external services i.e. the access road or overhead power line may run in proximity to watercourses and whether or not such features are likely to require Water Use License Applications (WULAs). The Applicant has two alternatives for water required for the construction and operation of the Richtersveld Solar Farm, the one being abstraction directly from the Orange River, or transferring existing water use rights from other cadastral properties to the Remainder of Portion 10. Although the property contains an existing borehole (close to the study site), it appears this hole may be dry, hence it is unlikely that water for construction and operation will be sourced from this borehole. Depending on the preferred source an Application will be submitted to the Northern Cape Department of Water Affairs (DWA) for abstraction of water from the Orange River or to transfer existing water use rights. In meeting with the Provincial Department of Environmental Affairs, it was pointed out that additional abstraction from the Orange River is unlikely to be supported, thus further discussions with the Department of Water Affairs are necessary to determine whether water rights may be transferred from other properties owned by the CPA. According to the National Freshwater Ecosystem Priority Areas (NFEPA) the closest drainage line (watercourse) is the Orange River (approximately 8.3km from the bank of the river to the centre point of the solar site) and a tributary to the North (roughly 2km from the access road and 1.4km from the solar site). Based on the information available, the proposed project will not affect any watercourses. Please refer to Figure 4 showing the location of identified watercourses in relation to the project. Cape EAPrac 10 Draft Scoping Report

27 Figure 4: Map indicating proximity of solar site to known watercourses as per National Freshwater Ecosystem Priority Areas The following sections 2.10 and 2.11 consider relevant policy that is applicable to the proposed Richtersveld Solar Farm proposal NATIONAL PROTECTED AREA EXPANSION STRATEGY (NPAES) FOR S.A (2010) Considering that South Africa s protected area network currently falls far short of sustaining biodiversity and ecological processes, the NPEAS aims to achieve cost-effective protected area expansion for ecological sustainability and increased resilience to Climate Change. Protected areas, recognised by the National Environmental Management: Protected Areas Act (Act 57 of 2003), are considered formal protected areas in the NPAES. The NPAES sets targets for expansion of these protected areas, provides maps of the most important protected area expansion, and makes recommendations on mechanisms for protected area expansion. The NPAES identifies 42 focus areas for land-based protected area expansion in South Africa. These are large intact and un-fragmented areas suitable for the creation or expansion of large protected areas. With the exception of a portion of the existing access track (+/- 30%) and approximately 40% of the proposed new 132kV powerline, the solar site in its entirety falls within one of the NPEAS Focus Areas. Cape EAPrac 11 Draft Scoping Report

28 Figure 5: Proposed solar facility with associated infrastructure ito NPAES As can be seen from Figure 5 the proposed Richtersveld Solar Farm project will impact on the NPAES focus area and the significance of introducing this project in this particular area must be investigated and reported on during the impact assessment phase of this EIA process NAMAQUA DISTRICT BIODIVERSITY SECTOR PLAN, Biodiversity sector plans are intended to help guide land-use planning, environmental assessments and authorisations; and, natural resource management in order to promote development which occurs in a sustainable manner. The Namaqua District Biodiversity Sector Plan was developed to further the awareness of the unique biodiversity in the area, the value this bio diversity represents to people as well as the management mechanisms that can ensure its protection and sustainable utilisation. The biodiversity profile information from this plan has been incorporated into the environmental planning section of the Spatial Development Frameworks (SDF's) for each of the six local municipalities in the district. The Namaqua District Critical Biodiversity Areas (CBA) has been mapped to include the Richtersveld Municipal area including the study site: The study site falls within an area designated as an Ecological Support Area (ESA) which is due to it being classified as a terrestrial migration corridor. 50% of the existing access track falls within a type 2 Critical Biodiversity Area (CBA) and the other half within an Ecological Support Area (ESA); The majority of the proposed new 132kV powerline crosses a type 2 Critical Biodiversity Area (CBA). Cape EAPrac 12 Draft Scoping Report

29 Level 2 CBA s are designated to near-natural landscapes including: Ecosystems and species largely intact and undisturbed, Areas with intermediate irreplaceability or some flexibility in terms of area required to meet biodiversity targets. There are options for loss of some components of biodiversity in these landscapes without compromising our ability to achieve targets, and These are landscapes that are approaching but have not passed their limits of acceptable change. Figure 6: Map showing project in relation to CBA and ESA areas. The proposed Richtersveld Solar Farm will impact on both the ESA and CBA areas and it is important to note that the impact assessment phase of this application will have to investigate and assess the significance of implementing this project on these areas SUSTAINABILITY IMPERATIVE The norm implicit to our environmental law is the notion of sustainable development ( SD ). SD and sustainable use and exploitation of natural resources are at the core of the protection of the environment. SD is generally accepted to mean development that meets the needs of the present generation without compromising the ability of future generations to meet their own needs. The evolving elements of the concept of SD inter alia include the right to develop; the pursuit of equity in the use and allocation of natural resources (the principle of intra-generational equity) and the need to preserve natural resources for the benefit of present and future generations. Economic development, social development and the protection of the environment are considered the pillars of SD (the triple bottom line). Cape EAPrac 13 Draft Scoping Report

30 Man-land relationships require a holistic perspective, an ability to appreciate the many aspects that make up the real problems. Sustainable planning has to confront the physical, social, environmental and economic challenges and conflicting aspirations of local communities. The imperative of sustainable planning translates into notions of striking a balance between the many competing interests in the ecological, economic and social fields in a planned manner. The triple bottom line objectives of sustainable planning and development should be understood in terms of economic efficiency (employment and economic growth), social equity (human needs) and ecological integrity (ecological capital). As was pointed out by the Constitutional Court, SD does not require the cessation of socioeconomic development but seeks to regulate the manner in which it takes place. The idea that developmental and environmental protection must be reconciled is central to the concept of SD - it implies the accommodation, reconciliation and (in some instances) integration between economic development, social development and environmental protection. It is regarded as providing a conceptual bridge between the right to social and economic development, and the need to protect the environment. Our Constitutional Court has pointed out that the requirement that environmental authorities must place people and their needs at the forefront of their concern so that environmental management can serve their developmental, cultural and social interests, can be achieved if a development is sustainable. The very idea of sustainability implies continuity. It reflects the concern for social and developmental equity between generations, a concern that must logically be extended to equity within each generation. This concern is reflected in the principles of inter-generational and intragenerational equity which are embodied in both section 24 of the Constitution and the principles of environmental management contained in NEMA. [Emphasis added.] In terms of NEMA sustainable development requires the integration of the relevant factors, the purpose of which is to ensure that development serves present and future generations. 6 It is believed that the proposed 75MW Richtersveld Solar Farm development supports the notion of sustainable development by presenting a reasonable and feasible alternative to the existing vacant land use type, which has limited agricultural potential due the lack of water and infrastructure. Furthermore the proposed alternative energy project (reliant on a natural renewable resource solar energy) is in line with the national and global goal of reducing reliance on fossil fuels, thereby providing long-term benefits to future generations in a sustainable manner. 3 ACTIVITY The Applicant intends to develop a solar energy facility with a generation capacity not exceeding 75MW (Megawatt). The proposed Richtersveld Solar Farm is to be located on a development site of approximately 200ha on the Remainder of Portion 10 of the Farm Korridor Wes No 2 near Alexander Bay in the Northern Cape. The proposed infrastructure planned to be constructed includes a series of solar CPV Systems and/or PV arrays, inverters, internal electrical reticulation and an internal road network. An on-site substation will need to be constructed - this will typically include a transformer to allow the generated power to be fed into Eskom s electricity grid. Auxiliary buildings, including ablution, workshops and storage areas, are planned to be erected. A distribution line will also be required to distribute the generated electricity from the site to the Eskom substation and grid. 6 See definition of sustainable development in section 1 of NEMA. Cape EAPrac 14 Draft Scoping Report

31 Onsite substation Auxiliary Buildings Internal Roads PV Arrays Figure 7: A typical layout of the components of a solar facility The 75MW project will occupy approximately 200ha of land excluding the area associated with the new 132kV powerline and access road. An earlier proposal for 50MW on 100ha was considered by the Applicant. However during Round 3 of the Department of Energy (DoE) RE IPP Procurement Programme projects were awarded to 75MW and a 60MW project (elsewhere in the country). The Applicant is of the opinion that this is a fair indication of the scale of projects that are likely to be considered by DoE as being feasible. Without the economies of scale the Applicant believes a project smaller than 75MW is not going to be competitive on price. As a result the Applicant introduced a further alternative, being the preferred alternative, of the 75MW (on 200ha). This coordinates for this preferred 200ha development site is: South and East South and East South and East South and East 4 CONSIDERATION OF ALTERNATIVES A number of alternatives, including site, layout and technological alternatives were considered for the proposed Richtersveld Solar Farm development. The consideration of these alternatives is detailed below. 4.1 ACTIVITY ALTERNATIVES Two activity alternatives were considered at the onset of this project, namely: A 75MW CPV Power Plant; or A 75MW Hybrid Power Plant. Cape EAPrac 15 Draft Scoping Report

32 It should be noted that both of these options are considered feasible to the Applicant, thus both are to be investigated and assessed as preferred with the option of implementing either, and a combination of these two alternatives. 4.2 SITE ALTERNATIVES Two site alternatives for the proposed facility have been considered: A 100ha, 50MW CPV or Hybrid Power Plant; or A 200ha, 75MW CPV or Hybrid Power Plant. 4.3 GRID CONNECTION ALTERNATIVES Three different grid connection alternatives have been considered with each of these being either a 66kV (associated with the 50MW alternative) or a 132kV (associated with the 75MW alternative): Direct connection to the existing Beesbank Substation (option 3); Direct connection to the existing Oranjemund Substation (option 1); and Connection to the Oranjemund Substation following the route of an existing Eskom 66kV line/servitude (option 2). The option of connection to the Beesbank Substation has subsequently been excluded from this project as the Beesbank Substation does not have sufficient spare capacity to accommodate the preferred 75MW solar facility. 4.4 NO-GO ALTERNATIVE The Status Quo Alternative will mean that the Richtersveld Solar Farm not go ahead and remain as extensive agricultural use as it is currently. The land on which the proposed project is proposed is currently vacant however local herders make use of the land for grazing purposes. The solar-power generation potential of the area is significant and will persist should the no-go option be taken. The No-go/Status Quo alternative will limit the potential associated with the land and the area as a whole for ensuring energy security locally, as well as the meeting of renewable energy targets on a provincial and national scale. Should the no-go alternative be considered, the positive impacts associated with the solar facility will not be realised. The no-go alternative is thus not considered a favourable option in light of the potential benefits associated with the proposed solar facility development and the envisioned low environmental impact, however it will be used as a baseline from which to determine the level and significance of potential impacts during the Impact Assessment phase of the ongoing environmental process. 5 ENGINEERING OVERVIEW 5.1 BASIC UNDERSTANDING OF SOLAR PLANTS Photovoltaic (PV) panels convert the energy delivered by the sun to direct current (DC) electric energy. The array of panels is connected to an inverter by means of a network of cables. The DC power is inverted to alternating current (AC) power by a grid-tied inverter. The AC power can then be injected into the national electricity network (grid). The voltage at which power is generated is stepped up to the required voltage and frequency of the national grid by using a transformer. The electricity is distributed from the on-site transformers via distribution lines to the nearest Eskom substation. From the Eskom substation the electricity is fed into the Eskom grid. Cape EAPrac 16 Draft Scoping Report

33 Figure 8: Typical overveiw of solar power generation facility The infrastructure of the facility for either technology (CPV/PV) includes the ground-mounted PV racks (tracker units in the case of CPV), cables, access roads, auxiliary roads, an on-site substation, and a distribution line. The primary input of the system is sunlight, which is converted to electricity. The facility also utilises auxiliary electricity from the Eskom grid to power tracker motors in order to optimise the amount of sunlight on the solar PV infrastructure (in the case of single or dual axis tracking). In a fixed system, the PV panel stay in one position, and do not follow the path of the sun. A tracking system is ground-mounted and follows the sun s path with the use of typically single (for PV) or dual-axis (CPV) technology in order to maximise the amount of direct sunlight on the Solar PV panels. By following the sun, the tracked array rises quickly to full power and stays there on a clear sunny day, while the fixed array only maintains maximum power for a few hours in the middle of the day. CPV technology differs from PV in the sense that it uses inexpensive Fresnel lenses to focus the sun s direct normal irradiation (DNI) onto small, high efficiency triple-junction solar cells. By concentrating the sunlight, the required area of triple-junction solar cell is reduced to a small fraction of the area required by conventional PV solar cells. These cells are mounted on a base plate made of glass and convert the concentrated light directly into electrical energy. The lens plate and the base plate are connected via a metal frame and comprise a concentrator module. The concentrator module is mounted on a two-axis tracking system ( CPV Systems or trackers ) that follows the sun and ensures that the focus point of the concentrated sunlight is directly on the cells at every moment of the day. The modules are translucent and constantly move throughout the day (allowing for vegetation to grow underneath them), and do not create reflections other than directly back to the sun. 5.2 SITE DEVELOPMENT COMPONENTS The final design will consist of different components. A typical description of the components and their assumed impact are listed below Position of solar facilities The exact position of the solar CPV/PV array layout will follow a risk adverse approach and be determined by the recommendations in the environmental specialists reports in order to avoid all Cape EAPrac 17 Draft Scoping Report

