JEFFREY S BAY WIND PROJECT DRAFT EIA REPORT SUMMARY BACKGROUND

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3 SUMMARY BACKGROUND Mainstream Renewable Power Jeffrey s Bay (Pty) Ltd, a special purpose vehicle of Mainstream Renewable Power South Africa (referred to as Mainstream SA ), is proposing the construction of a wind energy facility near Jeffrey s Bay in the Kouga Municipal area of the Eastern Cape Province. The proposed project, referred to as the Jeffrey s Bay Wind Project, will utilise wind turbines with a combined generation capacity of a maximum of 180 MW. This proposed 180 MW facility will include the Kouga Wind Project of approximately 16 MW for which an environmental authorisation was obtained in March A separate Basic Assessment (Department of Environmental Affairs Reference number: 12/12/20/1748) has been submitted to DEA for authorisation for the establishment of wind monitoring masts on the Jeffrey s Bay site prior to the development of the wind farm. The monitoring masts will have a maximum height of 100 m. Seventeen sites are being investigated and applied for, from which Mainstream SA proposes to select 9 sites for the installation of the monitoring masts. The proposed Jeffrey s Bay Wind Project is stretching across 8 farms and covering over 3000 ha. Once operational, the project could produce enough clean electricity to power approximately typical Eastern Cape households (a typical Eastern Cape household uses 1500 kwh per year) in a year, or approximately 25-30% of the power demand of the Nelson Mandela Metropolitan Area (which includes Port Elizabeth, Uitenhage and Despatch), when at full generation capacity. During the pre-feasibilities stages of the project, representatives of the World Bank Carbon Fund were involved with the identification of possible alternative designs and sites. They have indicated that the project has merit and would qualify for carbon credits once operational. Furthermore, this project complies with the Clean Development Mechanism (CDM) of the Kyoto Protocol of 1997, whereby a First World country can purchase certified emission reductions from a clean energy project in a developing economy such as South Africa. In March 2010 the proposed Jeffrey s Bay Wind farm was shortlisted by the national government as 1 of 4 carbon offset projects for the Soccer World Cup Greening 2010 programme. Once operational, the wind farm will offset approximately 513,721 tonnes of CO 2 every year and 50% of this emissions benefit will be allocated to the South African Government as part of their initiative to offset the CO 2 emissions from major sporting events. In the pre-feasibility stage of the Phase 1 project various sites were considered in the wider Southern and Eastern Cape regions, leading to the selection of the Kouga area for more detailed studies and wind monitoring for the project. The Kouga region was seen as an ideal area for this project due to the following factors: pg i

4 The wind regime in the area appears favourable (see Figure 2.1). Eskom power lines are in close proximity to the proposed site. There were willing landowners. Access to the site was viable. Initial investigation suggests there are few additional constraints to the development in the immediate area. There is a need for additional energy capacity to support and stimulate economic growth. The network within the Kouga area can benefit from a localized power plant to stabilise the grid. The need for regional economic stimulus that a development of this kind could bring. THE PROPOSED PROJECT The key components of the project are: Wind turbines 40 to 85 turbines (number dependent on capacity of turbines selected in the range between 1.5 and 3 MW), with an expected hub height in the range m and a blade diameter in the range 70 m to 120 m. Turbines to be supported on reinforced concrete foundations with an approximate size 20 m x 20 m x 2.5 m depth. 1. Electrical transformers will be placed beside each turbine. 2. Gravel surfaced hard standing areas (approximately 40 m x 20 m) adjacent to each turbine for use by cranes during construction and retained for maintenance use throughout life span of the project. Electrical connections 1. The wind turbines typically will be connected to each other and to the substation using medium voltage cables which will, in most cases, be buried approximately 1 m below ground, except where a technical assessment of the proposed design suggests that overhead lines are appropriate. 2. A new sub-station (with an approximate compound size of 90 m x 120 m) and a transformer with a connection of maximum 500 m will be built to the 132 kv Eskom grid. The substation will preferably be located close to the 132 kv line. 3. The connection from the substation to the Eskom grid line is a stretch of maximum 500 m overhead line supported on an intermediate pole(s), depending on the location of the substation relative to the 132 kv line. Other infrastructure 1. Operations and maintenance building: A single storey building, approximately m 2, with warehouse / workshop space and access, office and telecoms pg ii

