SCIENTIFIC SERVICES Postal Private Bag X6546, GEORGE, 6530 Physical Fourth Floor York Park Building, York Street, GEORGE, 6530 Website Enquiries www.capenature.co.za Clyde Lamberts Telephone +27 44 802 5300 Fax +27 44 802 5313 Email clamberts@capenature.co.za Reference SSD# 14/2/6/1/6/6_INFRA UPGRADE EUREKA PARK & THE ISLAND/2014 Date 30 April 2014 Cape Environmental Assessment Practitioners (Pty) Ltd P.O. Box 2070 GEORGE 6530 Tel.: 044 874 0365 Fax: 044 874 0432 Attention: Sian Holder By email: sian@cape-eaprac.co.za Dear Sian DRAFT BASIC ASSESSMENT REPORT FOR ENVIRONMENTAL AUTHORISATION IN TERMS OF THE NEMA FOR PROPOSED UPGRADE OF SERVICE INFRASTRUCTURE, EUREKA PARK & THE ISLAND, GREAT BRAK RIVER, MOSSEL BAY DEA&DP: 16/3/1/1/D6/17/0054/13 CapeNature would like to thank you for the opportunity to comment on the proposed development and would like to make the following comments. Please note that our comments only pertain to the biodiversity related impacts and not to the overall desirability of the proposed development. According to the Vegetation Map of South Africa (2009 update) the vegetation type falls within Great Brak Dune Strandveld, Endangered. However, the receiving environment is highly transformed by formal settlement and infrastructure. CapeNature does not object to the proposed upgrade of service infrastructure. The proposed activity will address the current environmental and health problems. CapeNature reserves the right to revise initial comment and request further information based on any additional information that may be received. Yours sincerely Clyde Lamberts The Western Cape Nature Conservation Board trading as CapeNature Board Members: Mr Eduard Kok (Chairperson), Prof Gavin Maneveldt (Vice Chairperson), Ms Francina du Bruyn, Mr Mico Eaton, Dr Edmund February, Prof Francois Hanekom, Mr Carl Lotter, Dr Bruce McKenzie, Ms Merle McOmbring-Hodges, Adv Mandla Mdludlu, Mr Danie Nel
For: Manager (Scientific Services) Copies to: (1) Warren Manuel (Mossel Bay Municipality) (2) Shireen Pullen (DEA&DP) The Western Cape Nature Conservation Board trading as CapeNature Board Members: Mr Eduard Kok (Chairperson), Prof Gavin Maneveldt (Vice Chairperson), Ms Francina du Bruyn, Mr Mico Eaton, Dr Edmund February, Prof Francois Hanekom, Mr Carl Lotter, Dr Bruce McKenzie, Ms Merle McOmbring-Hodges, Adv Mandla Mdludlu, Mr Danie Nel
Cape Environmental Assessment Practitioners (Pty) Ltd Reg. No. 2008/004627/07 Telephone: (044) 874 0365 First Floor, Eagles View Building Facsimile: (044) 874 0432 5 Progress Street, George Web: www.cape-eaprac.co.za PO Box 2070, George, 6530 Dear Registered Interested & Affected Party 28 February 2014 Ref: MOS255/07 Via: e-mail, fax or post RE: AVAILABILITY of Draft Basic Assessment Report (DBAR) for REVIEW & COMMENT - Proposed UPGRADE OF SERVICE INFRASTRUCTURE, GREAT BRAK RIVER, Mossel Bay Department of Environmental Affairs & Development Planning (DEA&DP) Reference: 16/3/1/1/D6/17/0054/13 Exemption Application Ref: 16/3/1/4/D6/17/0011/13 DEA&DP Case Officer: Mrs. Shireen Pullen Cape EAPrac have been appointed as the independent Environmental Assessment Practitioners (EAP), by the Applicant, the Mossel Bay Municipality, to ensure compliance with the regulations contained in the National Environmental Management Act (NEMA No. 107 of 1998) for the proposed Upgrade of Service Infrastructure, Great Brak River, Mossel Bay. It is the intension of the Mossel Bay Municipality to install a bulk sewer pipeline to the Great Brak area south of the N2 highway, including Eureka Park, Dolphin Creek Estate and the Great Brak Island. The proposed Great Brak River sewer pipeline forms part of a long-term plan to allow a change from the existing sewerage system of septic and conservancy tanks currently in use, to a water-borne sewage reticulation system for the area. PLEASE NOTE: This long-term plan will include the requirement for future (new) developments to link directly to this main sewer line, whilst existing township/urban developments will have to link / connect over time (not part of this environmental process). The aim of the long-term reticulation proposal is two-fold: to reduce / remedy the contamination of surface and ground water (and the Great Brak Estuary) (high levels of E.coli) caused by the overflow / leakage of existing septic