34 sensitive areas in the positioning of the facility (Please see section 4 of this report discussing alternatives). In addition, the final layout will be influenced by the final detailed design of the project once a tender has been awarded. The footprint of the 75 MW plant will be located on approximately ha of the proposed site with space for the substation, control room stock room and workshop within the remaining 12.5ha making up the total of 200ha Foundation footprint Approximately 2400 x 36 kw trackers units are proposed for the Richtersveld Solar Farm 75 MW CPV Option. The CPV System mast (upon which the tracker table with modules is affixed) is approximately 4-5 m in height and roughly 700 mm in diameter. The physical footprint of the PV panels on the ground is formed by a network of vertical poles supporting a frame/rack upon which the solar panels are to be mounted (see examples below). Different methods are used to mount the panels to the ground. These poles are up to 2 m in height and approximately 80 mm in diameter. Figure 9: Showing typical examples of PV (left) and CPV (right) foundation footprints CPV System/PV Panel height A CPV tracker table, which consists of an integrated array of 12 x CPV Modules mounted side by side to form a panel +/ x 7.6 m (+/- 105 m²) in size (maximum total height +/- 8 m above ground). PV panels are affixed to a racking frame supported by poles and typically up to 3 m in height Access road to site The existing jeep tracks running to the site will be used as the primary access road to this facility Internal roads Gravelled internal roads and un-surfaced access tracks are to be provided for. Such access tracks (typically < 4 m wide and limited to the construction site) will form part of the development footprint. Pathways (typically < 4 m wide) between the PV panel layout will also be provided for to make the cleaning and maintenance of the panels possible. Existing roads will be used as far as possible On-site substations and transformers Approximately 12,5ha is allocated to accommodate auxiliary buildings, substations, transformers, workshops etc. These will fall within the 200ha footprint that will be fenced. Cape EAPrac 18 Draft Scoping Report

35 Figure 10: Typical example of on-site substation and transformer Cable routes and trench dimensions Shallow trenches for electric cables will be required to connect the panels to the on-site substation (such electric cables are planned along internal roads and/or along pathways between the PV panels). Figure 11: Examples or typical cable trenching used to connect the panels to the on-site substation Connection routes to the distribution/transmission network Electricity will be transmitted from the on-site step-up substation via a new 132kV overhead power line to the existing Oranjemund substation which is located to the west of the proposed site. A number of possible connection routes are investigated in this EIA (please see section 4 above for the discussion of the power line route alternatives) Security fence A perimeter security fence will be constructed around the solar park with a guarded security point. The ecological specialist will provide recommendations into the type and location of perimeter fence during the impact assessment stage of this process Auxiliary buildings The auxiliary buildings area will typically include: A workshop area; A storeroom area; A change and ablution room area; An administrative and security building; and 10 x 10 kl water tanks Cape EAPrac 19 Draft Scoping Report

36 The final detailed design and exact coordinated layout of the facility will be designed and finalised should the facility be approved and awarded a tender as an IPP. The components listed above are typical to such projects and may deviate due to engineering requirements, new technologies and regulatory changes from the government s tender process. The detailed design will take place with due consideration of the specialist recommendations Cut and fill areas As far as possible, any cut and fill activity along the access roads will be avoided. Where alternations might be necessary, input from civil construction engineers and the environmental control officer will be sourced regarding the cut and fill aspects Borrow pits As far as possible, the creation of borrow pits will also be avoided. The current EIA application does not make provision for new borrow pits. Should new borrow pits be required on the property, these will have to be licenced/authorised in terms of the Minerals and Petroleum Resources Development Act and the National Environmental Management Act Soil heaps As far as possible, the creation of permanent soil heaps will be avoided. All topsoil removed for the purpose of digging foundations are to be separately stockpiled within the boundaries of the 200 ha development footprint, for later rehabilitation. It is unlikely that major soil heaps will be required for this construction site. 5.3 CONSTRUCTION OF THE PROPOSED FACILITY The following engineering construction phase considerations are proposed for this project. The environmental management of these activities will be addressed in the Environmental Management Programme that will be included with the Draft Environmental Impact Report (DEIR) Should the project be approved, and all required approvals and licences are obtained from the DEA, NERSA and a Power Purchase agreement (PPA) is secured with Eskom, the construction is envisioned to begin in A series of activities would need to be undertaken, to construct the proposed facility and associated infrastructure. Each facility will be established in different phases namely: the pre-construction, construction, operation and decommissioning phases. The preconstruction phase includes: 1. Conducting of surveys; 2. Transporting of the required construction components and equipment to site; and 3. Pre-site preparation (establishment of temporary services for construction such as lavatories, water, health and safety requirements, site office, etc.). The construction phase includes: 1. Transportation of solar components and equipment to site; 2. Establishment of internal access roads; 3. Undertaking site preparation (including clearance of vegetation; stripping of topsoil where necessary); 4. Erecting of solar PV frames and panels; 5. Constructing the on-site substation; 6. Establishment of additional infrastructure (workshop and maintenance buildings); 7. Establishing the underground connections between PV panels and on-site substation; Cape EAPrac 20 Draft Scoping Report

37 8. Connection of on-site substation to power grid; 9. Undertaking site remediation; and 10. Construction of perimeter fencing. The activities that will be undertaken on site fall under different specialist fields and include: Civil works: site preparation, site grading, drainage, roads, foundations, storm water & antierosion management; Mechanical works : piers installations, mechanical assembly including trackers, mounting of panels; and Electrical works: installation from low to high voltage, including substation Transportation of solar components and equipment to site All solar plant components and equipment are to be transported to the planned site by road. The most viable route option is from Cape Town, via the N7 (West Coast Road) to Steinkopf, turning onto the R382 to Port Nolloth linking to Alexander Bay. From here the road (DR3246) becomes a wide gravel road that follows the Orange River all the way to the Richtersveld National Park. At the existing Beesbank Substation a number of jeep tracks run all the way to the solar site. Although the majority of the access roads are private roads, the Provincial Department of Roads and Public Works will have to be consulted in order to obtain confirmation of upgrade and maintenance requirements for the duration of the construction phase for any roads falling within their jurisdiction. Construction should stretch over a period of approximately 18 months. During this period the majority of the solar PV panels and construction components will be transported by utilising container trucks. This will typically include all solar PV components and additional construction equipment. Over the period of 18 months, a substantial number of containers will therefore be transported to the proposed site. Normal construction traffic will also need to be taken into account. The usual civil engineering construction equipment will need to be transported to the site (e.g. excavators, trucks, graders, compaction equipment, cement trucks, etc.). The components required for the establishment of the on-site substation power line will also need to be transported to the site. In the unlikely event that some of this power station equipment may be defined as abnormal loads in terms of the Road Traffic Act (Act No.29 of 1989), input and approval are to be sought from the relevant road authorities for this purpose Establishment of internal access roads on the farm Minor internal maintenance roads on the farm and proposed construction site are to be constructed. Where necessary, gravel may be used to service sections of the existing road on the farm itself. In order to form an access track surface some of the existing vegetation and level the exposed ground surface might need to be stripped off. The impact of this will be assessed by the botanical specialist in the impact assessment report. These access tracks (typically less than 4 m wide) will form part of the development footprint. The layout and alignment of these internal roads will be informed by recommendations made by the botanical specialist, as well as the topographical survey (although this detailed design based on the topographical survey will only take place at a later stage). Pathways (typically less than 4 m wide) between the solar PV panels are to be provided for ease of maintenance and cleaning of the panels. Cape EAPrac 21 Draft Scoping Report

38 In addition, a fire break (buffer area) that can also serve as an internal road will be constructed around the perimeter edges of the entire proposed site. All gravel access roads constructed will be more or less 4 m wide Site preparation Cleaning of the surface areas is necessary in order to construct the solar PV plant. This will include clearance of vegetation at the footprint of the solar PV panels, the digging of foundations for the on-site substation and workshop area foundations and the establishment of the internal access roads and lay-down areas. Where stripping of the topsoil is required, the soil is planned to either be stockpiled, backfilled and/or spread on site. In the instance where there are cultivated areas currently on the site, the upper 30 cm of the cultivated areas will be stockpiled on the boundaries of the site. The topsoil stockpiles must be protected from erosion by re-establishing vegetation (grasses) on them. The environmental management plan will provide specifications for this vegetation re-establishment. Figure 12: Showing typical examples of site preparation during the construction phase of a solar project To reduce the risk of open ground erosion, the site preparation will typically be undertaken in a systematic manner / phased approach. Where any botanical species of concern or sites of cultural/heritage value are involved, measures are to be put in place to attend to the preservation or restoration of these elements as recommended by the participating specialists and in the Environmental Management Programme Erecting of solar PV panels Once the site preparation has been done, and all necessary equipment has been transported to the site, the solar PV panels and structures are assembled on site. Each solar PV module consists of a number of cells, forming a single panel. The solar PV modules are assembled in long rows across the solar PV array, with the rows approximately 5 m apart. The exact amount of modules in each solar PV array is subject to the final facility design and is still to be confirmed. Foundation holes for the solar PV panels are to be mechanically quarried to a depth of approximately mm. Cape EAPrac 22 Draft Scoping Report

39 Figure 13: Showing typical erection of panels during the construction phase Driven piers and screws are recommended in order to minimise the environmental impact of the facility, but will be dependent on mechanical specifications. If concrete foundations are used, foundation holes will be mechanically excavated to a depth of about 30 cm 50 cm. The concrete foundation will be poured and be left for up to a week to cure Construct ion of on-site substation An on-site substation will be necessary to enable the connection between the solar energy plant and the National Eskom electricity grid. The generated voltage is planned to be stepped up to 132 kv by means of an on-site substation in order to be fed into the Eskom grid via the existing Oranjemund Substation. The on-site substation is constructed in a few sequential steps. First a site is determined by the recommendations from the reports of the environmental specialists to avoid the most sensitive areas in the positioning of the substation. Once the site is approved, the site clearing and levelling is to be done, after which the access roads to the substation are constructed. Next the substation foundation is laid. Once the foundation is constructed, the assembly, erection and installation of all equipment, including the transformers, are to be completed. The final step is the connection of the conductors to the equipment. The post-construction phase includes the rehabilitation of disturbed areas and protection of erosion sensitive areas. Below is typical on-site substation that connects to the existing Eskom substation. Figure 14: Showing typical example of on-site substation Cape EAPrac 23 Draft Scoping Report

40 5.3.6 Establishment of additional infrastructure To minimise the potential ecological impact of this project, a decision was made to limit all activities and storage of equipment to one nominated area. A dedicated construction equipment camp and lay-down area are planned to be established, which will then form part of the auxiliary building area. The laydown area for the construction period will be approximately 1ha. This area will typically be used for the assembly of the solar PV panels and the generation placement/storage of construction equipment. A temporary facility are planned to be used to secure the storage of fuel for the on-site construction vehicles. Necessary control measures will be put in place for correct transfer and use of fuel. The auxiliary building area will typically consist of the following: workshop area; storeroom area; change and ablution room area; administrative and security building; and 10 x 10 kl water tanks Connect on-site substation to power grid In order to evacuate the power generated by the proposed facility and feed it into the Eskom grid, a distribution line would have to be constructed between the proposed on-site substation and the existing Oranjemund substation. The Applicant must submit a grid feasibility application to Eskom, to confirm the connection possibilities for this project. Feedback on the grid feasibility application will be included in the final Environmental Impact Report Undertake site remediation Once construction is completed and once all construction equipment is removed, the site is to be rehabilitated where practical and reasonable. In the case where access routes to the site will not be used during operation, the access points are to be closed and rehabilitated as detailed in the Environmental Management Programme. 5.4 WATER USE REQUIREMENTS The project requires about m 3 of water during the entire construction period. During maintenance, approximately 822 m 3 of water would be required per annum (mainly for the cleaning of the panels). The ten 10 kl capacity tanks will be places on site in order to store sufficient water at any given time. The water distribution system will distribute water from the ten 10 kl water tanks to a high pressure hose and onto the solar panels. The proposed activity is not a water intensive activity (as opposed to CSP). Only a limited amount of water is required in low rainfall periods to clean the modules once every quarter so that they can operate at maximum capacity. No chemicals will be used to clean the panels, only water. Weather conditions, traffic and general dustiness at the site play a role in the exact amount of ground water required to wash the solar PV panels. At present it is assumed that each panel should be washed once every three months. To further reduce the use of water at the solar facility, the use of alternative panel cleaning methods are also being investigated. The most feasible technology under consideration uses Cape EAPrac 24 Draft Scoping Report

