PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report April 2015 ISSUES TRAIL Issues submitted post Scoping Phase for inclusion in the Draft Environmental Impact Assessment Report Notes on the Issues Trail: Issues submitted are listed in alphabetical order of the surname of the person that submitted that issue. Some issues were submitted by I&APs in PDF format and had to be retyped by Sustainable FuturesZA (SFZA). Minor typing errors may have occurred. For some issues, headings were added or words highlighted to make it easier for the reader to identify the focus of that issue. The response from EAP refers to a response from the EAP team, which includes SFZA. For the Issues Trail, issues were translated from Afrikaans to English. The original issues submitted are included in Appendix E No. Issue Access for specialist studies 1. Morning Mercia, I contacted Frans van Rooyen at SANParks to notify that I was coming through. He told me that I require written permission from the community of Melkbosrant, who are the owners of the land that SAN Parks merely manage on their behalf as part of the reserve. SANParks will not grant me access without this. Would you know how I would go about doing this? I am booked to go through there tomorrow, so would like to get this done ASAP if possible. 2. Kind regards, Mathew Ross (Pr Sci Nat, MSc) From: Frans Van [mailto:[email protected]] Sent: 02/04/2015 07:52 AM To: Lloyd Theunissen Subject: RE: ACCESS TO THE PARK 09 APRIL 2015 Hi Lloyd, Comments & Response Report Rooyen Raised by Kind regards, Mathew Ross (Pr Sci Nat, MSc), comment by email, 17 March 2015 Response from CES EIA team or Hydro SA Good morning Frans van Rooyen Please find attached the requested letter. Your positive response will be highly appreciated. Kind regards Lloyd Theunissen, Trustee, Riemvasmaak Community Development Trust, comment by e-mail, 17 March 2015. Lloyd Theunissen, Trustee, Riemvasmaak Community Development Trust, comment by e-mail, 02 Please allow Mathew Ross and his team access to the park, tomorrow, 18 March 2015. From: "Lloyd Theunissen" <[email protected]> To: "'Frans Van Rooyen'" <[email protected]> Cc: <[email protected]>, "'Mercia Grimbeek'" <[email protected]>, "'Niel Theron'" <[email protected]>, <[email protected]> Subject: RE: ACCESS TO THE PARK 09 APRIL 2015 Page 1 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue Raised by April 2015. I’ll need a request and you be specific where access is needed and the reason access is needed for also the amount of time they’ll spend. April 2015 Response from CES EIA team or Hydro SA Date: 2 April 2015 09:38:16 GMT+2 Good morning Frans 1. Access to the Park will need to be approved by Park Manager. I do not understand your e-mail. 2. This is not the first time that access is requested and granted. I just need from you the OK that you give authorization to whoever to access Melkbosrant area. 3. Hydro-SA is in the process of applying to install a hydro power plant in this specific area and need to do the necessary inspections and comply with the necessary requirements as stipulated by the relevant Governmental Department. Regards! Frans 4. As trustee of the Riemvasmaak Community Development Trust, I, Lloyd Wilfred Theunissen, on behalf of the trustees and the Riemvasmaak community, hereby give authorisation to Niel Theron and his team to gain access to the Melkbosrand area of the park on 09 April 2015. The time, gate of entry and period need for the day, Hydro-SA will communicate directly with you and or a designated member your team. 5. I hope and trust that the above request is clear and in order. 6. Kind regards and should you be travelling over the long weekend, please travel safely. Lloyd Theunissen Benefits of the Project 3. As a community member of Riemvasmaak I have concerns. If the the project starts, will there be job opportunities for the people of Riemvasmaak? Willl the hydro power station benefit tourism? Comments & Response Report Bennie Kordom, Marchand Community, comment by comment form, 20 March 2015 The power plant will create jobs during construction and operations. During the construction phase approximately 150 -200 jobs will be available for the local cimmunity. This includes the Riemvasmaak community. The hydro power plant has the potential to benefit Page 2 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue What are the direct benefits for the people of Riemvasmaak? Raised by April 2015 Response from CES EIA team or Hydro SA tourism