tank / soak-aways and conservancy tanks; and to phase out the use of the expensive, inconvenient and obnoxious tanker service (honeysucker) currently used to empty the septic and conservancy tank systems and transport of sewage to the Great Brak Waste Water Treatment Works (WWTW). The procedures for a Basic Assessment environmental process in terms of the 2010 Regulations - R544 & R546 are being followed for this application. The following listed activities are applicable: R544 Listed Activity Activity Description R544 (9) The construction of facilities or infrastructure exceeding 1000m in length for the bulk transportation of water, sewage or stormwater (i) with an internal diameter of 0.36m or more; or (ii) with a peak throughput of 120 litres per second or more; excluding where (a) such facilities or infrastructure are for the bulk transportation of water, sewage or stormwater or stormwater drainage inside a road reserve; or (b) such construction will occur within urban areas, but further than 32m from a watercourse. Although the majority of the proposed sewage infrastructure will be installed within road reserves within an urban area, such infrastructure may extend beyond a road reserve, within 32m from the Great Brak River / Estuary (and below the 1:100 year floodline). D.J. Jeffery Directors L. van Zyl
R544 (11) R544 (16) R544 (18) R544 (37) R544 (45) The construction of (xi) infrastructure or structures covering 50m² or more, within a watercourse or within 32m of the watercourse, measured from the edge of the watercourse. The construction or earth moving activities in the sea, an estuary, or within the littoral active zone or a distance of 100m inland of the high water mark of the sea or an estuary whichever is greater, in respect of (iv) rock revetments or stabilising structures, (vi) infrastructure covering 50m² or more. The infilling or depositing of any material of more than 5m³ into, or the dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock of more than 5m³ from (i) a watercourse, (iv) the littoral active zone, an estuary or a distance of 100m inland of the high water mark of the sea, whichever is greater. The expansion of facilities or infrastructure for the bulk transportation of water, sewage or stormwater where (a) the facility or infrastructure is expanded by more than 1000m in length or (b) where the throughput capacity will be increased by 10% or more; excluding where such expansion (i) relates to transportation of water, sewage or stormwater within a road reserve; or (b) such expansion will occur within urban areas, but further than 32m from a watercourse. The expansion of facilities within a distance of 100m inland of the highwater mark of the sea or an estuary, whichever is the greater, for (iv) rock revetments or stabilising structures, (vi) infrastructure by more than 50m², where such expansion will result in an increase in the development footprint of such facilities. The installation of sewage infrastructure within 32m from the Great Brak River / Estuary (and below the 1:100 year floodline). The installation of sewage infrastructure within 100m of the high water mark of the Great Brak River / Tidal Estuary (and below the 1:100 year floodline). The installation of sewage infrastructure within 32m from the Great Brak River / Tidal Estuary (and below the 1:100 year floodline). The sewer reticulation is to link to the approved Midbrak Sewer Pipeline (Authorisation date 1 Nov.2012). Although the majority of the proposed sewage infrastructure will be installed within road reserves within an urban area, such infrastructure may extend beyond a road reserve, within 32m from the Great Brak River / Estuary (and below the 1:100 year floodline). Possible need to expand existing sewage infrastructure within 100m of the highwater mark of the Great Brak Estuary. R546 Listed Activity Activity Description R544 (12) R546 (16) R546 (24) The clearance of an area of 300 square metres or more of vegetation where 75% or more of the vegetative cover constitutes indigenous vegetation: within an Endangered ecosystem, with a CBA & within 100m of the highwater mark of an estuary. The construction of (iv) infrastructure covering 10m² or more, within 32m of a watercourse: Inside urban areas: areas zoned for use as public open space; areas designated for conservation use is Spatial Development Frameworks; areas within 100m of the highwater mark. The expansion of (d) infrastructure where the infrastructure will be expanded by 10m² or more within 32m of a watercourse: Inside urban areas: areas zoned for use as public open space; areas designated for conservation use is Spatial Development Frameworks The clearance of approx. 