41 compressed air to blow off any debris from the panel s surface. At this stage the technology is being tested and needs refinement before it would be commercially viable Water Sources The following water sources are currently under investigation: Boreholes: The on-site borehole which was used to supply livestock with drinking water has not been used for some time due to lack of maintenance and upkeep. Although a possible water source it is unlikely that this borehole will be used as a source for construction and operational phases Orange River The Applicant is considering direct abstraction from the Orange River. In order to do this, the Department of Water Affairs will have to confirm that the volume of water required for construction (temporary) and operational phases (long term) may be abstracted without negatively impacting on other lawful water users and/or the sensitive Orange River estuary. A Water Use License Application (WULA) may be required in such an instance Existing water use rights As an alternative the Applicant is considering transferring water from other properties also owned by the CPA, for the purpose of construction and operational requirements. Again, such a transfer must be confirmed by the Department of Water Affairs as not having a negative impact on existing lawful water users. A Water Use License Application (WULA) may be required in such an instance Water buffer Water storing infrastructure is to be provided as part of the auxiliary building footprint area. Storing capacity for two weeks are planned to be provided for. This requires the installation of ten 10 kl water tanks. These tanks will serve as both a water buffer as well as for rainwater capture as described above Water-use permission The quantity of water required usually qualifies for a general authorisation, but the specific quaternary area in which the development site is situated does not allow for general authorisation. Thus, a formal water use licence would have to be applied for additional abstraction from the Orange River or for transferring from one cadastral unit to another. However, a full assessment of the water-use licence application will only be undertaken by the Department of Water Affairs (DWA) once the project is approved. The EIA application can therefore be submitted without a water licence, as long as there is enough confirmation that there are sufficient water available. The Applicant will identify in their Bid Response whether an Integrated Water Use Licence will be required in terms of the National Water Act, 36 of 1998 for the activities to be undertaken in relation to the Project, including the construction of all infrastructure, such as roads and underground cables associated with the Project, and provide copies of all studies done to determine this and provide copies of all applications (if any) made regarding this. The DWA are also registered as a key stakeholder in the environmental process and will have an opportunity to provide any additional input. Cape EAPrac 25 Draft Scoping Report

42 5.5 EROSION AND STORM WATER CONTROL The erosion potential of the site is low because of the extremely low annual rainfall in the area. The ground condition in the Richtersveld area is such that any surface water is very quickly absorbed into the soil. This avoids water build up on the surface and quickly reduces any water flow which might cause water erosion. On large structures or buildings appropriate guttering would be used around the building to avoid water erosion where roof water would be flowing off the roof. Wherever practically possible rainfall run-off from the roofs/gutters will be captured and stored in rainwater tanks. If this water cannot be captured, water will be channelled into energy dissipating structures to spread the water and slow it down to reduce the risk of erosion. Such a structure could be moulded from precast concrete, loosely packed rock or perforated bags filled with stone. Any rainfall on the solar panels would be welcomed due to its cleaning effect, but as mentioned before the annual predicted rainfall is very low and would not cause any erosion. The solar panel surfaces are installed at a relatively large incline with gaps between panels. This does not allow significant water build up on the panels while also reducing the energy in falling droplets. Considering that the panels are on a tracking system, this also means that droplets leaving the solar panel surface would not drop onto the same ground areas all the time. It is in the interest of the solar operator to keep the area clean and free of erosion to avoid any damage to the equipment. The solar panels would be installed on frames, allowing for natural sheet flow underneath the structure. During the construction phase of the project there might be a risk of wind erosion where natural vegetation is removed. This might increase the risk of damaging sensitive equipment with a sandblasting effect and all parties involved will have to be vigilant in avoiding this from happening. The environmental management programme submitted as part of the Draft Environmental Impact Report will contain management recommendations regarding dust and erosion control during the construction phase. Note that the construction will take place in three phases. This phased construction approach should also minimise the amount of exposed soil at any one time thus reducing the risk for wind erosion and dust generation. Once the construction on each phase is complete the cleared areas will be re-vegetated. Bare areas will also be packed with brush removed from other parts of the site to encourage natural vegetation regeneration and limit erosion. Any water being used in the cleaning process would speed up this natural vegetation rehabilitation process. Further it will also have a bonding effect on the sandy soil, avoiding the loose sand blowing away causing wind erosion. Access roads and internal roads would also be designed and build using recognised erosion and storm water management systems. During the construction phase of the solar PV facility temporary solutions would be implemented to ensure that the environment is preserved in a sustainable way by avoiding erosion. 5.6 PROJECT OPERATION AND MAINTENANCE PHASE The proposed operation of the site is for years. During this life-cycle, the plant will be maintained and monitored. The facility should be operational during daylight hours, except during maintenance, poor weather conditions or breakdowns. Regular maintenance will typically include periodic cleaning, greasing of bearings and inspection. The panels are planned to be cleaned with water or compressed air. Any waste products generated (defunct bearings, broken panels etc) be Cape EAPrac 26 Draft Scoping Report

43 disposed of in accordance with the National Environmental Management: Waste Act (Act 59 of 2008). It is estimated that during the operational phase up to 40 jobs will be created. The staff members will typically include technicians, maintenance and security personnel. Staff can be transported around the site using utility vehicles and a typical mini bus to transport staff from nearby towns of Kuboes, Alexander Bay or Port Nolloth and surrounding community. From time to time additional contract staff may be required for ad hoc ground cleaning or special panel cleaning. When the solar modules and associated equipment become defective, they will be recycled and reused where possible. 5.7 PROJECT DECOMMISSION PHASE The proposed solar energy facility is expected to have a lifespan of approximately years if the specified periodic maintenance is performed. If financially viable and depending on climate factors in years time (farming may no longer be viable) the PV facility may continue operating. Existing infrastructure and components of the PV facility may be replaced with new technology. Once the facility has reached the end of its economic life, the infrastructure is to be decommissioned. The decommissioning of the facility would entail the disassembly and replacement of components with other appropriate technologies. However, if not deemed so, then the facility would be completely decommissioned. Preparation activities for site decommissioning should include confirming the integrity of access to the site. Site access should be able to accommodate the required equipment (e.g. lay down areas, construction platform) and the mobilisation of decommissioning equipment. The components would be disassembled, reused and recycled where possible, or disposed of in accordance with regulatory requirements. Functional components are planned to be donated to and installed at local schools and clinics to benefit the community. 5.8 WASTE EFFLUENT, EMISSION AND NOISE MANAGEMENT (CONSTRUCTION, OPERATION & DECOMMISSIONING) Solid waste management During the construction phase an estimated amount of less than 5m 3 non-hazardous solid construction waste are to be produced per month, for the expected 18 month construction period. All construction waste will be safely stored, and should be removed from site on a scheduled waste removal basis by the appointed construction contractor where and when deemed necessary. The construction waste, where applicable, are to be disposed at a municipal landfill site that is appropriately licenced. The Environmental Management Programme will address solid waste management during construction. During the operational phase after construction, the facility should not produce any solid waste Liquid effluent (sewage) The liquid effluent generated is going to be minimal and limited to the ablution facilities. All workers will be transported to site on a daily basis and no workers will be housed on site. Chemical toilets will be on site during construction and during operation of the facility. These chemical toilets will be serviced and emptied on a weekly basis by a private contractor. The sewage will be Cape EAPrac 27 Draft Scoping Report

44 transported to a nearby Waste Water Treatment Works for treatment. The use of a septic vs. conservancy tank during operation will be determined by the local authority, namely Richtersveld Municipality. The Richtersveld Municipality is a registered stakeholder on this process and will be requested to provide input. Due to the remote locality of the farm, sewage cannot be disposed in a municipal waterborne sewage system Emissions into the atmosphere and noise generation Very little emissions should be released into the atmosphere (with the exception of dust during the construction phase) and no significant noise should be generated, except during the construction period with drilling and hammering. Due to the site location this should not pose any issue as no residential area is located nearby. The Environmental Management Programme will address the noise and dust generation during the construction phase. 6 SOCIO-ECONOMIC CONTEXT The socio-economic context of this project will be provided by Tony Barbour (July 2014). Please see the social scoping report attached in Annexure D6 supplementary information in this regard. 6.1 PROJECT COST OVERVIEW Renewable energy projects, such as the proposed solar facility, require significant investment. Funds of equity and debt investors either from foreign or domestic sources are obtained. The cost requirements and potential revenue are discussed in this section. The project costs consist of two parts, capital cost and running cost. The capital cost pertains to all costs incurred for the establishment of a producing facility. The running cost relates to those costs incurred to ensure that the facility operates as it should throughout its expected lifetime. Solar PV installations can operate for many years with little maintenance or intervention. Therefore after the initial capital outlay required for building the solar power plant, financial investment is limited. Operating costs are also extremely low compared to other existing power generation technologies. Investment in renewable energy initiatives, such as the proposed SEF, is supported by the White Paper on Energy Policy for South Africa (December1998). In this regard the document notes: Government policy is based on an understanding that renewables are energy sources in their own right, are not limited to small-scale and remote applications, and have significant medium and longterm commercial potential. Renewable resources generally operate from an unlimited resource base and, as such, can increasingly contribute towards a long-term sustainable energy future. The support for renewable energy policy is guided by a rationale that South Africa has a very attractive range of renewable resources, particularly solar and wind and that renewable applications are in fact the least cost energy service in many cases; more so when social and environmental costs are taken into account. Government policy on renewable energy is thus concerned with meeting the following challenges: Cape EAPrac 28 Draft Scoping Report

45 Ensuring that economically feasible technologies 7 and applications are implemented; Ensuring that an equitable level of national resources is invested in renewable technologies, given their potential and compared to investments in other energy supply options; and, Addressing constraints on the development of the renewable industry. The White Paper also acknowledges that South Africa has neglected the development and implementation of renewable energy applications, despite the fact that the country s renewable energy resource base is extensive and many appropriate applications exist. The White Paper also notes that renewable energy applications have specific characteristics that need to be considered. Advantages include: Minimal environmental impacts in operation in comparison with traditional supply technologies; and Generally lower running costs, and high labour intensities. Disadvantages include: Higher capital costs in some cases; Lower energy densities; and Lower levels of availability, depending on specific conditions, especially with sun and wind based systems. The IRP 2010 also allocates 43% of new energy generation facilities in South Africa to renewables. 6.2 PROJECT SPECIFIC COSTS The Richtersveld Solar Farm detailed costing has not been completed on the date of completing this Draft Scoping Report. The running cost of a solar PV facility is minimal related to the initial capital cost, contributing to the most significant cost of constructing and running a solar PV facility. The economic feasibility of the project has however been determined. The capital expenditure on completion of this project is anticipated to be in the region of R 1.5 billion (2014 rand value) for a 75 MW facility. 6.3 OPERATIONAL REVENUE STREAMS The revenue streams during the operation of the facility results mainly from electricity sales, intended under the current governmental subsidy, known as the Independent Power Producer Procurement Programme (IPP procurement programme). The IPP procurement programme portrays fixed ceiling prices for bidders to tender against. The establishment of these ceiling prices is based on industry standard return on investments. The IPP governmental study identified the feed-in tariff per technology related to the capital cost required per technology against its revenue potential, identifying the required subsidy per technology to be paid. In short the subsidy offered by the IPP procurement programme enables the project to be financially viable by selling electricity at a subsidised price, while the costs of such a facility relates to the industry standard. 7 In this regard the Applicant is considering a 75MW project (as the preferred option) compared to the initial 50MW proposal with which this application process commenced. Cape EAPrac 29 Draft Scoping Report