through the Economic Development spend which it will be obligated to spend as part of the Renewable Energy Independent Power Producer Program(REIPPP). The Riemvasmaak people can benefit in three ways: Rental Income as the Developer will lease the land on which the power plant is to be constructed. Direct job creation Dividend Income – the community has the opportunity to purchase between 1% and 5% shareholding in the project. This is another condition of the REIPPP General 4. Hi Shawn, I would like to renew my status as I&AP Regards Nardus du Plessis Section Ranger SANParks: Augrabies Falls National Park Nardus du Plessis Section Ranger SANParks: Augrabies Falls National Park, comment by email, 10 March 2015 Dear Nardus, Thank you for your e-mail regarding the proposed Riemvasmaak Hydro Power environmental impact assessment. Nardus you and all of the key SANPArks staff at Augrabies National Park, SANParks Regional, SANParks Head Office and SANParks Planning have been registered as interested and affected parties. My team is currently updating the database of all interested and affected parties. I hereby confirm that you have been registered as a interested and affected party. If there are any additional persons who would like to register please feel free to send me their contact details. 5. WESSA in the Northern Cape is not able to deal with these matters. Please do not send faxes or hard copies of documents to us. They will be destroyed. Comments & Response Report Wildlife and Environmental Society of South Africa, Northern Cape Branch, Sincerely, Shawn Johnston Comment noted. Page 3 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue Registered mail will NOT be collected. 6. Please consult the website for other WESSA contact details, or direct your e-mail to [email protected] or [email protected] We thank you for showing interest in one of our amazing adventures. Our office will be in contact shortly to discuss your booking. Raised by comment by email, 19 March 2015 April 2015 Response from CES EIA team or Hydro SA The Kalahari Team, comment by e-mail, 13 March 2015 Comment noted. Luel Culwick, Sidale Energy Solutions, comment by email, 16 March 2015 Owen Peters, Eskom, comment by e-mail, 19 March 2015. Ramon Odendal, Eskom Land and Rights, comment by e-mail, 25 March 2015 Dear Luel, Thank you for your e-mail. interested and affected party. Please note we have recently moved servers and upgraded our website. If you have not had a response within 24 hours please contact us directly on +27 (0)54 453 0001 or +27 (0)82 476 8213, alternatively [email protected] 7. We look forward to seeing in the Green Kalahari. Kind Regards The Kalahari Team. Hi Shawn I am already an IAP. I assume I don’t need to register again? Luel Culwick, Sidale Energy Solutions 8. Eskom’s rights and infrastructure affected by the proposal. 9. Please register me as an interested and affected party. Eskom representative. You are a registered Sincerely, Shawn Johnston Dear Owen Peters, You have been registered as an interested and affected party and your comment has been noted. Sincerely, Shawn Johnston. Dear Ramon, Thank you for registering as an interested and affected party. Our team will keep you informed regarding the availability of the DEIR. Sincerely, Shawn Johnston Comments & Response Report Page 4 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. 10. 11. Issue The weir is extremely close to my property and I live on the island adjacent to the proposed weir. Hi Shawn, Please register or re-register as per attached the 4 persons from SANParks side as I&EP. With any communications please send to all 4 of these persons. Also find attached previous comments/concerns document of SANParks. Raised by Gert Heese, Orleans Boerdery, Groot Vaalkop Eiland, comment by e-mail, 15 March 2015 Frans van Rooyen, Park Manager: Augrabies Falls National Park, comment by email, 16 March 2015 Regards! Frans van Rooyen Park Manager: Augrabies Falls National Park April 2015 Response from CES EIA team or Hydro SA Dear Mr. Gert Heese, Thank you for your e-mail. You have been registered as an affected party on the project database. I’m forwarding your comments onto the environmental team and will convene a meeting with you shortly. Sincerely, Shawn Johnston. Dear Mr. Frans van Rooyen, Thank you for your e-mail. I hereby acknowledge receiving your e-mail and registration of the following persons: 1. 2. 3. 