5 space, security and ablution facilities as required. Preferably these should be situated preferably close to the substation. 2. Fencing will be erected as required. 3. One to two permanent wind measuring mast /s of 70 m 100 m, covered by the Basic Assessment process. Roads 1. Gravel surfaced access roads will be constructed or upgraded from the public road to the turbine sites. Three permanent access route options and one temporary access route, for the construction period, are proposed. 2. An internal road network to the turbines and other infrastructure (substation and operation and maintenance building) will be constructed. The road network may include turning circles for large trucks, passing points and culverts over gullies and rivers. 3. All roads that will be used for the transport of wind turbine components will have a width of approximately10 m, which serves as the road servitude, including cabling and drainage. 4. As far as possible upgrading of certain existing roads will take place. Temporary activities during construction 1. Lay down areas will have to be prepared, beside an access route, for the assembly of the turbine components. The lay down areas will cover an area of approximately 10,000 m 2 this hard standing area could be temporary or if the landowner prefers, left for long-term use. 2. The overall site compound for all contractors would be an approximately of 5000 m Approximately 5 borrow pits, which are subject to appropriate permits; will be distributed around the site. Existing borrow pits will be used as far as possible. The size of these pits will be dependent on the terrain and need for granular fill material for use in construction. 4. At the end of construction these pits will be backfilled as much as possible using surplus excavated material from the foundations and vegetation will be rehabilitated as indicated in the EMP. The construction and commissioning phase is expected to require between 12 and 24 months. The operational life of the wind turbines is expected to be a minimum of 25 years. Exact turbine positions will only be established once sufficient wind data has been received from the wind monitoring masts that will be installed on the proposed site. In order to minimize impact on sensitive environments, a constraints map with no-go areas (Fig.14.1) has been developed with input from all the specialists and based on international wind farm planning buffer standards. These no-go areas will be avoided during development of the wind farm. pg iii

6 EIA AND PUBLIC REVIEW PROCESS An application to conduct the EIA process was submitted to the Department Environmental Affairs (DEA) office in Pretoria on13 November Approval was received and the project moved into the scoping phase. The Final Scoping Report and Plan of Study was submitted to DEA and notice to proceed to the EIA phase was received on 30 June. The results of the specialist studies are included in the Draft EIA Report and are now released for a 40 days public review period to interested and affected parties(i&aps) on the project database. Advertisements in relevant newspapers will announce the release of the Draft EIA Report and I&APs will be notified in writing. The report will be available in the local library at Jeffreys Bay and Humansdorp main libraries and on the project website at Hard copies and/or CDs containing the document will be send to key stakeholders, including authorities. The Environmental Management Plan (EMP) is available as PART B of this report. The EMP is based on the recommendations made by specialists for design, construction and operation of the project. The Draft EIA will be revised based on the comments received during the review period and the Final EIA, including the EMP, will be submitted to the authority, DEA, for decision making. All I&APs on the project database will be notified of this stage in the process and the distribution of the Final EIA Report. All I&APs on the project database will be notified of the issuing of the Environmental Authorisation and the Appeal period. IMPACT ASSESSMENT AND MITIGATION No fatal flaws, or negative impacts of high significance that would necessitate substantial redesign or termination of the project, were identified during the EIA process, provided that the recommended management actions are implemented affectively. In summary, the predicted impact of the wind turbines was low to medium, with the impact on the visual character of the area identified as being the most significant as medium to high. The key issues identified during the scoping process, and assessed during the EIA, were investigated and nine specialist studies were conducted. The overall ratings were determined as follow for specialist studies: Impacts on landscape ecology: Low Impacts on fauna and flora: Low Impacts on birds: Low to Moderate Impacts on bats: Low to Moderate Visual impacts: Moderate to High Noise impacts: Low Economic impacts: Low (with some positive impacts) Impacts on archaeology: None Impacts on palaeontology: None pg iv

