Proposed Windhoek - Gocheganas Road upgrade. Environmental Assessment Scoping Risk Report

Transcription

1 Proposed Windhoek - Gocheganas Road upgrade Environmental Assessment

2 COPYRIGHT ENVIRO DYNAMICS, ALL RIGHTS RESERVED PROJECT NAME STAGE OF REPORT CLIENT LEAD CONSULTANT DATE OF RELEASE AUTHOR MAPPING FORMATTING, EDITING INTERNAL REVIEW Environmental Assessment Proposed Windhoek- Gocheganas Road upgrade Environmental Roads Authority Enquiries: Mumba, Vitumbiko Tel: Enviro Dynamics cc Enquiries: Quzette Bosman Tel: +264 (0) Quzette Bosman Eddy Kuliwoye Sigi Horsthemke Internal Reviewer: Stephanie van Zyl

3 i ENVIRONMENTAL ASSESSMENT PRACTITIONER DECLARATION I hereby declare that I do/will: (a) Have knowledge of and experience in conducting specialist assessments, including knowledge of the Environmental Management Act (Act 7 of 2007) and the Regulations and Guidelines that have relevance to the proposed activity; (b) Perform the work relating to the application in an objective manner, even if these results in views and findings that is not favourable to the applicant; (c) Comply with the abovementioned Act, its Regulations, Guidelines and other applicable laws. I also declare that there is, to my knowledge, no information in my possession that reasonably has or may have the potential of influencing (I) any decision to be taken with respect to the application in terms of the Act and its Regulations; or (ii) The objectivity of this report, plan or document prepared in terms of the Act and its Regulations. Quzette Bosman Environmental Assessment Practitioner

4 ii Table of Contents Table of Contents... ii Abbreviations & Acronyms...iii List of Figures... iv List of Appendices... iv 1. Introduction Purpose of Report Application for an Environmental Clearance Certificate Environmental Impact Assessment Requirements Sensitivities Project Description Overall Project Phase 1: A new road section between Gocheganas and Windhoek Need and Desirability Alternatives Public Participation Conducted to date Printed Media Background Information Document Newspaper Advertisements Site Notices Building a Stakeholder Database Public Meetings Comments and review period Key Risks and flaws Conclusion and Recommendations... 7

5 iii Abbreviations & Acronyms ABBREVIATION & ACRONYMS DEFINITION BID Background Information Document DEA Directorate of Environmental Affairs ECA Environmental Clearance Application ECC Environmental Clearance Certificate ED Enviro Dynamics cc EIA Environmental Impact Assessment EMA Environmental Management Act, 2007 (Act no. 7 of 2007) GIS Geographic Information System MET Ministry of Environment and Tourism MME Ministry of Mines and Energy NGO Non-Government Organisation PPE Personal Protective Equipment

6 iv List of Figures Figure 1: Locality... 2 Figure 2: Sensitive social receptors... 1 Figure 3: Sensitive bio-physical environment... 2 List of Appendices Appendix A: Letter to Roads Authority Appendix B: Public Consultation Process

7 1 1. Introduction The Roads Authority appointed Lithon/GIBB Joint Venture Consultants to conduct a study on how to improve the safety conditions and traffic flow on the main road B1 between Windhoek and Rehoboth by means of a new freeway. A proposed road alignment had been established and the entire section of road divided into 3 phases for environmental assessment and project implementation. These are: Phase 1: Road Section between Windhoek and Gocheganas Phase 2: Road section between Gocheganas and 15km before Rehoboth Phase 3: Potential Rehoboth Eastern Bypass and rehabilitation of T104/T105 south of eastern bypass and Rehoboth Enviro Dynamics, who provided a technical and cost proposal to the Litho/Gibb joint venture, for the related application for Environmental Clearance (and which was included in the awarded tender) have been commissioned to commence with such an application for Phase 1 of the project. This report therefor only pertains to Phase 1, the location of which is indicated on Figure 1 overleaf. According to the Namibian Environmental Management Act, 2007 (Act No 7 of 2007)(EMA) and in terms of International Environmental Impact Assessment best practice, a project of this magnitude requires the completion of an Scoping Phase followed by an Environmental Assessment Report and related Environmental Management Plan (EMP) in support of an Environmental Clearance Application (ECA). This approach will apply to each phase of the overall project separately. For Phase 1, the Scoping Phase had been initiated. This report has been compiled in terms of the activities which have been completed thus far in the scoping phase and aims at highlighting the risks of continuing with the process.