46 As part of the IPP procurement programme preferred bidders will enter into a power purchase agreement between the IPP generator and the Single Buyers Office. National treasury stands in for surety, while the National Energy Regulator of South Africa (NERSA) regulates the IPP licences. NERSA and the IPP procurement programme require an Environmental Authorisation as a gate keeping criteria, where no project would be considered without the Environmental Authorisation being granted. NOTE: This Richtersveld Solar Farm project is scheduled for consideration as part of the 5 th Bidding window which is due sometime between May 2015 and August EMPLOYMENT OPPORTUNITIES It is estimated that roughly 200 job opportunities will be created over the duration of the 18 month construction period for the Richtersveld Solar Farm development. The operational phase is likely to create up to 40 permanent employment opportunities over the lifespan of the project (estimated years). 7 SITE DESCRIPTION AND ATTRIBUTES The following sections provide a description of the environmental and built environment context of the Remainder of Portion 10 (Arris) of the Farm Korridor Wes No 2, with particular focus on the study area, access road and overhead powerline alignment. The existing access track (to be upgraded to fit-for-purpose standard falls within Remainder of Portion 10 (Arris) of the Farm Korridor Wes No 2. The proposed new 132kV powerline will cross two (2) neighbouring properties, one which is privately owned, namely Portion 9 of the Farm Korridor Wes No. 2 and Portion 10 of the Farm Groot Derm. 7.1 LOCATION & BUILT ENVIRONMENT The target property, Remainder of Portion 10 (Arris) of the Farm Korridor Wes No. 2, is located in the Namakwa District of the Northern Cape Province, within the jurisdiction area of the Richtersveld Local Municipality. The property is approximately hectares is size and is located approximately 28.4km East from Alexander Bay (to the centre of the site) and 8.3km South of the Orange River 8 (to the centre of the site). No structures were noted on the study site during the site inspection although a dilapidated windmill with Jo-Jo tanks was noted at the position of an existing borehole (off-site). The study site itself slopes towards the lowest point in the North Western corner. The slopes are very gentle and even. There is no sign of erosion from water on this site implying that water is absorbed into the ground before any surface runoff occurs. This is also consistent with the very low total and monthly rainfall (monthly rainfall range between 5mm and 8mm) and annual rainfall of roughly 50mm. In the event that Applicant decide to abstract water directly from the Orange River (for construction and operational requirements), an 9km long 63mm PVC pipe will have to be installed leading 8 Also referred to as the Gariep River. Cape EAPrac 30 Draft Scoping Report

47 from an already identified point north the Beesbank Substation, past the substation and following the existing track to the study site. This site was selected due to its proximity to the access road leading to the study site and the fact that this portion of the river is already accessible via an existing track. The potential for impacting on the biophysical environment as a result of additional disturbance along this route is considered limited. The property along the Orange River is the Farm Brandkaros 621 which, according to records, is owned by the Richtersveld Municipality. Formal permission will have to be obtained from the Municipality to install a pump and pipeline within this portion prior to finalising the EIA process. Figure 15: Area on the bank of the Orange river where abstraction is being considered showing sparse vegetation and rock banks within the flood line. The Applicant intends to make use of the existing access road(s) that lead from the Beesbank Substation directly to the solar site. These tracks vary in width along the route and in many instances up to three tracks run in parallel eventually ending at the existing borehole with windmill situated on the Remainder of Portion 10 (Arris) of the Farm Korridor Wes No. 2. For this reason it is unlikely that upgrading of (one) of these tracks will cause any notable further environmental degradation. It is recommended however that once a preferred route is chosen the Applicant rehabilitates others running along the same alignment. The majority of the existing jeep tracks fall within the ambit of the Remainder of Portion 10 (Arris) of the Farm Korridor Wes No. 2. The portion closest to the Beesbank Substation runs through Eskom s property. Figure 16: Images indicate the track(s) running from the Beesbank substation to the study site. Disturbance along these tracks is notable as it appears between one and three tracks follow the same route. The windmill and borehole is situated east of the study site. Although this borehole was at some stage considered a possible water source, it appears unfeasible. The borehole is likely to be dry of Cape EAPrac 31 Draft Scoping Report

48 damaged due to lack of maintenance, thus is it unlikely to be used as a primary source of water supply. Figure 17: Existing borehole situated (off-site) east of the solar site The proposed new powerline (excluding the option to connect to the Beesbank substation) connecting to the Oranjemund substation will cross two other properties situated between the solar site and the Oranjemund Substation. The one is the property immediate to the West of the solar site (Portion 9 of the Farm Korridor Wes No.2) which is also owned by the Sida!HUB Communal Property Association as well as the Remainder of Farm Grootderm Portion The preferred option at this point in the project planning is for this new powerline to run within an existing, vacant servitude (owned by Eskom) that runs in parallel to Eskom s existing 66kV line linking to the Oranjemund substation (referred to as Option 2). This preferred alternative will reduce the potential for negative impact by concentrating the disturbance level along an already disturbed power line servitude. Figure 18: The Oranjemund Substation (left) has sufficient capacity to absorb the electricity generated by the proposed project. The proposed 132kV line will run alongside the 66kV (right) line connecting to the substation The detail design for the proposed 132kV powerline will only be undertaken closer to project implementation phase, thus the micro-siting of individual pylon structures remains unknown at this stage. It is recommended however that the Applicant appoint an independent Ecologist to assist with micro-siting at the time of detail design. 7.2 GEOLOGY & CLIMATE The Geology and climate of the study site was defined by the agricultural specialist as follows. Cape EAPrac 32 Draft Scoping Report

49 7.2.1 Geology From the Oranjemond Substation at the Orange River inland the initial topography is undulating with bare rocks covered with sand. The sand is wind-blown from Namibian heavy dunes, across the river. The terrain then develops in typical flat, succulent Karoo veld, sparsely covered with vegetation. The area lies in the Namibian Erathem, within the Gariep Complex, specific in the Grootderm Suite. The lithology (mineralogical composition and texture of rocks) of this area consists of Schist Andesite and Basalt Climate The region is classified as an arid zone with desert climate. The following specific parameters are applicable: Table 3: Showing typical data associated with the RE of Portion 10 Farm Korridor Wes No2 Rainfall Annual rainfall 0-200mm Summer rainfall <62.5mm Winter rainfall <62.5mm Variation in rainfall 40 to 50% Temperature Mean maximum temperature 29 31⁰C January Temperature >27.5⁰C Mean minimum temperature July temperature <8⁰C <7.5⁰C Temperature range >15⁰C First frost expected No frost before June Last frost expected No frost after August Hours of sunshine >80% Evaporation mm Humidity <30% 7.3 SOILS With the climate and geology associated with the area, calcic soils are prone to develop. Calcic soils originate in arid climates with the accumulation of secondary lime, forming a distinctive horizon consisting chiefly of calcite. In calcic soils, either hardpan carbonate or a soft carbonate horizon or (rarely) gypsic horizon dominates the morphology of the sub-soil. Soil forms with these characteristics include Molopo, Askham, Kimberly, Plooysburg, Etosha, Gamoep, Addo, Prieska, Brandvlei and Coega AGIS indicates the typical profile for soils in this region as follows: Soils with minimal development, usually shallow, on hard or weathering rock, with or without intermittent diverse soils. Lime generally present in part or most of the landscape. Red and yellow well drained sandy soil with high base status Freely drained, structure less soils Favourable physical properties May have restricted soil depth, excessive drainage, high erodability, low natural fertility Strongly saline soils Cape EAPrac 33 Draft Scoping Report

50 Ae 74 Site Land Type Map Ae 74 Red and Yellow apedal soils,freely drained and deeper than 300 mm. Figure 19: Soil land use map for RE for Portion 10 of Farm Korridor Wes No.2 According to the Land Type Map, the predicted soils (80% chance) that could be found in the polygon where the site is situated are as follows: Previous notification Recent Notification Group Series Form Family Limiting horizon Hutton Maitengwe Plooysburg Kimberly Brakkies Taung Hard carbonate Soft carbonate 7.4 TOPOGRAPHY The topography has low relief with terrain form 4, namely floodplain. The slope gradient is between 0 and 2% with a concave shape. Higher ground drains towards multiple depressions, forming waterways towards the Orange River. 7.5 VEGETATION Mr. Simon Todd, of Simon Todd Consulting, conducted an Faunal and Flora scoping study of the proposed Solar development sites (see Appendix D, Annexure D1 for full report), from which the following is drawn. The purpose of the Ecological Scoping Report is to describe and detail the ecological features of the proposed site; provide a preliminary assessment of the ecological sensitivity of the site and identify the likely/potential impacts that may be associated with the development. A desktop review of the available ecological information for the area was conducted in order to identify and characterize the ecological features of the site. This information was used to derive a draft ecological sensitivity map that presents the presumed ecological constraints and opportunities for development of the site. These assumptions will be verified by means of a detailed site inspection during the environmental assessment stage of this process. The information and sensitivity map presented by the ecologist thus provides an ecological baseline that can be used in the planning phase of the development to ensure that the potential Cape EAPrac 34 Draft Scoping Report

51 negative ecological impacts associated with the development can be minimized. The constraints detailed in this plan will be used to generate the preferred layout alternative for this proposed facility Scope of Study The specific terms of reference for the scoping ecological study included the following: a description of the environment that may be affected by the activity and the manner in which the environment may be affected by the proposed project; a description and evaluation of potential environmental issues and potential impacts (including direct, indirect and cumulative impacts) that have been identified; and Identification of potentially significant impacts to be assessed within the EIA phase and the details of the methodology to be adopted in assessing these impacts. This should be detailed enough to include within the Plan of Study for EIA and include a description of the proposed method of assessing the potential environmental impacts associated with the project Sensitivity Mapping & Assessment A draft ecological sensitivity map of the site was produced by integrating the available ecological and biodiversity information available in the literature and various spatial databases. The ecological sensitivity of the different units identified in the mapping procedure was rated according to the following scale: Low Units with a low sensitivity where there is likely to be a negligible impact on ecological processes and terrestrial biodiversity. This category is reserved specifically for areas where the natural vegetation has already been transformed, usually for intensive agricultural purposes such as cropping. Most types of development can proceed within these areas with little ecological impact. Due to the large amount of transformation that has occurred in the area, this is the dominant sensitivity category within the study area. Medium- Areas of natural or previously transformed land where the impacts are likely to be largely local and the risk of secondary impact such as erosion low. Development within these areas can proceed with relatively little ecological impact provided that appropriate mitigation measures are taken. High Areas of natural or transformed land where a high impact is anticipated due to the high biodiversity value, sensitivity or important ecological role of the area. Development within these areas is undesirable and should only proceed with caution as it may not be possible to mitigate all impacts appropriately. Very High Critical and unique habitats that serve as habitat for rare/endangered species or perform critical ecological roles. These areas are essentially no-go areas from a developmental perspective and should be avoided as much as possible. In some situations, areas where also categorized between the above categories, such as Medium-High, where an area appeared to be of intermediate sensitivity with respect to the two defining categories. Cape EAPrac 35 Draft Scoping Report