7 The main findings of these studies are outlined below, together with proposed mitigation and recommendations: Impacts on Landscape Ecology and Recommended Mitigation Temporary loss of vegetation cover in the construction and laydown areas is inevitable during construction of the turbines. Construction workers might increase the possibility of a fire hazard resulting from people smoking and making fires for cooking purposes. Animals will avoid the construction sites which will result in a loss of foraging area. The footprint of constructing the infrastructure, the power line and new access roads will cause a loss of plant habitat. Terrestrial as well as aquatic habitat fragmentation will result from the construction of new access roads. Since birds tend to rest on utility lines, one could expect a preferential dispersal of bird dispersed seed along the utility lines. There may be a loss of nocturnal pollinators as a result of turbine related mortality. Though the powerline is expected to be less than 500 m in length, lower flower visitation rates by birds and insects might be experienced around the stretch of powerline. For example, honeybee foraging behaviour is reputed to be affected by the presence of power lines. Establish the laydown areas in degraded areas where possible. Demarcate the construction area with danger tape to limit the footprint of the affected area. Educate workers on the risk of fire. Designate a safe area for smoking. Keep the number of drainage line crossings to a minimum. Ensure the culverts are suitably sized, embedded in the substrate (i.e. there is no step and hence potential barrier in the channel bed) and substrate continuity between upstream and downstream areas is maintained. Place anti-perching devices on the top of structures where practically possible, depending on implications with respect to the turbine manufacturer s warranty. All potential ecological impacts assessed should be of low significance after mitigation. The potential impacts on the study area that will require careful planning in order to minimize impacts will be the upgrade and construction of new roads and the potential impact of infrastructure on the foraging behaviour of predators and avian seed dispersers. Impact on Fauna and Flora Flora Degradation in the form of infestation by alien plants tends to be insignificant, but significant as a result of excessive fire and overgrazing in areas. Areas with an elevated vulnerability (moderate to high) include rocky outcrops, seeps and wetlands, and thicket habitat on steep slope. Sixteen terrestrial vegetation impacts that may occur during the construction and operational phases of the proposed project, have been indentified, these include: Loss of habitat of the Kouga Grassy Sandstone Fynbos and Gamtoos and a general loss of faunal habitat. It is further expected that there will be a reduction or changes to ecological processes and functioning in the Kouga Grassy Sandstone Fynbos and Gamtoos Thicket. Temporary/permanent fragmentation of habitats as well as barriers to animal movement could be expected. As mentioned in the Impact on the Landscape Ecology (Chapter 5), an increased risk of alien invasion is expected along the drainage pg v

8 lines and disturbed areas as well as an influence on the fire regime, i.e. an increase in the frequency of fires. One could also expect increased mortality of fauna due to road traffic. Loss of species of special concern might be expected in the Kouga Grassy Sandstone and Gamtoos Thicket habitats. Endemic and protected flora must be removed from the development footprint to be safeguarded from destruction and relocated either to undeveloped areas or off-site in consultation with conservation authorities and relevant botanical specialists. These could also be replanted in Open Space areas. Permission must be obtained from the provincial authorities to destroy or remove any protected plant species as per legislation. Clearing of Acacia saligna and Acacia mearnsii, especially from the drainage and riparian areas should be set as a priority. A long term alien plant management plan to control these invasive species must be implemented within the designated Open Space areas. Kikuyu grass must not be utilised during re-grassing of verges, turbine footprints and other landscaped areas within the site, particularly adjacent to riparian habitat. Overall the site has a low to moderate vulnerability dependent on the level of agriculturerelated degradation. Fauna The species that will be mostly affected during the construction phase of this project is those that can t vacate the affected area themselves, e.g. tortoises, burrowing reptiles and burrowing mammals. These species can suffer direct mortality. Traffic on the access roads to and from the construction sites would most likely result in road kills. As indicated in Chapter 6, some species of special concern are found in the area and will be affected by this development. All amphibians are of least concern and are well protected elsewhere. The reptiles of special concern are the FitzSimons long-tailed Seps and the Elandsberg Dwarf Chameleon. Although these species are well protected elsewhere (e.g. Lady Slipper Nature Reserve), their known distribution is limited. A proper survey needs to be undertaken to determine the presence of these species in the proposed area to mediate the development process. Data on most mammal species are deficient. The impact on the terrestrial fauna will be temporary and is expected to return to its normal sate after construction. Removal of animals from the affected areas before the start of site clearing and construction, and relocating these to safe areas would only be a valid mitigation option in the case of tortoises. All other reptile and small mammal species are extremely difficult to catch and it would be futile to attempt to relocate them. Before site clearing, affected areas should be thoroughly searched for tortoises. Tortoises found must be released in adjacent unaffected areas. A speed limit of 60 km/h needs to be implemented on the access roads to the site and a 40 km/h speed limit on the construction sites and for the cranes. pg vi

9 All terrestrial floral and faunal impacts have been assessed and it is estimated that these can be mitigated from moderate impact to low through implementation of the recommended mitigation measures during the operational and construction phases of the proposed wind farm development. Impact on birds and recommended mitigation The effects of a wind farm on birds are highly variable and depend on a wide range of factors including the specification of the development, the topography of the surrounding land, the habitats affected and the number and species of birds present. The principal areas of concern with regard to effects on birds are listed below. Each of these potential effects can interact, either increasing the overall impact on birds or, in some cases, reducing a particular impact (for example where habitat loss or displacement causes a reduction in the number of birds using an area which might then reduce the risk of collision). Collision (mortality) with the wind turbines Collision with the power line Displacement due to disturbance Habitat change and loss Ensure that key areas of conservation importance and sensitivity are avoided as described in Chapter 7. However, it is appreciated that avoiding construction of turbines in sensitive areas may not be practicable in some cases. Implement appropriate working practices to protect sensitive habitats: Habitat destruction should be limited to what is absolutely necessary for the construction of the infrastructure, including new roads. Provide adequate briefing for site personnel particularly with respect to sensitive locations: personnel should be adequately briefed on the need to prevent unnecessary habitat destruction. Personnel must be restricted to the actual building sites. Implement an agreed post-development monitoring programme through planning or licence conditions. Where possible, install transmission cables underground in accordance with existing best practice guidelines. Mark overhead cables using Bird Flight Diverters. It is envisaged that the impact of collision mortality on Red listed avifauna is likely to be low, due to the infrequency of the envisaged interactions (mostly raptors) and the likelihood that key species such as the Blue Crane and Denham s Bustard are likely to be displaced by the development. As a result of the expected lack of large concentrations of Red listed species (e.g. roost sites or funnelling points) close to any of the proposed turbine sites, no potential no-go areas have been identified from a bird perspective. Collisions with the proposed power line, although the power line length is less than 500 m and the impact is expected to be limited, could have an impact on Red listed species, pg vii