8 2 Figure 1: Locality

9 3 2. Purpose of Report This report has been compiled as an interim report to the Scoping Phase. It provides a brief overview of the following: The Application of Environmental Clearance and related assessment report, Project description, Project need and desirability, Project alternatives Public consultation conducted to date Key risks and flaws of the process By providing a brief background of the environmental processes and the project description, a clear idea of the project risks can be identified as reported in Section Application for an Environmental Clearance Certificate An ECA is required for any activity listed as per Government Notice No 29 of 2012 of the EMA. In Namibia all projects which require an ECA are subject to a Scoping Phase. Projects of a larger scale further require an Environmental Assessment developed from the Scoping Phase. All activities pertaining to these phases are listed in the Government Notice 30: Environmental Impact Assessment (EIA) Regulations: Environmental Management Act, Environmental Impact Assessment Requirements An EIA is a planning process used to help ensure that environmental features are taken into consideration early in the project development phase. For the purposes of this assessment the EIA is a valuable tool that identifies undesirable effects on the environment that may arise from prospecting activities, and provide measures for these to be avoided. The objectives thereof are to: Enable the selection of optimal alternatives from the various relevant options available if feasible. Identify adverse environmental problems as well as benefits that might be expected to occur; Allow the incorporation of appropriate mitigation measures into the project; and Identify the critical problems which require further study or monitoring. The Scoping Report and Environmental Assessment report once completed and inclusive of public / stakeholder comments, will be submitted to the Department of Environmental Affairs (DEA) of the Ministry of Environmental and Tourism (MET) which

10 4 is the custodian of the EMA, The contents of such documents are therefore legally binding and should the requirements not be adhered to, an Environmental Clearance Certificate (ECC) may be subject to a compliance order process as stipulated in Section 20 of the EMA Should an ECC be granted the project may commence with their planned activities for a period of three years where after an extension of the ECC may be applied for. Once these documents are submitted in support of an Environmental Clearance Certificate (ECC), the team has already incorporated and considered all possible alternatives, motivated their preferred ones and provided an impact assessment with mitigation for the preferred alternative. 4. Sensitivities The major sensitive and constraining features which have been identified to date pertain to the topography and the land use/settlements along the alignment of the proposed route, as indicated in Figure 3. Topographical constraints around the Auas Mountains comprise the steep mountain and hill slopes; the valley and the Kuduschlucht River that winds its way through the kloof where the B1 and the railway line also pass through. Further south along the proposed route a residential settlement has been established on what is known as Kruin 491 indicated in Figure 2. The property has further been developed as a self-catering and camping facility which is reliant on the naturally occurring wildlife in the valley. Both of these sensitivities (bio-physical i.e. the topography and social i.e. the affected community) indicate high risk areas where high impacts may be expected as a result of the proposed route. Biophysically one may expect major landscape transformation in this area because of steep slopes along with and a large capital requirement (i.e. resources needed) to bring about the road, as well as visual impact, erosion, impacts related to quarrying, etc). Socially the livelihoods as well as the well-being of the community will be affected.