1965m² of indigenous wetland periphery vegetation beside the Great Brak Estuary, for the installation of a section of sewer pipeline. This area falls with an Endangered ecosystem, terrestrial & aquatic CBA, within 100m of the highwater mark of the estuary. The installation of sewage infrastructure within 32m from the Great Brak River / Tidal Estuary (and below the 1:100 year floodline): within Terrestrial and Aquatic CBAs, and an Endangered Vegetation type. The installation of sewage infrastructure within 32m from the Great Brak River / Tidal Estuary (and below the 1:100 year floodline): within Terrestrial and Aquatic CBAs, and an Endangered Vegetation type. Deviation has been applied for from the following requirements of Regulation 54(2) of the Public Participation process: R54 (1)(a)(i) fixing a notice board at a place conspicuous to the public at the boundary or on the fence of the site where the activity to which the application relates is or is to be undertaken (ii) an alternative site (no alternative sites considered) - As a linear activity, the proposed sewer infrastructure will traverse several properties, the boundaries of which are often beyond public view. Site Notices were placed at the entrance to Eureka Park and on either side of
The Island bridge, and Notices were placed at local public venues (the Total Garage, De Dekke & Dolphin Creek Golf Club). R54 (1)(b)(ii) giving written notice to the occupiers of the site where the activity is or is to be undertaken or to any alternative site where the activity is to be undertaken service infrastructure to align within / along municipal streets. R54 (1)(b)(iii) giving notice to owners or occupiers of land adjacent to the site or alternative sites - not necessary for linear activities. Exemption has been applied for from the following regulation: 10(2)(d) Advertising the environmental decision in a newspaper. DEA&DP Ref: 16/3/1/4/D6/17/0011/13. As a registered Interested & Affected Party (I&AP), you are hereby notified that the Draft Basic Assessment Report (DBAR) is available for review and comment for a period of 40 days extending from Monday, 3 March to Monday, 14 April 2014. Hard copies of the Draft BAR have been placed at the following venues for review: Great Brak Main Library (located at 2 Watsonia Avenue, Great Brak), and Mossel Bay Municipality, Technical Depart. (located at 15 Charles Street, Great Brak). Please do not remove these copies from the above venues. A digital copy of the Draft BAR will also be available on the Cape EAPrac website at: www.cape-eaprac.co.za Active Projects Great Brak Infrastructure Upgrade Please submit your full contact details and any comments you may have to Cape EAPrac (contact details below) on or before 14 April 2014: Cape EAPrac ATTN: Mrs Siân Holder P.O. Box 2070, George, 6530 Tel: 044 874 0365; Fax: 044 874 0432 E-mail: sian@cape-eaprac.co.za Upon closing of the 40-day comment period, comments received will be considered and feedback provided, after which the comments and responses will be included in the Final Basic Assessment Report. This Final BAR will then be made available for a further 21-day comment & review period, prior to / along with submission to DEA&DP for decision-making. If you require any further assistance, please do not hesitate to contact this office directly. Kind regards, Review & Comment Period: Siân Holder For Cape EAPrac Monday, 3 March to Monday, 14 April 2014. In the event that you or your organization have been wrongly identified as a stakeholder, or in the event that the responsibility of providing comment on this application lies with another party within your organization, either forward this notice to them or notify Cape EAPrac within one week of receiving this notice of the correct party that should be informed. Should you be aware of any relevant legislation that needs to be complied with, in addition to this process, please inform us of such as soon as possible.