10 particularly the Blue Crane and Denham s Bustard. The potential for the displacement of the Blue Crane and Denham s Bustard is envisaged to be significant, although this is admittedly speculative due to the lack of any precedent in South Africa. The impact of direct habitat change and loss is regarded to be as a result of the small footprint. However, if construction of additional wind turbines takes place in an uncontrolled manner, the impact will increase significantly, which could lead to fragmentation of (in particular) the Blue Crane and Denham s Bustard habitat and increased levels of disturbance. The cumulative impact of additional wind facilities will therefore have to be assessed and closely monitored. The overall rating of impact on birds is low to moderate. Impacts on Bats and Recommended Mitigation The greatest impact on bats is mortality, attributed to both direct collisions with turbines and to barotrauma. The proposed site is within the distribution ranges of 12 species of bat, five of which are listed as Near Threatened. These bats include one species endemic to South Africa and another species that is endemic to southern Africa. No large caves or maternity colonies were observed on the property. Large water bodies, riparian vegetation and rocky crevices are present on the proposed site. These landmarks are important for bats as they provide roosts and foraging habitat. Activities at the proposed site that are likely to adversely affect bats include loss of habitat, construction of new buildings and, in the operational phase, when the turbine blades are turning. A period of bat monitoring is advised before the start of construction. If monitoring shows that a high occurrence of bats is present, the location of the affected turbine should be reconsidered, or that a buffer zone is implemented in the affected areas. Further mitigation will then have to be discussed with a qualified bat specialist. Where there are no 500 m buffer zones as specified by the noise specialist study or natural topography, and if it is found through pre-construction monitoring that some areas have a high frequency of bat occurrence, a >500 m buffer zone is recommended. Avoid the removal of large trees (either for the construction of roads, or the lay down areas, or the erection of wind turbines) that may provide roosting habitats for some species. The construction of new buildings may provide additional roosting habitats for bats. This can be prevented by ensuring that the roofs are completely sealed. The potential impacts on bats can be mitigated so that the impact rating is low to moderate. This can be achieved by implementing the recommended pre-construction monitoring programme and the proposed mitigation measures arising from the results of the monitoring studies. pg viii

11 Visual Impacts and Recommended Mitigation Wind farms are highly visible because of the height of the individual turbines, located on ridges and the movement of their rotating blades. The wind farm proposed for this project will consist of over 70 wind turbines spread over an area of approximately 8 km by 7 km. It is clear that the wind farm will have a considerable impact on the landscape and will alter existing views of the landscape in the region. Wind farms will have significant visual impacts where there are visual receptors and landscape impacts regardless of visual receptors (unless it is an industrial landscape). The landscape around Jeffrey s Bay is a mixture of urban and agricultural land, and is changing rapidly as more land becomes incorporated into the urban landscape. Wind farms are not incongruent with this type of landscape in other countries. Three main types of visual impacts are predicted for the wind project: Intrusion of large and highly visible construction activity on sensitive viewers The height of the features being built and the location on ridges is likely to expose construction activities against the skyline. Large construction vehicles and equipment will be highly visible over long distances. Activity at night is also probable since transport of large turbine components may occur after work hours to minimise disruption of traffic on main roads. The duration of the impact is short term (while construction lasts). Construction activities is expected to be moderate to high due to the visual exposure that highly sensitive viewers (residents in or close to the wind farm area, and others in close proximity to the site) will experience during the construction phase. If mitigation measures are adhere to, the severity of the impact is likely to be moderate. The most obvious causes of impact cannot be mitigated since the turbines are very tall and they are to be installed on the top of ridges close to settlements and busy roads. The duration of other aspects of the construction impact is short, though, and there are a number of mitigation measures that will curtail the intensity to some extent: New road construction should be minimised and existing roads should be used where possible. The contractor should maintain good housekeeping on site to avoid unsightly litter, such waste should be removed to an approved waste disposal site. Clearance of indigenous vegetation should be minimised and rehabilitation of cleared areas should start as soon as possible. Erosion risks should be assessed and minimised as erosion scarring can create areas of strong contrast which can be seen from long distances. Laydown areas and stockyards should be located in low visibility areas (e.g. valleys between ridges) and existing vegetation should be used to screen them from views where possible. Night lighting of the construction sites should be minimised within requirements of safety and efficiency. pg ix