11 1 Figure 2: Sensitive social receptors

12 2 Figure 3: Sensitive bio-physical environment

13 1 5. Project Description 3.1 Overall Project The proposed Windhoek - Rehoboth Dual Carriageway road will form the southern extension of the Windhoek Western Bypass and will join the road network at a planned Gobbis Interchange. Section 1 is classified as a Class 1 Trunk Road. The proposed new section of dual carriageway road will also provide the new link between the urban centres of Windhoek and Rehoboth for the daily commuters. 3.2 Phase 1: A new road section between Gocheganas and Windhoek. Planning for this new section of road between Gocheganas and the western bypass in Windhoek had been initiated in 1971 at which time the road reserve thereof had been proclaimed. As the proposed alignment will traverse the Auas Mountains, major earthworks will be required during the construction phase. At this section the confining influences of topography are so severe that the alignment is proposed along the existing road. In this area the existing road has to be relocated, and a major stream diversion is required. Further major earthworks may be required west of the existing road over the rail crossing at Kruin, and at the northern entrance to Auaspoort. 3.3 Need and Desirability Technical assessments as conducted by the appointed engineering consultants have determined that the current road (between Windhoek and Rehoboth) will reach its full capacity within 8 years. A dual carriage way will not only accommodate better traffic flow and lower collision risk, but will further serve to ensure safe passage of abnormal loads and heavy motor vehicles. Currently the only suitable route for abnormal loads is along the Trans-Kalahari Corridor through Botswana. Should the proposed section between Windhoek and Gocheganas not be upgraded to accommodate traffic growth, the vehicle density on this section will continue to increase due to natural traffic growth including the lack of passing opportunities until a total breakdown of flow is experienced by the road users. This will result in increased delays on the network, road surface degradation and related road works, while an increase in traffic accidents may also be expected. 3.4 Alternatives As part of the assessment proses the project team will consider the following which may constitute layout and design alternatives

14 2 The evaluation of encroachments into the alignment (if any) and possible or necessary re-alignments of the freeway; The conformance of the old planning to latest design standards; The appropriateness of the spacing and location of the planned interchanges at "Auaspoort", "Kruin" and "Gocheganas linked to existing road"; and The appropriateness and location of the planned accesses provided by the future service road in view of the developments that have taken place since All of the above will generate alternatives within the project such as design and material alternatives. No alignment alternatives have however been developed or will be considered by the Roads Authority. No environmental motivation could further be sourced for the proposed alignment and related corridor (Developed in 1971) as proposed by the Roads Authority.

15 3 6. Public Participation Conducted to date Informing Interested and Affected Parties who may be affected by, or who are interested in the proposed activities, is a key component of the ECA process. The public participation process, as set out in Section 21 of Regulation No 30 of EMA, has been allowed for during this assessment and the details thereof documented below. 7.1 Printed Media Background Information Document A Background Information Document (BID) was drafted at the onset of the Environmental Assessment (EA) process to act as a useful information handout about the proposed activities and related ECA. In addition, the BID provided details on the public participation process with contact details for further information. This document was distributed through various means of newspaper articles, meetings and the internet, Appendix B. It was further sent to all parties as listed on the project stakeholder list Newspaper Advertisements Press notices about the proposed activity and related EA was circulated in two newspapers for two weeks. These notices appeared in the Namibian and Republikein on the 27 th of March 2015 and 2 nd of April 2015 respectfully. Please refer to Appendix B to view these notices and articles Site Notices Site notices were distributed throughout the area. These provided information about the proposed project and related EA while providing contact details of the project team. Some notices were futher provided to the Kruin Community to be placed and distributed as per their discretion. 7.2 Building a Stakeholder Database A stakeholder database for the project developed. Initially stakeholder lists from previous projects in the area were used as a base list. During the advertisement of the project (through public notices in national newspapers and site-notices) the list was augmented as Interested & Affected Parties (I&AP) registered and contact information of stakeholders updated. All direct owner details were obtained and included as these are the most crucial stakeholders Information about the proposed project was further made available on the internet providing stakeholders contact information to register as I&AP A public meeting provided valuable contact details as per network and chain referral. Not only did this meeting serve to update the stakeholder list, but also