Cape Environmental Assessment Practitioners (Pty) Ltd Reg. No. 2008/004627/07 Telephone: (044) 874 0365 First Floor, Eagles View Building Facsimile: (044) 874 0432 5 Progress Street, George Web: www.cape-eaprac.co.za PO Box 2070, George, 6530 Dear Registered State Department, Organ of State / Stakeholder 28 February 2014 Ref: MOS255/08 Via: e-mail, fax or post RE: AVAILABILITY of Draft Basic Assessment Report (DBAR) for REVIEW & COMMENT - Proposed UPGRADE OF SERVICE INFRASTRUCTURE, GREAT BRAK RIVER, Mossel Bay Department of Environmental Affairs & Development Planning (DEA&DP) Reference: 16/3/1/1/D6/17/0054/13 Exemption Application Ref: 16/3/1/4/D6/17/0011/13 DEA&DP Case Officer: Mrs. Shireen Pullen Cape EAPrac have been appointed as the independent Environmental Assessment Practitioners (EAP), by the Applicant, the Mossel Bay Municipality, to ensure compliance with the regulations contained in the National Environmental Management Act (NEMA No. 107 of 1998) for the proposed Upgrade of Service Infrastructure, Great Brak River, Mossel Bay. It is the intension of the Mossel Bay Municipality to install a bulk sewer pipeline to the Great Brak area south of the N2 highway, including Eureka Park, Dolphin Creek Estate and the Great Brak Island. The proposed Great Brak River sewer pipeline forms part of a long-term plan to allow a change from the existing sewerage system of septic and conservancy tanks currently in use, to a water-borne sewage reticulation system for the area. PLEASE NOTE: This long-term plan will include the requirement for future (new) developments to link directly to this main sewer line, whilst existing township/urban developments will have to link / connect over time (not part of this environmental process). The aim of the long-term reticulation proposal is two-fold: to reduce / remedy the contamination of surface and ground water (and the Great Brak Estuary) (high levels of E.coli) caused by the overflow / leakage of existing septic tank / soak-aways and conservancy tanks; and to phase out the use of the expensive, inconvenient and obnoxious tanker service (honeysucker) currently used to empty the septic and conservancy tank systems and transport of sewage to the Great Brak Waste Water Treatment Works (WWTW). The procedures for a Basic Assessment environmental process in terms of the 2010 Regulations - R544 & R546 are being followed for this application. The following listed activities are applicable: R544 Listed Activity Activity Description R544 (9) The construction of facilities or infrastructure exceeding 1000m in length for the bulk transportation of water, sewage or stormwater (i) with an internal diameter of 0.36m or more; or (ii) with a peak throughput of 120 litres per second or more; excluding where (a) such facilities or infrastructure are for the bulk transportation of water, sewage or stormwater or stormwater drainage inside a road reserve; or (b) such construction will occur within urban areas, but further than 32m from a watercourse. Although the majority of the proposed sewage infrastructure will be installed within road reserves within an urban area, such infrastructure may extend beyond a road reserve, within 32m from the Great Brak River / Estuary (and below the 1:100 year floodline). D.J. Jeffery Directors L. van Zyl
R544 (11) R544 (16) R544 (18) R544 (37) R544 (45) The construction of (xi) infrastructure or structures covering 50m² or more, within a watercourse or within 32m of the watercourse, measured from the edge of the watercourse. The construction or earth moving activities in the sea, an estuary, or within the littoral active zone or a distance of 100m inland of the high water mark of the sea or an estuary whichever is greater, in respect of (iv) rock revetments or stabilising structures, (vi) infrastructure covering 50m² or more. The infilling or depositing of any material of more than 5m³ into, or the dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock of more than 5m³ from (i) a watercourse, (iv) the littoral active zone, an estuary or a distance of 100m inland of the high water mark of the sea, whichever is greater. The expansion of facilities or infrastructure for the bulk transportation of water, sewage or stormwater where (a) the facility or infrastructure is expanded by more than 1000m in length or (b) where the throughput capacity will be increased by 10% or more; excluding where such expansion (i) relates to transportation of water, sewage or stormwater within a road reserve; or (b) such expansion will occur within urban areas, but further than 32m from a watercourse. The expansion of facilities within a distance of 100m inland of the highwater mark of the sea or an estuary, whichever is the greater, for (iv) rock revetments or stabilising structures, (vi) infrastructure by more than 50m², where such expansion will result in an increase in the development footprint of such facilities. The installation of sewage infrastructure within 32m from the Great Brak River / Estuary (and below the 1:100 year floodline). The installation of sewage infrastructure within 100m of the high water mark of the Great Brak River / Tidal Estuary (and below the 1:100 year floodline). The installation of sewage infrastructure within 32m from the Great Brak River / Tidal Estuary (and below the 1:100 year floodline). The sewer reticulation is to link