12 Impact of a change in mixed urban-coastal resort-agricultural landscape as a result of establishing a wind farm The landscape character has a moderate sensitivity to the change that will be caused by introduction of a wind farm, therefore the intensity of the impact is expected to be moderate partly because the residences in the seaside resorts at Jeffrey s Bay and along the coast face seawards. The landscape impact is expected to be high due to the long duration and the extent of the impact. The landscape is changing, however, as the surrounding urban centres continue to expand. It is therefore likely that the impact will decrease as time passes. The status of the impact will depend on whether the wind farm is seen to be in conflict with environmental concerns or not. A moderate landscape impact is expected by the visual specialist. There are no mitigation measures that will change the significance of the landscape impact other than avoiding the site entirely. A reduction in the number of wind turbine numbers is unlikely to have an appreciable effect since even a few wind turbines will still be highly visible. Intrusion of large wind turbines on the existing views of sensitive visual receptors A number of farms north and north-west of the wind farm area are located in areas with potential for pristine and scenic views. Their visual exposure to the wind farm is high because they are close to the wind farm area and some views will contain many wind turbines. Since there are few other man-made structures in existing views, the intrusion of the wind farm on their views will be high. Areas south and west of Paradise Beach (including the southern extension of Paradise Beach) will experience a similarly high intensity visual impact because of the high visual exposure ratings in contrast with the current relatively pristine views. Most of the protected areas that may be affected are in low landscape sensitivity areas and the visual intrusion will be low to moderate. There are no mitigation measures that can reduce the impact significantly unless the site is avoided, but there are a number of measures that can enhance the positive aspects of the impact. It has been shown that uncluttered sites are preferred for wind farms. In view of this, the following mitigation measures and suggestions may enhance the positive visual aspects of the development: Ensure that there are no wind turbines closer than 500m to a residence or farm building. The maintenance of turbines is important. A spinning rotor is perceived as being useful. If a rotor is stationary when the wind is blowing it is seen as not fulfilling its purpose and a negative impression is created. Signs near wind turbines should be avoided unless they serve to inform the public about wind turbines and their function. Advertising billboards should be avoided. According to the Aviation Act, 1962, Thirteenth Amendment of the Civil Aviation Regulations, 1997: Wind turbines shall be painted bright white to provide maximum daytime conspicuousness. The colours grey, blue and darker shades of white should pg x

13 be avoided altogether. If such colours have been used, the wind turbines shall be supplemented with daytime lighting, as required. Lighting should be designed to minimise light pollution without compromising safety. Investigate using motion sensitive lights for security lighting. Turbines are to be lit according to Civil Aviation regulations. An information kiosk (provided that the kiosk and parking area is located in a low visibility area) and trails along the wind farm can enhance the project by educating the public about the need and benefits of wind power. Engaging school groups can also assist the wind farm proponent, as energy education is paramount in developing good public relations over the long term. Instilling the concept of sustainability, and creating awareness of the need for wind farm developments, is an important process that can engage the entire community. Impact of night lights on existing nightscape Wind farms are required by law to be lit at night with the appropriate lightning as required by the CAA as they represent hazards to aircraft due to the height of the turbines. Marking of turbines depends on wind farm layout and not all turbines need to be lit. Marking consists of a red flashing light of medium intensity. The conceptual layout of the Jeffrey s Bay wind farm is a combination of cluster and linear in terms of the lighting specification and it is not clear how many turbines will need to be lit, but it is likely to be more than 30. There are large urban areas and other light sources in close proximity to the wind farm to which the aviation warning lights will add very little in terms of light pollution. Farms to the north and west of the wind farm will have the glow of towns like Jeffrey s Bay and Humansdorp as backdrop to the wind farm lights. The intensity of the impact is therefore expected to be low. The impact is rated as moderate due to the long term of the development, but it should be kept in mind that expansion of the nearby urban centres are likely to have a far greater impact in terms of light pollution than the wind farm. The bright lights of the chokka (squid) fishing boats during the fishing season will also reduce the wind farm impact in terms of light pollution, but it is only a seasonal mitigation. The aviation standards have to be followed and no mitigation measures are applicable. Impact of shadow flicker on residents in close proximity to wind turbines The impact of shadow flicker caused by wind turbines appears to be a minor issue in most countries where wind farms are common. There are no official regulations governing the levels of exposure to shadow flicker. There are isolated buildings closer than 500m from some of the proposed wind turbine sites which mean they may potentially be affected by shadow flicker. Two sections of the N2 are also within 500 m of wind turbines where shadow flicker could be hazardous. Mitigation measures include: Adjust the layout of the wind farm to lower the number of residents and/or motorists potentially affected by shadow flicker. pg xi