16 4 helped to identify key community communication channels to be used during future phases of the project. 7.3 Public Meetings A public meeting was advertised and subsequently held on the 9 th of April 2015 during which the project was formally introduced to the public. At the meeting a presentation of the ECA was provided while technical information about the proposed route was detailed. The meeting was attended by 35 people which presented a combination of authorities and I&AP. Minutes of the meeting is attached in Appendix B Comments and review period From the onset of the public participation process and the initial information sharing through the BID, newspaper and site notices, various stakeholders have registered and provided comments (all of which have been included in the public consultation Appendix B). Comments received during the public meeting had been minuted while additional comments which had been received via written notifications have been included in an issues and responses trail as per Appendix B. Further to documents received, a petition and various legal letters have been received by Enviro Dynamics and may be viewed in Appendix B. As per all the comments received thus far, the main public concern refers to the alignment of the proposed road upgrade and the lack of feasible alternatives to be considered. I&APs are very concerned about how the proposed new alignment will affect their livelihoods and quality of life. Sound technical motivation is the concern that underpins all their comments.

17 7. Key Risks and flaws At the onset of the project Enviro Dynamics met with the project team to highlight the risks of not considering an alternative alignment. The risks were further communicated to the client through a formal letter directed to the Roads Authority (Appendix A. No further communication was sent off received between the Roads Authority and Enviro Dynamics. In terms of the EIA requirements as mentioned in Section 8 and 15 any ECA should include and adhere to the following: Section 3 (h) of the EMA states: the option that provides the most benefit or causes the least damage to the environment as a whole, at a cost acceptable to society, in the long term as well as in the short term must be adopted to reduce the generation of waste and polluting substances at source; Government Notice No 30 of 2012 as per the EMA Section (8)(g): a description of the need and desirability of the proposed listed activity and any identified alternatives to the proposed activity that are feasible and reasonable, including the advantages and disadvantages that the proposed activity or alternatives have on the environment and on the community that may be affected by the area. Government Notice No 30 of 2012 as per the EMA Section (15)(d): a description of the need and desirability of the proposed listed activity and identified potential alternatives to the proposed listed activity, including advantages and disadvantages that the proposed activity may have on the environment and the community affected by the activity. Furthermore no Environmental Clearance Application had been conducted for the route determination of the road as required and indicated in Section 10.2 of Government Notice 29 of 2012 as per the EMA which states: The route determination of roads and design of associated physical infrastructure where (a) (b) it is a public road the road reserve is wider than 30 metres; or

18 (c) the road caters for more than one lane of traffic in both directions. As per all of the legislation quoted above and as per the biophysical constraints of the proposed alignment combined with the possible effects on the surrounding community, a well-motivated and feasible route alternative needs to be investigated.

19 8. Conclusion and Recommendations 1. Expected increases in the traffic volumes from Windhoek to Rehoboth seem to indicate that an upgrade of the BI National Road is necessary and desirable, although this and the design specifications and road user standard for the road upgrade still need to be determined. Most stakeholders who provided input during the scoping process seemed in agreement that a road upgrade is needed. It should be noted that the Sustainable Urban Transport Master Plan for Windhoek (2012) does not envisage major capacity increases on the Rehoboth-Windhoek link. This needs to be considered and final recommendations made. 2. The main risk currently identified is the lack of alternatives to the proposed route (or sections thereof). The planning done 45 years ago did not consider route alternatives or motivate why the current alternative was selected. No public consultation was done at the time, or there are no records of such. Affected communities have changed considerably, if not completely since then. Furthermore, when the original route selection was done, there was no EIA conducted for the route selection and for the road activity. This is required by law. Not only did Enviro Dynamics point out this risk to the Roads Authority, but the public input confirmed the same concerns. They are valid and need to be addressed. 3. It is therefore our considered and careful opinion that a route selection process needs to be completed before the scoping process of the EIA for the Windhoek-Gocheganas upgrade can be finalised, and for the full EIA to continue. There are two major environmental and social sensitivities in the area under consideration, namely steep mountain and hillslopes, and a settlement. Alternatives need to include these sensitivities and consideration to their avoidance, together with technical and financial considerations. The need and desirability for the upgrade also needs to be confirmed vis a vis the Master Plan mentioned in point 2 above.