4. Howard Hendricks; Andre Riley; Frans van Rooyen; and, Lucius Moolman. I hereby confirm that the above mentioned person have been registered as interested and affected parties (I&APs) for the proposed Riemvasmaak Hydro-Power Station EIA. Mr. Frans van Rooyen, I acknowledge receiving your five page document and will forward it to Ted Avis and Bill Rowlston (of EOH CES, the project EAP). 12. Information on the social, labour and plans. Communication and public sector meetings. Comments & Response Report Alfred Tieties, Director Technical Services, Z.F. Mgcawu District Municipality – Upington, comment by comment form, 19 March 2015 Sincerely, Shawn Johnston Comment noted. Presentation was scheduled to be made to the ZF Mgawu District Municipality on Friday 17 April to provide more detail about the proposed project. Unfortunately the ZFM District Municipality cancelled and we are awaiting confirmation of a new date. Page 5 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report April 2015 No. Issue Raised by Response from CES EIA team or Hydro SA Department of Environmental Affairs, SANParks & Hydro SA Meeting/Site Visit 23 October 2014 13. Hi Niel and Mercia, Department of The attendance register, notes, and SANParks Position Environmental Paper are recorded as a record of the meeting and Below are my notes from the recent meeting with DEA and Affairs, SANParks included into environmental impact assessment process. SANParks, focusing on the questions raised. & Hydro SA meeting and site The South African National Parks Position Paper, August 1. During culvert construction will game still have access to visit, 23 October 2014, 7 page document is hereby appended as part of the the river? Will need to allow for this. Is it possible to also 2014. Notes record of the notes of the National Department of provide watering holes along pipeline. Will need to map recorded by Dr. Environmental Affairs, SANParks and Hydro SA meeting game paths and ensure access during construction. Ted Avis, CES and site visit. 2. Pipeline to follow existing road/track. Disturbances during construction to be rehabilitated. 3. The small drainage lines to Orange river will need to continue functioning so pipeline cannot block these. A storm water management plan approved by DWA will be required. Where these drainage lines occur culverts may need to be deeper to avoid the pipeline been exposed. 4. Road width will be 6m and servitude about 20m wide. 5. Danie- have approved many renewable energy projects. Third time they have been engaged with this project and have great concern about the falls. Whether activity takes place outside park the effect will be on the park. EIA needs to deal with this and must have guarantee that falls and national park cannot be compromised. It’s a Schedule 1 protected area. Mitigation is easy but the fundamental issue that there must be measures to sustain the falls and hence the park. 6. The holistic and sustainable perspective is NB to DEA. When water bypasses falls this is seen as a key issue. 7. Gap in EIA was lack of flow data, short and long term/ and risk of low flows. Must be properly managed as if not can be a fatal flaw. Second largest water fall in Africa. Comments & Response Report 1. This aspect has been dealt with in the Faunal Specialist Study and the impact section of the EIAR. 2. Noted and recommended 3. A Stormwater management Plan would need to be produced as a condition of approval. Detailed design will determine where the pipeline needs to be deeper to achieve the mitigation measure of minimizing visual impacts through burial. 4. This relates to the required servitude for the pipeline/conveyance system. 5. Recommendations in the EMP and mitigation measures in the EIAR deal with this issue, which has been a central focus of the EIA. 6. Noted and addressed. 7. More detailed flow data and analyses are included. See for example Section 3.3 of the EIAR. 8. This has been addressed in the DEIR, the development will not avail istelf of any water once the flow is reduced to 30m3/s. This is the environmental flow required and the power plant will be not operate at this level. 9. The design of the weir is such that it will guarantee 30 cumecs of water over the falls. 10. The Hydrological Model looked at the past sixty years (although the banking model will only be based on the last 20 years – as this more Page 6 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue 8. DEA need assurances from developer that they will not affect the falls. Water availability over the falls over a long term period needs to be investigated. Must consider long term trends especially extended dry periods and also climate change. 