14 For residents, the project proponent could offer to fit blinds or awnings on houses that may be found to be affected by shadow flicker. Trees are an effective measure against shadow flicker and if residents are willing trees can be planted to reduce the flicker effect, although it should be recognized that trees take a long time to establish Shadow flicker modelling should be used to identify potentially vulnerable buildings and roads and assess the significance of this impact (e.g. in terms of hours of exposure per year). The actual impact of shadow flicker cannot be determined accurately until the layout has been finalized and the turbines selected. This will depend on the forthcoming outcome of the wind monitoring, further technical studies and commercial negotiations. Mainstream SA is conducting a shadow flicker study using the current provisional turbine layout. Results will be available for the final EIA report and the model will be re-run for any revised layouts during the subsequent detailed design phase. Noise Impacts and Recommended Mitigation The wind turbines are the key source of noise impacts during the operation of the wind farm. These effects are unlikely to adversely affect the residents: the distance between the turbines and the nearest communities will permit noise attenuation and the sound power level from the turbines is low. The noise level at three Noise Sensitive Areas is predicted to be unacceptable during operations, in that noise from the turbines will exceed the 45 db(a) limit at residential areas. The results of the noise study indicate that there will be a short term increase in noise in the vicinity of the site during construction since the ambient level will be exceeded. This is due to the impact on the immediate surrounding environment from construction activities and will increase with the number of construction vehicles used. The opinion of the noise specialist is that the impact of low frequency noise and infra sound will be negligible as there is no evidence to suggest that adverse health effects will occur as the sound power levels generated in the low frequency range are not high enough (i.e. are well below 90 db) to cause physiological effects. The impact of the noise pollution that can be expected from the site during the construction and operational will largely depend on the climatic conditions at the site. The ambient noise increases as the wind speed increases. Under very stable atmospheric conditions, a temperature inversion or a light wind the turbines will not be operational as the cut-in speed is 4m/s. As the wind speed increases above the cut-in level the ambient noise will also increase. During the detailed design phase, the siting of turbines near noise-sensitive areas should be revised and the predicted noise levels re-modeled by the noise specialist in order to ensure that the predicted noise levels are less than 45 db(a) at these noise sensitive areas. It should be noted that this is a precautionary approach since the noise modelling does not take into consideration the effect the prevailing wind may have on masking the operational noise of the turbines. At a setback distance of 500m, the operation of the turbines may not be audible above the background noise of the prevailing winds. pg xii

15 There are limited options for mitigating the noise impact during the construction phase. These include: o o o All construction operations to only occur during daylight hours if possible. No pile driving (if required) at night. Construction staff to be given training in actions to minimise noise. Wind turbines are to be properly serviced and maintained during operation, in order to reduce operational noise emissions. Provided that the mitigation measures presented in the noise specialist study are implemented effectively, the noise from the turbines at the identified noise sensitive areas is predicted to be less than the 45 db(a) limit for rural areas presented in SANS 10103:2008. The overall noise impact with recommended mitigation is expected to be low. Economic Impact and Recommended Mitigation A critical aspect of economic desirability is whether the proposed development complements national energy, economic development and spatial development planning. The project achieves a high degree of fit with the national energy planning policy with respect to renewable energy which has links to climate change, environmental impact and energy security/flexibility considerations. The project also has the potential to contribute to a greater energy supply stability and higher levels of energy security in the area. At a regional and local scale the concept of a wind farm is broadly supported in economic planning documents. With regard to specific spatial planning, the wind farm site is situated outside the short and medium term Urban Edge of Humansdorp and Jeffrey s Bay implying a good alignment with the spatial planning of the area. In the longer term, however, the expectation is that Humansdorp and Jeffrey s Bay will continue to grow toward each other with the N2 serving as their northern boundary. There is thus a reasonable chance that the land forming part of the site between the N2 and the R102 will become sought after for urban development in the long term (15-20 years plus). If it is not possible to avoid these areas (as is anticipated), turbine placement on them should be limited to areas closer to the N2 if this is possible within the confines of viability and other biophysical factors affecting turbine placement. This will minimise the chances that turbines may need to be moved in 25 years time and avoid potential land use conflicts. While financial risks cannot be ignored, financial viability is considered to be a minor issue once a long term contract that secures payment for the electricity generated based on the National Energy Regulator (NERSA) Renewable Energy Feed-in Tariff (REFIT) for wind energy has been agreed on with the relevant authorities. The project, however, will have to compete with other wind energy projects in order to secure a contract as NERSA will only be allocating the contracts needed to meet their immediate target (400 MW of electricity from wind power by 2013). The proponent has also indicated that the registration of the project with the Clean Development Mechanism (CDM) and potential income from offsets will be investigated further. It is highly likely that the economic impacts on all land owners within the site boundaries would be positive and in most cases significantly so. The project would provide a welcome source of additional income while allowing existing farming activities to continue with relatively minimal risks and potential negative impacts. pg xiii