to the approved Midbrak Sewer Pipeline (Authorisation date 1 Nov.2012). Although the majority of the proposed sewage infrastructure will be installed within road reserves within an urban area, such infrastructure may extend beyond a road reserve, within 32m from the Great Brak River / Estuary (and below the 1:100 year floodline). Possible need to expand existing sewage infrastructure within 100m of the highwater mark of the Great Brak Estuary. R546 Listed Activity Activity Description R544 (12) R546 (16) R546 (24) The clearance of an area of 300 square metres or more of vegetation where 75% or more of the vegetative cover constitutes indigenous vegetation: within an Endangered ecosystem, with a CBA & within 100m of the highwater mark of an estuary. The construction of (iv) infrastructure covering 10m² or more, within 32m of a watercourse: Inside urban areas: areas zoned for use as public open space; areas designated for conservation use is Spatial Development Frameworks; areas within 100m of the highwater mark. The expansion of (d) infrastructure where the infrastructure will be expanded by 10m² or more within 32m of a watercourse: Inside urban areas: areas zoned for use as public open space; areas designated for conservation use is Spatial Development Frameworks The clearance of approx. 1965m² of indigenous wetland periphery vegetation beside the Great Brak Estuary, for the installation of a section of sewer pipeline. This area falls with an Endangered ecosystem, terrestrial & aquatic CBA, within 100m of the highwater mark of the estuary. The installation of sewage infrastructure within 32m from the Great Brak River / Tidal Estuary (and below the 1:100 year floodline): within Terrestrial and Aquatic CBAs, and an Endangered Vegetation type. The installation of sewage infrastructure within 32m from the Great Brak River / Tidal Estuary (and below the 1:100 year floodline): within Terrestrial and Aquatic CBAs, and an Endangered Vegetation type. Deviation has been applied for from the following requirements of Regulation 54(2) of the Public Participation process: R54 (1)(a)(i) fixing a notice board at a place conspicuous to the public at the boundary or on the fence of the site where the activity to which the application relates is or is to be undertaken (ii) an alternative site (no alternative sites considered) - As a linear activity, the proposed sewer infrastructure will traverse several properties, the boundaries of which are often beyond public view. Site Notices were placed at the entrance to Eureka Park and on either side of
The Island bridge, and Notices were placed at local public venues (the Total Garage, De Dekke & Dolphin Creek Golf Club). R54 (1)(b)(ii) giving written notice to the occupiers of the site where the activity is or is to be undertaken or to any alternative site where the activity is to be undertaken service infrastructure to align within / along municipal streets. R54 (1)(b)(iii) giving notice to owners or occupiers of land adjacent to the site or alternative sites - not necessary for linear activities. Exemption has been applied for from the following regulation: 10(2)(d) Advertising the environmental decision in a newspaper. DEA&DP Ref: 16/3/1/4/D6/17/0011/13. As a registered Stakeholder, State Department or Organ of State you are hereby notified that the Draft Basic Assessment Report (BAR) is available for review and comment for a period of 40 days extending from Monday, 3 March to Monday, 14 April 2014. Included with this correspondence please find a complete digital (CD) copy of the Draft BAR. Hard copies of the Draft BAR have been placed at the following venues for review: Great Brak Main Library (located at 2 Watsonia Avenue, Great Brak), and Mossel Bay Municipality, Technical Depart. (located at 15 Charles Street, Great Brak). Please do not remove these copies from the above venues. A digital copy of the Draft BAR will also be available on the Cape EAPrac website at: www.cape-eaprac.co.za Active Projects Great Brak Infrastructure Upgrade Please submit your full contact details and any comments you may have to Cape EAPrac (contact details below) on or before 14 April 2014: Cape EAPrac ATTN: Mrs Siân Holder P.O. Box 2070, George, 6530 Tel: 044 874 0365; Fax: 044 874 0432 E-mail: sian@cape-eaprac.co.za Upon closing of the 40-day comment period, comments received will be considered and feedback provided, after which the comments and responses will be included in the Final Basic Assessment Report. This Final BAR will then be made available for a further 21-day comment & review period, prior to / along with the submission to DEA&DP for decision-making. If you require any further assistance, please do not hesitate to contact this office directly. Kind regards, Review & Comment Period: Siân Holder For Cape EAPrac Monday, 3 March to Monday, 14 April 2014. In the event that you or your organization have been wrongly identified as a stakeholder, or in the event that the responsibility of providing comment on this application lies with another party within your organization, either forward this notice to them or notify Cape EAPrac within one week of receiving this notice of the correct party that should be informed. Should you be aware of any relevant legislation that needs to be complied with, in addition to this process, please inform us of such as soon as possible.