52 7.5.3 Baseline Description of the Affected Environment The following baseline description of the affected environment was provided by the Ecological Specialist Broad-Scale Vegetation Patterns The vegetation of the area has been mapped at a relatively fine scale for an arid area, with the result that a fairly large number of vegetation types are present in the area. The development area itself is restricted to the Upper Annisvlakte Succulent Shrubland vegetation type. This vegetation unit is relatively restricted at only 191 km 2 and occurs on parts of the Annisvlakte north and northwest of the Goariep Mountain in the north-eastern Richtersveld from near Kubus to the region southeast of Arrisdrift. The landscape occupied by this vegetation unit is mostly a very wide tilted plain. On the plains, habitats are controlled by soil salinity and texture and by different states of degradation by overgrazing. Of significance in terms of climate is that the area receives only 55-70mm rainfall largely during the winter and experiences strong to very winds which cause severe dust and sand storms resulting in strong erosion of topsoil and sandblasting. It is also pertinent that the current state and composition of this vegetation type is considered to be the result of degradation through overgrazing by smallstock. Another important vegetation type in the area is Western Gariep Lowland Desert, which occupies the majority of the proposed power line route as well as most of the water supply pipeline. This vegetation unit occupies the Northwestern Richtersveld as well as the plains of the Annisvlakte west of Kuboes and the hilly mafic land rock landscape close to Arrisdrift, Brandkaros and Grootderm. This vegetation is also very arid and receives 45-60m rainfall annually, falling mostly during the winter. Fog is also an important water source for this vegetation type, which is not captured in the rainfall statistics. Frequent and strong wind and sandstorms are also reportedly common especially in the western regions of this unit. This vegetation unit falls within the West Gariep centre of endemism (Jurgens 1991). Parts of this vegetation are also considered degraded as a result of overgrazing by smallstock. The vegetation composition of this vegetation unit can be quite variable depending on substrate conditions and can vary from grassy plains to dwarf succulent shrublands and rocky outcrops with taller stem and tree succulents. The only other vegetation unit that might be directly affected by the development would be Lower Gariep Alluvial Vegetation which occurs along the Orange River. This vegetation unit is classified as Endangered as a result of the fact that only 50% remains, having been impacted by agriculture and mining activities. However, only the last 300m of the pipeline route along the Orange River floodplain occurs within this vegetation and the scope for significant impact is relatively low. This vegetation unit is associated with the banks and alluvial terraces of the lower Orange River and is characterised by the presence of riparian thickets dominated by large trees such as Zizyphus mucronata, Euclea pseudebenus, Rhus lancea and Tamarix usneoides. At the site of the extraction point the alluvial vegetation is highly degraded and only the overstorey of trees remains. The ecological sensitivity of the different parts of the site are likely to be related to local ecological features and the presence of species and habitats of conservation concern, rather the broad distribution of vegetation types. Cape EAPrac 36 Draft Scoping Report

53 Figure 20: Broad-scale overview of the vegetation in and around the Richtersveld Solar Farm (Todd, 2014) Figure 43: Broad-scale overview of the vegetation in and around the Richtersveld Solar Farm (Todd, The following table is taken from the Ecological Report and reflects important information on the vegetation found in the area. Table 4: Vegetation types that occur within or near the site with their basic conservation statics and status according to the National List of Threatened Ecosystems (2011), Todd 2014 Name Extent km 2 Remaini ng Conservation Target Protect ed Status Lower Gariep Alluvial Vegetation % 31% 5.80% Endangered Western Gariep Lowland Desert % 28% Least threatened Upper Annisvlakte Succulent Shrubland % 28% Least threatened Western Gariep Plains Desert % 28% Least threatened Northern Richtersveld Yellow Duneveld % 26% Least threatened Cape EAPrac 37 Draft Scoping Report

54 Richtersveld Sandy Coastal Scorpionstailveld % 26% Least threatened Fine-Scale Vegetation Patterns The solar study site The vegetation of the proposed development area is very sparse and probably amounts to less than 10% total cover, which is to be expected in such an arid area. The soils in the development area are very silty soils that may be the result of degradation having resulted in the finer-textured loamy fraction having been blown away by strong winds. The impact of wind is apparent in the vegetation as most of the shrubs and dwarf succulents present have collected small hummocks of sand around their bases. There is some patchiness in the vegetation with large areas being dominated by the weedy degradation indicator Mesembryanthemum hypertrophicum, while other areas appear to be less disturbed and may be dominated by grasses of perennial shrubs as illustrated below. Within the degraded areas dominated by Mesembryanthemum hypertrophicum, there is little other perennial cover, but the dead material present at the time of the site visit, suggests that the cover of Mesembryanthemum hypertrophicum and Mesembryanthemum barklyi as well as other annuals is likely to increase significantly following good rainfall. The less disturbed areas dominated by shrubs are composed of species such as the stem succulents Sarcocaulon patersonii, Sarcocaulon flavescens, Euphorbia gummifera, Brownanthus arenosus and Pelargonium carnosum; woody shrubs such as Salsola zeyheri, Galenia crystalina and Lycium horridum and Asparagus capensis; dwarf succulents such as Phyllobolus oculatus and Dracophilus dealbatus; and occasional grasses such as Stipagrostis ciliata and Stipagrostis obtusa. The south-east section of the development area contains a higher abundance of grasses, mainly Stipagrostis geminifolia with lesser amounts of Stipagrostis ciliata and Stipagrostis obtusa. The water supply line: The vegetation along the first section of the proposed pipeline route is similar to that within the development area, however as one drops in elevation and approaches the Orange River, the substrate changes and becomes more rocky, which results in changes in vegetation composition as well. A wider variety of succulents is present in the rocky sections and includes species such as Stoberia gigas, Psammophora modesta, Schlechteranthus hallii, Euphorbia gummifera, Euphorbia chersina and Brownanthus pubescens. The first section of the floodplain of the Orange River is not vegetated probably on account of the fact that the route runs adjacent to a livestock post at this point. Along the river the vegetation consists of Rhus lancea and Tamarix usneoides with some weedy and alien species such as Nicotiana glauca and Gomphocarpus fruticosus subsp. fruticosus. Despite the threatened status of the vegetation, the access point is not considered highly sensitive and the pump could be installed at the site with minimal damage to the vegetation. Overhead powerline The overhead power line to the Oranjemund substation runs through a series of low hills and broad valleys, mostly within the Western Gariep Lowland Desert vegetation type. The majority of the route is on fine gravel or loose sand and is grassier than the area around the development area. Cape EAPrac 38 Draft Scoping Report

55 Typical species include Stipagrostis dregiana. S.lutescens, S.shaeferi, Centropodia glauca and Cladoraphis cyperoides Listed and Protected Plant Species According to the SANBI SIBIS database, 337 indigenous plant species have been recorded from the two quarter degree squares 2816 DA and 2816 DB. This is a comparatively high total for such an arid area and illustrates the high diversity of the region. The total includes six species of high conservation concern and another 20 of moderate concern. This is a high proportion of listed species and highlights the potential sensitivity of the area. The majority of listed species are either succulents or geophytes. Although none of the listed species were observed within the proposed development area, it is possible that some of the geophytes are present as it was not possible to assess their presence at the time of the site visit as it was summer and the majority are only present in the winter and spring. In addition the power line route has not been finalised and it is highly likely that some of the listed species would be present along the route. In addition to the listed species, it also worth mentioning the presence of Euphorbia melanohydrata at the site. This species is considered an endangered species by Jurgens (2006) in his description of the vegetation of the area. It is however classified as Least Concern by the Red List of South African Plants. According to the SIBIS database it has been recorded from only one quarter degree square, 2817AC, northeast of the current site, within the Richtersveld National Park, but it is known from Namibia as well. Regardless, it is clear that this species is a narrow endemic and warrants some consideration. Within the development area this species was relatively common and it is possible that as many as several hundred plants would be affected by the development. At this point it is not clear how much more widely distributed the species is outside of the proposed development area. Euphorbia plants do not generally transplant well, so the most likely scenario would be the loss of individuals from the development footprint. The distribution of this species in and around the project site will need to be examined in the EIA phase to establish the extent of impact of the development on this species. It is important to note that a large proportion of the vegetation at the site is protected under the Northern Cape Nature Conservation Act of 2009, which includes all Mesembryanthemaceae, all species within the Euphorbiaceae. Oxalidaceae, Iridaceae, all species within the genera Nemesia and Jamesbrittenia as well as numerous others not listed here. Table 5: Summary of the conservation status of plant species known from the two quarter degree squares affected by the development IUCN Status Count Endangered 1 Vulnerable 5 Threatened 2 Near Threatened 5 Cape EAPrac 39 Draft Scoping Report

56 Rare 11 Declining 1 Data Deficient - Insufficient Information 1 Data Deficient - Taxonomically Problematic 1 Least Concern 310 Grand Total Critical Biodiversity Areas & Broad-Scale Processes The site falls within the planning domain of the Namakwa Biodiversity Sector Plan (Desmet & Marsh 2008). This biodiversity assessment identifies Critical Biodiversity Areas (CBAs) which represent biodiversity priority areas which should be maintained in a natural to near natural state. The CBA maps indicate the most efficient selection and classification of land portions requiring safeguarding in order to meet national biodiversity objectives. The CBA map for the area is depicted in the below figure and indicates that the proposed development area lies partly within an Ecological Support Area, while the majority of the power line route to the Oranjemund substation lies within a CBA. In addition to the CBAs, both the development area and power line route lie within NPAES focus areas. This indicates that the site has been identified as part of an extensive tract of unfragmented habitat of high biodiversity value within vegetation types that are not currently well represented within formal conservation areas. According to the conservation ethos development within such areas is not encouraged as it may compromise the resilience and biodiversity value of the focus area and ultimately impact the countries ability to meet its conservation targets. Figure 21: Critical Biodiversity Areas indicated for the study area Cape EAPrac 40 Draft Scoping Report

57 Apart from the CBA depicted above, there are some other important conservation areas present in the vicinity of the site. This includes the proposed expanded Orange River Mouth Conservation Area, Orange River Mouth RAMSAR site and Richtersveld World Heritage Site. It can be confirmed however that the site falls outside of the above conservation areas and it is not likely that the development would generate any direct impacts on these conservation areas Faunal Communities Mammals The site falls within the distribution range of 40 terrestrial mammals, indicating that the mammalian diversity at the site is of moderate to low potential. Within the development area itself, diversity is likely to be relatively low on account of the limited extent and low habitat diversity of this area. Diversity within the broader area which includes the water supply pipeline and power line would be higher on account the much greater diversity of habitats captured. Two listed terrestrial mammals may occur at the site, the Brown Hyaena Hyaena brunnea (Near Threatened) and Black-footed cat Felis nigripes (Vulnerable). Although the area is used for livestock production, human activity in the area is currently low and it is not likely that these species are actively persecuted. As a result, it is considered likely that these species occur in the area and may sporadically use the development area at least for foraging. These species do however have a wide distribution in the country and the loss of 200ha of habitat is not considered significant as this would not be enough area to support even a single individual of either species. Overall there do not appear to be any highly significant issues regarding mammals and the development of the site. In general the major impact associated with the development of the site for mammals would be habitat loss and potentially some disruption of the broad-scale connectivity of the landscape. Reptiles According to the SARCA database, 34 reptile species are known from the area suggesting that the reptile diversity within the site is likely to be moderate to low. Species observed at the site include the Spotted Desert Lizard Meroles suborbitalis and Giant Desert Lizard Meroles ctenodactylus. As there are no rocky outcrops within the proposed development area, species within this area are likely to be those associated with plains and sandy environments, while a greater diversity of species would be present along the power line route and water supply pipeline. Although there is only one listed species known from the area, this is of particular significance as the Namib Web-footed Gecko Pachydactylus rangei is listed as Critically Endangered. This species is associated with dune environments and as such it is highly unlikely that this species occurs within the proposed development area or along the water pipeline route. It is however possible that this species occurs along the power line route within the dune fields that occur en-route to the Oranjemund substation. Therefore, the power line is highlighted as potential concern regarding impact to this species. The footprint of the power line would be relatively low and it is possible that with greater investigation into the preferred habitat of this species along the route that avoidance or mitigation measures could be implemented to reduce or avoid impact to this species. Cape EAPrac 41 Draft Scoping Report

58 The construction of the solar panels with supporting structures and electrical connections would significantly alter the habitat structure within the development area as compared to the original open vegetation. This is likely to change the reptile composition within the affected area and species able to tolerate or utilise the novel conditions will increase at the expense of those species associated with the open vegetation. Functionally this is likely to represent an increase in geckos and other climbing species at the expense of diurnal ground-foraging species. This effect is likely to be of local extent and given that there are few listed species that might be affected within the development area itself, of relatively low significance as well. Amphibians Nine amphibian species are known from the area, including two listed species, the Desert Rain Frog Breviceps macrops and Namaqua Stream Frog Strongylopus springbokensis. The Desert Rain Frog is however restricted to coastal dunes and is not likely to be impacted by the development, while the Namaqua Stream Frog is associated with seeps and springs and as such is not likely to occur within the development footprint either. Given the aridity of the site and the lack of mesic features within the development footprint or along the power line route, impacts on amphibians are likely to be very low. It is possible that the pump station at the Orange River could impact amphibians, but given the limited footprint of this element of the development, this is not likely to generate significant impact. 8 PLANNING CONTEXT The following key components will likely take place from a planning perspective. Saunders (2014) provides a detailed report on the relevant planning requirements that may be relevant to the proposed project (refer to Annexure D7). A land use change application for the rezoning of 200ha, from Agricultural Zone I to Special Zone, will be lodged at the Richtersveld Local Municipality, in accordance with the Northern Cape Planning and Development Act (Act 7 of 1998). If there are restrictive Title Deed conditions burdening the proposed development, an application for the removal thereof will be lodged at the Government of the Northern Cape Province, Department: Corporate Governance and Traditional Affairs, in accordance with the Removal of Title Deed Restriction Act (Act 84 of 1967). Parallel to the rezoning application, a long term lease application will be lodged at the National Department of Agriculture, in accordance with the Subdivision of Agricultural Land Act (Act 70 of 1970). Relevant planning documents, on all spheres of Government, will be evaluated before any land use change application is launched. These documents include, but are not limited to the following: NSDP (National Spatial Development Perspective); PGDS NC (Provincial Growth and Development Strategy), Northern Cape Province; IDP (Integrated Development Plan); SDF (Spatial Development Framework). The town planning specialist will negotiate the best possible statutory process/program, submit the required land use application to all the relevant authorities, pay the application fees on behalf of the client, prepare notices and advertisements, place of adverts in the local newspapers, send registered letters, travel where required, etc. - this includes facilitation/submissions for comment/input and/or authorisation to among others the following competent authorities: Richtersveld Municipality for approval in terms of the relevant Zoning Scheme/LUPO; Cape EAPrac 42 Draft Scoping Report