16 No significant negative impacts on the agricultural activities on surrounding farms are anticipated for the same reasons that no significant impacts are anticipated on agricultural activities on the site. All agricultural production and activities will be able to continue as at present. Drawing on the visual assessment and international experience, it is reasonable to conclude that the development would make a significant change to the current sense of place of the site and would not be without tourism risks. However, given the site s location relatively near to urban areas and a major road link, it is expected with mitigation to have a relatively low impact on tourism. Potential positive impacts on tourism would stem from the potential attraction that the wind farm would introduce. Considered as a whole, the key potential drivers of negative impacts on tourism (primarily visual impacts) do not seem to be significant enough to provide any clear basis to conclude that the project would entail more than a low level of risk for tourism. The economic specialist is of the opinion that there is a possibility that this risk would be offset by the positive attraction provided by the project. It is predicted, therefore, that the net tourism impacts (i.e. positive and negative) associated with the project would be neutral to low positive with mitigation. The project has the potential to have a positive impact on economic activity in the local area and sub-region given the size of the new spending injection associated with it and the need for economic opportunities. Notwithstanding the need for relatively high proportions of imports, the construction of the project represents a significant investment. Roughly 190 jobs of one year s duration, of which approximately 88 will be allocated to local people and 98 to people from the rest of Eastern Cape, would be associated with the entire construction phase with the majority of jobs in the low and medium skill sectors. With regard to direct employment during operations, it is expected that approximately 10 direct employment opportunities would be created by the project evenly spread across skill levels. Adequate setbacks from buildings, structures and residences in particular to be strictly enforced. The economic specialist has taken recommendations from the noise, visual, ecological, bird and bat specialist studies into account. The recommendations and mitigation in the economic specialist study is therefore subjective to the implementation of these specialist studies. Mitigation in the form of benefit enhancement should focus on three areas: Targets should be set for how much local labour should be used based on the needs of the proponent and the availability of existing skills and people that are willing to undergo training. Opportunities for the training of unskilled and skilled workers from local communities should be maximized. Local sub-contractors should be used where possible and contractors from outside the local area that tender for work should also be required to meet targets for how many locals are given employment. The proponent should continue, as is their stated intention, to explore ways to enhance local community benefits with a focus on broad-based BEE through mechanisms such as community shareholding schemes and trusts. At this pg xiv

17 preliminary stage, and in accordance with the relevant BEE legislation and guidelines, up to 4% of after tax profit could find its way into community upliftment over and above that associated with expenditure in the area. When considering the overall costs and benefits of the project it was found that the latter are greater thus allowing for the achievement of a net benefit. With respect to risks and negative impacts, these should prove to be relatively low provided adequate mitigation is put in place much of which will revolve around optimal turbine locations. Impact on Archaeology and Recommended Mitigation The wind farm site, apart from the presence of a few Middle Stone Age stone tools, appears to be of low archaeological sensitivity. It is also highly unlikely that any archaeological heritage remains of any value will be found in situ. The impact of the development on archaeological sites/materials will be limited. The area is also situated more than five kilometres from the coast (the maximum distance shell middens are expected to be found inland); no such features have been observed. There is a possibility that the deep excavations for the tower bases potentially could affect buried archaeological material, similarly excavation of cable trenches and clearing of access roads could disturb material that lies buried in the surface sand. Construction managers/foremen should be informed before construction starts on the possible types of heritage sites and cultural material they may encounter and the procedures to follow when they find such sites. It is suggested that a trained person is on site to report to the site manager if archaeological material is found. In the unlikely event that any concentrations of archaeological material are uncovered during construction they should be reported immediately to the nearest archaeologist and/or the South African Heritage Resources Agency. If these materials are to be removed a permit has to be obtained from SAHRA. As a precautionary approach the general archaeological guidelines for developers should be followed. Once the precise locations of the turbine bases, roads, power line connections, offices and construction sites and other infrastructure are known, an archaeologist must undertake a further survey walk through of these areas before construction takes place. pg xv