59 Northern Cape Department of Agriculture as well as the National Department of Agriculture, Forestry & Fisheries (DAFF) for approval in terms of Act 70 of 70 (SALA) and Act 43 of 83(CARA); District Roads Engineer for comment on the land use application; Department of Water Affairs (DWA) for comment in terms of the National Water Act and the land use application; Department of Mineral Resources for approval in terms of Section 53 of Act 28 of 2002; Department of Transport & Public Works for comment on the land use application; South African Heritage Resource (SAHRA) Agency for comment on the land use application; Civil Aviation Authority for comment on the land use application; Eskom Northern Cape for comment on the land use application; and Northern Cape Nature Conservation for comment on the land use application. These same authorities have been registered as key stakeholders in the environmental process and as such were given an opportunity to provide comment on this Draft Scoping Report. 9 AGRICULTURAL POTENTIAL STATEMENT Mr Christo Lubbe, an agricultural specialist, undertook an agricultural potential study of the proposed Richtersveld Solar Farm from which the following is drawn. The proposed 200ha study site will occupy an estimated 1.6% of the total cadastral unit of roughly ha. A full copy of the agricultural potential study is attached in Appendix D, Annexure D2 of this report. 9.1 OBJECTIVES The objectives of the agricultural potential study were: To evaluate the possibility of impacts on agricultural production that may result from the development of the renewable power station. To consider the necessity of conducting a full agricultural study. 9.2 APPROACH AND METHODOLOGY The methodology applied by the agricultural specialist included a desktop study as well as a field investigation as described below Desktop Study A desktop study was conducted to review existing data and literature sources. The desktop review provided a baseline agricultural and land use profile, focusing on the specific geographical area potentially impacted by the proposed project Field Investigation The site was visited by the specialist and a field survey was carried out. Potential impacts of the proposed project on agriculture were identified with particular attention to the following issues: The possibility of permanent loss of high potential agricultural land; Impairment of land capability due to construction; Cape EAPrac 43 Draft Scoping Report

60 Analysis of erosion risk because of altered drainage patterns and poor rehabilitation in erosion-sensitive areas; and Veld conditions for grazing. 9.3 ASSUMPTIONS AND LIMITATIONS As far as regional information is concerned, this is primarily a desktop-based study. Climatic conditions, land uses, land type and terrain are readily available from literature, GIS information and satellite imagery. Notwithstanding these limitations, the site-specific field studies confirmed most of the desktop findings. The specialist however confirmed that he is confident that the findings provide sufficient detail for the agricultural potential study reported in the study Past and Current Agricultural Activities on Site The sites are currently utilised for extensive goat and sheep farming. There is no evidence of past or current cultivation Agricultural Structures on site The only structures near, but not on the site are a borehole, windmill and water storage facilities Agricultural study findings Veld Condition Assessment A veld condition assessment was done, by visual acknowledgement and random sampling on 1m² grids. The outcome of the veld condition assessment is shown in the below table. Table 6: Veld condition assessment outcome of the study site ASSESSMENT CATEGORY FINDING SCORE PLANT COVER Plant cover very sparse with large bare areas 1 COMMON GRASSES Mainly poor grazing grasses very scarce Karoo succulents SURFACE CONDITION Moderate levels of top soil loss 3 BUSH ENCROACHMENT No encroachment present 10 SOIL TYPE Sandy soil 2 TOTAL 17 1 With a score of 17/80 and rainfall of only 200 mm per annum, the veld condition very poor with a grazing capacity of 110 ha/lsu Water Availability/Provision Currently, water is provided to livestock from boreholes pumped by windmills and stored in reservoirs and troughs. The borehole does not appear to be working. For the proposed Power Plant, a new water pumpline from the Orange River is intended along the existing access tracks to the solar site. Cape EAPrac 44 Draft Scoping Report

61 Land Capability and Suitability for agriculture Land capability is classified as non-arable low potential grazing land. The site is largely unsuitable for cultivation due to the following limiting factors: Low annual rainfall, high evaporation and extreme temperatures restrict dry land cultivation. The very shallow soil depth (60% of area)with its limited water holding capacity restricts root development The very fine sand grade of top soil influences the stability and increases Erodability potential. Low clay percentage results in low water holding capacity and low nutrient availability, resulting in low soil fertility. Saline soil restricts productivity and choice of crops. 9.4 IDENTIFICATION OF POSSIBLE IMPACTS ON AGRICULTURAL POTENTIAL Possible impacts on the agricultural environment that need further investigation include the following: Impairment of land capability due to construction; Erosion risks caused by altered drainage patterns resulting from construction Deterioration of veld conditions due to clearing of vegetation for construction of the plant and access roads and stockpiling of building material Diversion of natural water runoff. Loss of natural grazing, although it is known as low capacity grazing land. The possibility of losing high potential agricultural land needs not further investigation, since the area is generally known in agricultural and other circles as land on of low capability and potential. Further investigations are required to assess the possible impacts mentioned in the previous paragraph. These investigations should include: A field survey, including a soil survey, to verify the desktop study findings A study of current drainage patterns on site and the compilation of a water runoff plan for the site during and after the construction process. 10 ECOLOGICAL SENSITIVITY ANALYSIS The development area is considered to be of relatively low sensitivity, and at this point, the only sensitive feature identified is the presence of the narrow endemic Euphorbia melanohydrata within the site. While overall diversity within the site is relatively low, the site is located within an area that is essentially wilderness and the development would significantly impact the wilderness value of the area and potentially the connectivity of the landscape as well. The overall extent of the development is however relatively small and so impacts on broad-scale processes are not likely to be of high significance. Perhaps the greatest concern regarding the development of the site would be the effective implementation of mitigation measures. Given the aridity of the site, any soil disturbance can be considered more or less permanent and it is unlikely that the vegetation in disturbed areas would recover within a reasonable period of time. Therefore, extreme caution would need to be exercised to ensure that the development footprint is kept to a minimum and that areas outside of the final development area are not disturbed. This is especially important given the strong winds Cape EAPrac 45 Draft Scoping Report

62 the area experiences and the likelihood that disturbance in the area would encourage wind erosion. Therefore, specific measures would need to be taken to ensure that the substrate within the facility is stabilised and that there is not a large amount of bare ground present around the fringes of the facility. The mobilisation of loose sand would have an impact on the surrounding vegetation but would also potentially compromise the efficiency of the PV or CPV panels through sandblasting. This is an important aspect that should be addressed by the developer as it has the potential to compromise the viability of the development POTENTIAL IMPACTS Based on the results of the abovementioned ecological sensitivity analysis, the following impacts have been identified as the most significant potential impacts likely to be associated with the development of the Richtersveld Solar Farm facility: The development will result in a variety of impacts, associated largely with the disturbance, loss and transformation of intact vegetation and faunal habitat to hard infrastructure such as PV arrays, roads, operations buildings etc. The following impacts are identified as the major impacts that are likely to be associated with the development and which will be assessed during the EIA phase of the development, for the preconstruction, construction and operational phases of the development. The potential significance of these impacts is contained in the fauna and flora scoping report (annexure D1) but will only be assessed in detail during the EIA phase. Preconstruction Phase Activities Human presence and uncontrolled access to the site may result in negative impacts on fauna and flora through poaching of fauna and uncontrolled collection of plants for traditional medicine or other purpose. Site clearing & exploration activities for site establishment would have a negative impact on biodiversity if this was not conducted in a sensitive manner. Construction Phase Activities Vegetation clearing for the PV/CPV arrays, access roads, site fencing etc could impact listed plant species as well as high-biodiversity plant communities. Vegetation clearing will also lead to habitat loss for fauna and potentially the loss of sensitive faunal species, habitats and ecosystems. Increased erosion risk would occur due to the loss of plant cover and soil disturbance created during the construction phase. This may impact adjacent communities as the sand can smother vegetation and generate additional sand mobilisation and wind erosion. Presence and operation of construction machinery on site. This will create a physical impact as well as generate noise, pollution and other forms of disturbance at the site. Increased human presence can lead to poaching, illegal plant harvesting and other forms of disturbance. Operational Phase Activities The operation of the facility will generate noise and disturbance which may deter some fauna from the area. Cape EAPrac 46 Draft Scoping Report

63 The areas inside the facility will require management and if this is not done appropriately, it could impact adjacent intact areas through impacts such as erosion, alien plant invasion and contamination from pollutants, herbicides or pesticides. Overhead power lines will pose a risk to avifauna susceptible to collisions and electrocution with power line infrastructure IMPACTS TO BE ASSESSED The development will result in a variety of impacts, associated largely with the disturbance, loss and transformation of intact vegetation and faunal habitat to hard infrastructure such as PV arrays, roads, operations buildings etc. The following impacts are identified as the major impacts that are likely to be associated with the development and which will be assessed during the EIA phase of the development, for the preconstruction, construction and operational phases of the development. Preconstruction Phase Impacts on vegetation and protected plant species Preconstruction activities such as geotechnical investigations, access road construction or other unauthorised vegetation clearing may have a negative impact on vegetation and listed species. As protected species are widespread at the site this is a highly likely impact associated with the development, it will be assessed for the preconstruction phase. Impacts on fauna during the preconstruction phase Uncontrolled access to the site and preconstruction activities may be detrimental to fauna. Poaching of susceptible species may occur as a result of increased access to the site and site clearing or disturbance with heavy machinery may also result in mortality of fauna unable to avoid the disturbance. As this is a possible outcome of the development it will be assessed. Construction Phase Impacts on vegetation and protected plant species There are a number of local endemic and protected species present at the site and it is highly likely that some of these would be impacted by the development. The loss of currently intact habitat resulting from site clearing within the development footprint is an inevitable consequence of the development. This impact is certain to occur and will therefore assessed for the construction phase, for the facility and for the grid connection. Soil erosion and associated degradation of ecosystems The large amount of disturbance created during construction would potentially leave the site vulnerable to soil erosion. Strong winds are known to occur regularly in the area and may generate dust storms and cause soil loss. Soil erosion is therefore considered a likely impact and will be assessed for the construction phase. Direct faunal impacts Increased levels of noise, pollution, disturbance and human presence during construction will be detrimental to fauna. Sensitive and shy fauna would move away from the area during the construction phase as a result of the noise and human activities present, while some slow-moving species would not be able to avoid the construction activities and might be killed. Some mammals and reptiles would be vulnerable to illegal collection or poaching during the construction phase as a Cape EAPrac 47 Draft Scoping Report

64 result of the large number of construction personnel that are likely to be present. Some impact on fauna is highly likely to occur during construction and this impact will therefore be assessed for the construction phase. Operational Phase Direct faunal impacts During the operational phase of the development, interactions between fauna and the infrastructure of the facility may generate negative impacts on fauna. Possible impacts include electrocution of fauna such as tortoises along electric fencing around the facility, or the persecution or poaching of fauna within and around the facility. As there is a possibility that this impact would occur, it will be assessed for the development. Avifaunal Impacts Due to Power Lines Large raptors and many larger bird species such as cranes and bustards are vulnerable to collisions with or electrocution from power line infrastructure. This can be a particular problem if the power line lies within the movement or migration pathway of the birds. As many of the vulnerable species are long-lived slow-breeding species, collisions with power lines can be a major source of mortality for such species and may threaten the viability of local or regional populations. Insulating electrical components and fitting bird flight diverters can provide some mitigation against such impacts and is recommended as standard practice for new power line infrastructure. It important to note with regards to power line impacts that even if the impact at any one moment in time is low, it is the cumulative long-term impact which can generate significant impact. This impact is associated with the grid connection only and will be assessed separately for that component of the development. Cumulative impacts Reduced ability to meet conservation obligations & targets The loss of unprotected vegetation types on a cumulative basis from the broad area may impact the countries ability to meet its conservation targets. Although the receiving vegetation types in the study area are classified as Least Threatened and have been little impacted by transformation, the site lies within a NPAES Focus Area. This may compromise the countries ability to meet its conservation targets in the long-term. The vegetation types in the area are not extensive the opportunities for finding alternative similar habitat elsewhere is limited. Impact on broad-scale ecological processes Transformation of intact habitat on a cumulative basis would contribute to the fragmentation of the landscape and would potentially disrupt the connectivity of the landscape for fauna and flora and impair their ability to respond to environmental fluctuations. Due to the currently un-impacted nature the area, this is a possible cumulative impact of the development that will be assessed CONCLUSION & PRELIMINARY RECOMMENDATIONS Although the plant diversity at the site appears to be relatively low, the development is located within and intrinsically sensitive environment. The presence of Euphorbia melanohydrata is highlighted as a potential concern as this species is not widely known from the area. Furthermore, as the area is currently in a largely natural state with a low level of transformation, the potential disruption of landscape connectivity and a decline in the value of the area for future conservation use are highlighted as a further potential concern associated with the development. The site lies within an NPAES Focus Area and the development would contribute to transformation Cape EAPrac 48 Draft Scoping Report

65 and loss of ecological value within the affected Focus Area. Due to the heterogeneity of the area, there are not a lot of options available in terms of finding alternative intact areas to compensate for the loss of the developed area. The area also reportedly experiences very strong winds with dust storms and the disturbance at the site during construction will certainly increase the likelihood of wind erosion at the site. The impact of wind erosion may spread beyond the site as the mobilised sand may smother plant communities, which then itself propagates further sand movement and wind erosion. The hyperaridity of the area also means that it is unlikely that plants can be easily established in disturbed areas and so the options for reducing the wind erosion potential of disturbed areas is limited and within the facility itself, means of artificially covering or binding the soil will need to be investigated, especially as sand movement would be highly undesirable in the vicinity of the facility. The length of the proposed power line is highlighted as an additional concern associated with the development. Ideally, the power line should run as close to the existing Eskom power line to the Oranjemund substation as possible. This would reduce the terrestrial footprint of the power line as the same service road could be used and it would also reduce the likelihood of additional collisions of avifauna with the new line. The potential for impact on the Critically Endangered Namib Web-footed Gecko Pachydactylus rangei is highlighted as a particular concern and the likely distribution of this species in the area should be established before the route of the power line is finalised. Should it be likely that this species would be affected by the new power line, then a route along the main road should be investigated as an alternative, albeit slightly longer route option. The water extraction point and water pipeline are likely to generate relatively low impacts compared to other aspects of the development and with the appropriate mitigation the impact of this element of the development is likely to be low. In terms of the two technology options for the development, that is the PV/CPV hybrid vs the pure PV option, there is little difference in terms of their likely ecological impact. The total footprint of each appears to be the same and there does not appear to be any significant difference in the amount of construction-related disturbance that will accompany each technology. In both cases a similar amount of disturbance and habitat loss will be generated and therefore, from an ecological point of view, there does not appear to be preferred option in this regard. 11 HERITAGE CONSIDERATIONS A preliminary desktop heritage scoping study for the proposed Richtersveld Solar Farm was undertaken by Townsend (2014) with reference to archaeology (Hart 2014) and paleontological aspects as well. A full copy of this study is attached in Annexure D3 of this report. The following key points are drawn from this report: 11.1 PURPOSE OF STUDY The heritage scoping report is focused on the proposed development footprint alternatives of the solar energy facility with all associated infrastructure Heritage features of the region Members of the Richtersveld community recently successfully contested the State Diamond Mine occupation of ancestral land with result that the Richtersveld Community Property Association now has control of vast tracts of land on the Namaqualand coast including the and stretching inland as Cape EAPrac 49 Draft Scoping Report

66 far as Vioolsdrift. Historically, almost all of this land was the territory of the Nama herders, a Khoekhoen descendent community with roots in the area as long as 2000 years ago. Figure 22: The character of the site is unfragmented and situate in the flatlands The solar site is situated in proximity to the Richtersveld Word Heritage Site, however following correspondence with the Department of Environmental Affairs and input from the heritage specialist, it was confirmed by the Department that the site does not fall within the core conservation or the buffer area of the World Heritage Site (WHS). Figure 23: Location of site in context to the Richtersveld Natural and Cultural landscapes Cape EAPrac 50 Draft Scoping Report

67 Due to the proximity of the site to known cultural/heritage features, the necessary input and guidance from relevant heritage authorities is considered important. Both the South African National Heritage Association (SAHRA) as well as the Northern Cape Heritage Authority have been registered as key stakeholders and their comment will be important. Figure 24: Location of the site in context to Richtersveld World Heritage Site and its buffer areas (note that the site falls outside of the core and buffer areas) Pre-Colonial Heritage Although little has been formally researched until relatively recently, the existence of shell middens on the coast of Namaqualand has been known since the 18 th century travels of Robert Jacob Gordon. In August 1779 Gordon commented on the many shells and the remains of huts that littered the dunes (Cullinan 1992). In the early years of the 20 th century Winifred Hoernlé (Carstens et al. 1987) also visited the area remarking on the archaeology present. In her diary she remarks that all along the river there are evident signs of Bushman occupation for their shells are to be found in heaps on every side while here and there a piece of pot crops up too (Carstens et al. 1987:65). She comments that middens are plentiful along the shore but that nothing of interest is found on them. Recent heritage impact assessments along the Namaqualand coast have revealed just how remarkably rich the pre-colonial archaeology is, and that many middens do indeed contain nothing but shell and the occasional quartz flake (Halkett 2003; Orton 2005, 2007b; Orton & Halkett 2005, 2006; Webley, in prep.). Many thousands of shell middens occur, with some containing a rich array of finds including stone artefacts, pottery, bone tools, ostrich eggshell beads and animal bones. Human burials occur widely and along the coast are completely unmarked. They are seldom found by archaeologists with the vast majority being dug up during diamond mining. Hoernlé (Carstens et al. 1987) also remarks on burials. She found a skeleton eroded out onto the surface near Kortdoorn and saw many stone-covered mounds along the river which she suspected to be graves. Upon excavating one of them she found a skeleton lying on its left side with the knees brought up beneath the chin. The skeleton was 5 feet below the surface and covered with three large, flat Cape EAPrac 51 Draft Scoping Report

68 stones. ACO has also recovered a number of burials from un-marked contexts in mining concessions. Since the advent of heritage management and conservation programs ahead of diamond mining in coastal Namaqualand, academic research has also commenced.. A doctoral thesis has been completed (Dewar 2007) and published (Dewar 2008) and another has been recent completed by (Orton 2013). An earlier thesis examined mainly inland sites but also included the very important coastal site of Spoeg River Cave (Webley 1992b). Several academic journal articles have also been produced concerning coastal and near-coastal sites (Dewar et al. 2006; Dewar & Jerardino 2007; Jerardino et al. 1992; Orton 2007c, 2008; Orton et al. 2005; Webley 1992a, 2002, 2007). With archaeological research in Namaqualand being so youthful every contribution is valuable. Further inland, both in the Richtersveld and in central Namaqualand, research has been underway for slightly longer, primarily through the efforts of Lita Webley (1984, 1986, 1990, 1992b, 1997, 2001, 2007; Brink & Webley 1996; Miller & Webley 1994; Webley et al. 1993) but including contributions by Smith et al. (2001) and Orton and Halkett (in press; Orton 2007a). It has now been established that the archaeology of Namaqualand is long and complex, covering the entire time span between up to a million years ago to the present day. The archaeology of the last 5000 years is particularly interesting with human occupation of these arid areas pulsing with variations in climate. Namaqualand boasts possibly the longest unbroken record of human settlement in that Nama speaking herders who practise traditional lifestyles in the area are immediate descendants of Khoekhoen populations who first introduced stock keeping and ceramics making into southern Africa more than 2000 years ago Colonial Heritage The following account of activities in the Richtersveld area during the historical period is compiled from Carstens et al. (1987), Davenport (2010), Fleminger (2008) and Williamson (2000). The first travellers to the Gariep River included elephant hunters such as Jacobus Coetzee in The earliest European penetration of the Richtersveld via the coastal route was by William Paterson and Colonel Gordon in Dr E Richter, an inspector of the Rhenish Mission Society, visited the area in The area was subsequently named after him. A mission station was established at Kuboes in the mid-19 th century. Captain James Edward Alexander (geographer and explorer) visited the Sendelingsdrift area in 1837 and prospected for copper at Kodas. He explored the south bank of the Gariep from the mountains of the Richtersveld to the sea, and proposed transporting copper down the Gariep River by barge to the mouth, and then by ship to Europe. There is an inscription to this effect at the Baaken mine. A few years later, on 21 March 1846, the South African Mining Company was formed. They sent Thomas Fannin to the Gariep River to survey the area and begin mining the copper deposits. He started an open cast mine that is now thought to be the oldest commercial mine in South Africa. Although the ore was rich and the progress good, the company faded away, probably due to logistical difficulties, the harsh environment and the lack of finance. In 1847 the British extended their control to the Gariep River and the Richtersveld was included in the Namaqualand district. By the 1890s, the inhabitants of the Richtersveld demanded clarity regarding their ownership of the land. Eventually in 1934 a formal ticket of occupation was issued by the government giving the indigenous groups communal rights to the land which was technically still held in trust by the state. The Richtersveld then became a coloured reserve under a management board. It is interesting that although copper was mined in the mid-19 th century by the colonists and long before that by the prehistoric inhabitants of the area (Goodwin 1956), diamonds were only discovered by Europeans in the early 20 th century. In 1908 Dr Bernhard Dernburg discovered diamonds in southern Namibia (Davis 2008) and the area became known as the Sperrgebiet. Earlier, someone called Pohle had been the first to recognise the potential for finding diamonds in the Gariep River. He had reasoned that since the river ran past the Kimberley diamond fields it must be carrying the gems downstream, but his limited prospecting yielded no result (Coetzer Cape EAPrac 52 Draft Scoping Report

69 1997). It was only in 1925 that the first Namaqualand diamond was discovered. It came from a site 10.5 km south of Port Nolloth and was found by Jack Carstens on 15th August using very rudimentary techniques (J. Carstens 1962; P. Carstens 2001). He continued his work to the south, since his father had found nothing around Alexander Bay while prospecting between 1899 and Subsequently, in November 1926, Dr Ernst Reuning, a geologist employed by Dr Hans Merensky, found the first diamonds at Alexander Bay (P. Carstens 2001). It was near the ruins of an old stone house used in the 1830s by Alexander as a copper store that Merensky noted an outcrop of shingle containing oysters. He had earlier noted the co-occurrence of oysters and diamonds to the south and set Reuning to work at that location. This spot was at the northern end of the so-called Oyster line which was a very rich source of diamonds. Earlier, a solicitor from Springbok named Israel Gordon, his two brothers and two others had first found diamonds near Alexander Bay. On 28 th December 1926 Reuning and Merensky visited their claims and came to an agreement with the Gordon syndicate for 6 months of work on their claims but within a few days made a formal offer to purchase the property. This was accepted and Merensky obtained it for Merensky then appealed to the state to prevent public digging at Alexander Bay and on 22 February 1927 the government banned prospecting on Crown land and, amidst much wheeling and dealing, began planning the establishment of the state diggings there (Rudd & Watson 1956 in P. Carstens 2001). It took over all mining operations there in 1928 (Keyser 1972). This was later to become the Alexcor or State Diamond mines. After almost a century of mining, the Richtersveld community, compromising mainly people of Nama origin, once again obtained their rights to the land Living Heritage: The Nama Historical accounts up until 1913 suggest that Nama-speakers were living very much like their ancestors of centuries before. The Nama-speaking inhabitants of the region follow a seasonal transhumant cycle. This means that they are not nomadic but tend to use a specific area on a seasonal basis. There is no clear indication of specific boundaries, and early traveller s record meeting with Nama groups as far south as Steinkopf. While pastoralism did allow for larger herder settlements, historic accounts suggest that the dry Northern Cape could not support the group sizes of several hundred observed further to the southwest. Since population density was low, there was little competition for land. Villages or kraals were cantered on certain important water holes - the presence or absence of water was the first consideration when planning a move to a new area. Certain families, through time, come to be associated with a certain area. Each herder settlement consisted of male members of the same patri-clan, with their wives and children. All the settlements (or kraals) in a given area were often part of the same tribal structure, owing allegiance to the most senior member or captain. These chiefs decided, together with senior members of the village on when and where to move, and they gave permission to outsiders who wished to enter their area to use their resources. However, ultimately, economic survival depends on flexibility and reciprocity. The definitive account of the social organisation of the Nama-speaking Khoekhoen is that of Winifred Hoernle who travelled through the region in 1912 and 1922/3. Khoekhoen society emphasized various rituals which took place at times of transition in an individual s life, such as birth, puberty, marriage and death. Water was associated with the concept of!nau (danger or vulnerability) which occurred during these periods of transition. Water was therefore used in many ceremonies, including that of rain making, initiation, birth, etc. Men and women had different tasks in ceremonies and in society. Interestingly, there are many indications that women exerted considerable authority within the household but they could also own and inherit stock and on rare occasions become regents or temporary chiefs. The villagers of Kuboes, for example, moved to the Gariep River in summer and to a variety of winter locations such as Springklip and Jakkalsputs. This type of information, which is readily available, can assist when interpreting archaeological deposits and determining prehistoric seasonal patterns. Cape EAPrac 53 Draft Scoping Report