18 Impact on Palaeontology Recommended Mitigation The proposed Jeffrey s Bay Wind Project is located in an area that is underlain by potentially fossil-bearing sedimentary rocks of Palaeozoic and younger age. Construction will entail numerous and extensive excavations into the superficial sediment cover as well as the underlying bedrock. These include excavations for the turbine foundations (2.5m deep), buried cables (1m deep), new gravel access roads and five borrow pits. In addition, substantial areas of bedrock will be sealed-in or sterilized by infrastructure such as standing areas for each wind turbine, an electricity substation and maintenance building, lay down area (this may well be temporary, however) as well as the new gravel road system. All these developments may adversely affect the local fossil heritage within the study area by destroying, disturbing or permanently sealing-in fossils that are then no longer available for scientific research or other public good. Field experience with the rock formations concerned as well as the palaeontological literature indicate that the original fossil heritage within the study area was almost certainly very sparse and that this has been further reduced by tectonic deformation and weathering processes. The inferred sensitivity of this heritage, therefore, is low and the overall impact significance of the proposed wind project is correspondingly low. Should fossils be discovered during construction and reported by the responsible ECO to a heritage management authority (e.g. SAHRA) for possible recording and collection, as recommended, the overall impact significance of the project would change to low (positive). The proposed wind farm will not have a substantial impact on the very limited local fossil heritage at the construction stage or later. No further specialist mitigation of palaeontological heritage for this project is recommended. OVERALL EVALUATION BY ENVIRONMENTAL ASSESSMENT PRACTITIONER Residual impacts are those that are expected to remain once appropriate mitigation has been implemented. The main residual negative impacts at the Jeffrey s Bay Wind Project site are possible infrequent bird and bat mortality and the visual impact of the turbines on the sense of place. These impacts are summarised above. Taking into consideration the need for ongoing pre-construction monitoring of bats monitoring of bird and bat mortalities after construction (as part of the implementation of the EMP), and recognizing that the change to the character of the area, the project could be perceived as positive (being a renewable energy initiative). It is the opinion of the Environmental Assessment Practitioner that the necessary mitigation measures have been adequately investigated, and if these mitigation measures are applied and the final site layout incorporate the findings of the shadow flicker modeling, that the project benefits outweigh the costs. It is proposed that the project receive authorisation. pg xvi

19 CONTENTS Summary SECTION A: Draft Environmental Impact Assessment Report CHAPTER 1 CHAPTER 2 CHAPTER 3 CHAPTER 4 CHAPTER 5 CHAPTER 6 CHAPTER 7 CHAPTER 8 CHAPTER 9 CHAPTER 10 CHAPTER 11 CHAPTER 12 CHAPTER 13 CHAPTER 14 CHAPTER 15 Introduction Project Description Description of the Affected Environment Approach to the EIA Impact on Landscape Ecology Impact on Fauna and Flora Impact on Birds Impact on Bats Visual Impacts Noise Impacts Impact on the Economy Impact on Archaeology Impact on Palaeontology Conclusions and Recommendations References pg xvii

20 Appendices A. Curriculum vitae: Paul Lochner B. DEDEA s Acceptance letter of the Final Scoping Report and Plan of Study for EIA C. I&AP Database up to Final Scoping Report SECTION B : Environmental Management Plan pg xviii

21 REPORT DETAILS Title: Purpose of this report Environmental Impact Assessment for the proposed Jeffrey s Bay Wind Project: Draft Environmental Impact Assessment Provide a description of the proposed project as well as the affected environment at a sufficient level of detail to facilitate informed decision making; Describe the local planning context and environment within which the project is proposed; Provide an overview of the process being followed in the EIA and the public participation process, Describe and assess the predicted impacts of the project on the environment; Provide recommendations to avoid or mitigate negative impacts; and to enhance the benefits of the project. Prepared for Prepared by Authors Mainstream Renewable Power South Africa Contact person: Leila Mahomed-Weideman CSIR, P O Box 320, Stellenbosch, 7599, South Africa Contact person: Stephanie Dippenaar Tel: Fax: Stephanie Dippenaar, John Almond, Johan Binneman, Henry Holland, Peter Illgner, Paul Lochner, Jamie Pote, Brett Williams, Sandy Wren, Samantha Stoffberg, Chris van Rooyen, Hugo van Zyl Internal Review: Pat Morant CSIR Report Number CSIR Project Number STEL GEN 8085 CASKG59 DEA Ref Number 12/12/20/1718 Date June 2010 To be cited as CSIR (2010): Environmental Impact Assessment for the Jeffrey s Bay Wind Project: Draft Environmental Impact Assessment. Report Number: CSIR Report No. STEL GEN pg xix