70 While resources were often shared, there was also the understanding that certain groups or individuals had rights to particular resources (such as a honey nest) and that permission had to be obtained to use them. Ethno-botanical research by Archer (1994) has focused on the indigenous plant use of the descendants of the Nama-speaking Khoekhoen of the area. Knowledge on plant resources has declined during the 20 th century and it is only the rural poor who use plants to supplement their diet, for medicinal purposes and in domestic architecture. She has identified at least 75 different, edible plant species many of which are used by children as snacks. At least 45 different plants are used as medicines, some are common knowledge while others are only used by herbalists and healers. At least 22 different plants are used for utilitarian purposes including the construction of the traditional matjiesbuis, in leatherwork, in making soap and in making household items. The original inhabitants of the area (the San and the Nama) spoke related but different languages. San is no longer spoken although some 6000 Nama speakers are still found in the Northern Cape. The South African San Institute (SASI) was founded in 1997 to research and protect the rights of indigenous minorities like the Khoe and San. During land claims investigations, SASI discovered 11 fluent southern San speakers in the Northern Cape, meaning that this language is effectively extinct. Crawhall, a sociolinguist who works for SASI has identified 6000 Nama speakers and has been concerned with the continued survival of this language. Today there is dissent among the members of the Richtersveld community as the recent awarding of land to the indigenous inhabitants has created a plethora of management and leadership problems in a community who survival has depended very old traditional values for hundreds of years. Within the Study Area today is evidence active or recently active stock posts. Although the matjiehuisies are no longer built of traditional materials, they are rendered in modern materials and the style and size of the encampments follow traditional form. The stock posts are actively used indicating the people are practising traditional herding activities in the area today. Figure 25: A Nama stock post close to the study area In summary, the heritage survey revealed that the proposed site is of minimal heritage significance in terms of archaeology. All of the archaeological occurrences consist of thin scatters of flaked and fractured quartz without associated organic material. Formal artefacts were not noted and the material itself is a-diagnostic in terms of assigning secure cultural affiliations. Only one archaeological site of medium significance was recorded. This consisted of a spatially intact quartz scatter and an associated broken ostrich eggshell. This little site is easily mitigated through archaeological collection if the development proposal is approved. Cape EAPrac 54 Draft Scoping Report

71 A single Nama shelter was recorded in the study area. This consisted of a small brush windbreak and covering of brush supported on small poles. The presence of a few rusty tins indicates that it was probably erected a few years ago and had been recently occupied Impact on power lines No archaeological sites of any kind were noted on any of the proposed power line alternatives. Proximity to water was such a critical issue in this landscape, that the majority of archaeological sites were located within 1 km of the permanent waters of the Gariep River Paleaontology According to the SAHRA palaeontological sensitivity overlay (Figure 5) the study area lies with the blue zone indicating that the proposed project area has very low palaeontological sensitivity. No paleontological impact assessment is required. Figure 26: The palaeontological sensitivity map produced by SAHRA indicates that the study area lies in the dark blue zone which has very low palaetontological sensitivity (Townsend 2014) 11.2 RECOMMENDATIONS FOR FURTHER HERITAGE STUDY The proposed activity will require some levelling of the terrain, possibly piling and casting of foundations. These are all factors that are potentially dangerous for context sensitive heritage. The baseline study has indicated that within the site and on the power line alternatives, there is no palaeontology sensitivity and those archaeological sites that do exist are of low significance. In these terms the site is suited to the proposed activity. The impact of the proposed activity will depend on what alternative is favoured for the solar facility the larger it is the greater the impact albeit that indications are that the archaeology of the area is of low significance. 12 VISUAL CHARACTER AND IMPACT According to the visual specialist who will be undertaking the detailed visual impact assessment of the proposed Richtersveld Solar Farm development the dominant visual characteristics of the site s context include: Cape EAPrac 55 Draft Scoping Report

72 The flat expanse of the site situated within the area between the Orange River and the local mountains, Grootberg and Springklipberg to the east of the site; Undulating landforms adjacent to sections of the Orange River, notable the low depression area north west of the site; The framing mountains, Grootberg and Springklipberg, the backdrop of the Richtersveld National Park mountains and an isolated mountain to the south of the site; A low indigenous vegetation, to a maximum height of approximately 0.7m; No building in the immediate context and an absence of residence usage in context; Existing infrastructure within immediate context: Trans Hex Diamond mine, sub stations, power line, gravels roads and tracks; Lower level of the gravel public roadway running adjacent to the Orange River and therefore a lack of visibility of the site from the public roadway; Distant Namibian mountains to the north; Lack of visibility of the Orange River from the site; Level terrain of the site; The continuous mountain ranges to the south and east towards the Richtersveld National Park KEY VISUAL ISSUES Although the site is situated outside the buffer area of the proclaimed World Heritage Site (WHS), Richtersveld National Park, in context (6km) to existing infrastructure node situated along the Orange River (roadway, two sub stations, diamond mine and powerlines) and over 12km from the nearest residents on farm, Brandkaros, the site and its context does have a high scenic and aesthetic value. Figure 27: Viewshed analysis for the proposed solar facility with associated infrastructure Cape EAPrac 56 Draft Scoping Report

73 The preliminary visual investigation has identified the key visual sensitivities for the proposed Richtersveld Solar Farm, in addition to its construction and operational activities: World heritage site Ai- Ais/Richtersveld National Park; WHS buffer area; Users of the public roads; Settlements, such as the closest town, Sanddrift; Residents of farms in context to the proposed facility. The more detailed impact assessment phase will determine the level of visual impact of the proposed SEF on the adjacent WHS and buffer area, public road users, in addition to residents and visitors to the area. The assessment phase will determine the degree of change on the character of the site context. A copy of the visual baseline investigation can be viewed in Annexure D5 of this DSR. 13 SUMMARY OF SITE CONSTRAINTS The following site-specific constraints and/or key impacts were identified by various specialists during this scoping / baseline phase of the environmental process. These constraints / key impacts will be used to further refine the proposed solar facility layout, as the potential impacts associated with them will be and recommendations to avoid and/or mitigate impacts are provided during the on-going environmental process SOCIO-ECONOMIC Opportunity for employment, skills training and transfer (short term and long term); Housing and accommodation for construction and operational employees; Addressing existing socio-economic challenges of the area; Investment into a local economy that is otherwise declining FLORA: Protected plants species and communities; Potential for fragmentation of otherwise unfragmented environment; Potential impact on long term conservation goals for the area; Wind erosion with indirect impacts on surrounding environment FAUNA: Potential collision and electrocution from power-line infrastructure; Endangered reptilian species that could be affected AGRICULTURAL POTENTIAL: No specific constraints in terms of agricultural potential were identified 13.5 HERITAGE: Impact on the character and sense-of-place; Protection of existing archaeological sites VISUAL: Proximity to the World Heritage Site and Richtersveld National Park. Cape EAPrac 57 Draft Scoping Report

74 Potential impact on sense-of-place and visual character affecting visitors and residents of the area. 14 PUBLIC PARTICIPATION PROCESS TO DATE As part of the public participation process the following steps were taken to ensure compliance with the legislation and to allow ample opportunity for members of the public and key stakeholders to be involved and participate in the environmental process. Please see Appendix E for evidence of this Public Participation process. The Public Participation Process has been undertaken according to the requirements of the new NEMA EIA regulations. The following requirements i.t.o the scoping process have been undertaken and complied with in terms of Regulation 56: Table 7: Overview of process followed to date CHRONOLOGY OF EVENTS ACTION 1 Notification was sent to the respective land owners potentially affected by this development. 2 Notifications were sent to neighbouring landowners informing them of the development proposal and the environmental process. They were automatically registered as Interested and Affected Parties 3 The District Municipality and the Richtersveld Local Municipality (which have jurisdiction over the area) were notified and automatically registered as key stakeholders. 4 Organs of state (including SANParks, Northern Cape Nature Conservation, Department of Agriculture, Forestry & Fisheries, Department of Minerals and Energy, Department of Water Affairs, SAHRA, Eskom, Civil Aviation Authority etc.), were notified and registered as key stakeholders. 5 Advertisements were placed in a local newspapers, calling for stakeholders to register as Interested & Affected Parties 6 A Background Information Document (BID) was compiled and distributed to registered stakeholders to initiate initial comment (copy included as Appendix H). 7 Notice Boards were placed at the Port Nolloth Municipality and Port Nolloth Library. 8 A Stakeholder Register was opened and the details of all registered stakeholders entered for future correspondence. 9 Authority consultation took place in the form of a meeting with the Provincial Department of Environmental Affairs to discuss the project and gather initial comment (Springbok office). 10 Authority consultation took place in the form of a meeting with the Richtersveld Municipality to discuss the project and gather initial comment (Port Nolloth). 9 Hard copies of the Draft Scoping Report (DSR) have been placed at the Port Nolloth Municipality offices and the Port Nolloth Library, to inform the public of the proposal and EIA process, and invite them to review the document and provide comment. The DSR has also been made available on the Cape EAPrac website: 10 Registered Stakeholders and I&APs were sent notifications informing that of the availability of the DSR for a review and comment period of 40-days. All comments received on the Draft Scoping Report will be captured and responded to. comments and responses will be included in the Final Scoping Report (FSR). All Cape EAPrac 58 Draft Scoping Report

75 Figure 28: Proof of notifications placed at the Port Nolloth Library (left) and Richtersveld Municipal office (right) 15 ASSUMPTIONS & LIMITATIONS This section provides a brief overview of specific assumptions and limitations having an impact on this environmental application process: It is assumed that the information on which this report is based (specialist studies and project information, as well as existing information) is correct, factual and truthful. The proposed development is in line with the statutory planning vision for the area (namely the local Spatial Development Plan), and thus it is assumed that issues such as the cumulative impact of development in terms of character of the area and its resources, have been taken into account during the strategic planning for the area. It is assumed that all the relevant mitigation measures and agreements specified in this report will be implemented in order to ensure minimal negative impacts and maximum environmental benefits. It is assumed that due consideration will be given to the discrepancies in the digital mapping (PV panel array layouts against possible constraints), caused by differing software programs, and that it is understood that the ultimate/final positioning of solar array will only be confirmed on-site with the relevant specialist/s. The Department of Water Affairs may consider the submission of a water use application necessary for allowing the use of water. It is not the Applicant s intention to introduce any infrastructure, or carry out any activity listed under Section 21 of the National Water Act (Act 36 of 1998) in any area which may be deemed to be a watercourse, as defined in said Act.. The assumption is made that on review of this Draft Scoping Report the Department of Water Affairs will provide confirmation and recommendations in this regard. It is assumed that Stakeholders and Interested and Affected Parties notified during the initial public participation process will submit all relevant comments within the designated 40-days review and comment period, so that these can included in the Final Scoping Report can be timeously submitted to the delegated Authority, the Department Environmental Affairs for consideration. Cape EAPrac 59 Draft Scoping Report