9. HydroSA will be able to guarantee 30 cumecs over the falls, based on the weir design. 10. Need to look at last 20 to 50 years when there was less than 30 cumecs over the falls. Need to interrogate data and include a more detailed analysis of hydrology and flows in the system. 11. HydroSA – the option of designing an additional sluice gate that is under the control of the park and after a protocol is followed they could shut down the plant (over-ride switch). Give them a physical mechanism to control flows and hence guarantee flow. 12. SANPARKS- support renewable energy but Augrabies is a national park and therefore cannot support the construction of a weir or power lines within the park. 13. RVM community have been asking if SANPARKS is approving the HEP scheme. Have received questions from public about this. SANPARKS concerns are not included in the FSR as they were received after FSR was completed. 14. SANPARKS needs to provide a list of their concerns so it can be incorporated into the project design. 15. RVM community – they are in favour of project, subject to acceptable environmental impacts. Raised by April 2015 Response from CES EIA team or Hydro SA accurately reflects the current flow regime – based on controls at Van Der Kloof and Gariep Dams) Over the last 20 years there have been 561 days (out of 7300 days) where the flows have been less than 30m3/sec (7.7%) whereas there has been 233 days over the last 10 years (3650 days - 6.4%) 11. An emergency shutdown procedure is decribed in Section 3.3.2 of the EIAR. 12. Noted 13. SANParks concerns have been received and are dealt with in various and many places within the EIAR. 14. As above 15. Noted 16. Noted. A legal review relating to land ownership and management of the land was undertaken and the results are presented in Section 2.4 of the EIAR. 17. Noted 18. Noted. Dealt with in Section 2.4 aqnd elsewhere in the EIAR. 19. Noted. The EIA has focused on all aspects of the project’s potential impacts. 20. As for response 18 above. 21. Noted with concern 22. See asection 3.3.1 of the EIAR. 23. A legal review relating to land ownership and management of the land was undertaken and the results are presented in Section 2.4 of the EIAR. 24. Has been done 25. Noted 16. DEA Minister is responsible for settlement of land in protected areas and protected status must continue. A settled land claim must take protected status into account Comments & Response Report Page 7 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue and SANPARKS has jurisdiction over the area. Raised by April 2015 Response from CES EIA team or Hydro SA 17. Niel Theron (HydroSA) is aware of all the rights they need to get. Prerequisite to bid is the environmental authorization. 18. DEA Kalie Naude. National Park authority sits with SANPARKS and there is no other act that overrides this. Deproclamation can only be done by parliament. Management authority (SANParks) must give permission for activities that take place in a national park. DEA look negatively at developments in National Parks. If SANPARKS as management authority is opposed to development then approval is unlikely. Their management plan is a legislated instrument that must be complied with. If the project is not part of the management plan then changing the plan could delay the project by years. 19. SANPARKS Hugo Bezuidenhout - Need to also adhere to management plan in park as it is not all about the falls. 20. SANPARKS comments relate to remoteness, zonation of areas. If project required changes to zonation then management plan needs must be changed and Minister must approve it. 21. Danie Smit of DEA. Would like all parties to work together but once they receive report and if it has negative comments from SANPARKS then approval highly unlikely. 22. The 30 cumecs figures need to be fully justified. How did HydroSA determine this as the minimum flow required for the falls? Elucidate in the EIA. 23. Land claim on Portion 497/0 could take a number of years to remove. Land is currently zoned remote in terms of SANParks management plan. Comments & Response Report Page 8 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue 24. Need to check listing notice 3 because if protected area then there are much lower thresholds. Raised by April 2015 Response from CES EIA team or Hydro SA 25. Option of approving the EIA subject to changes to management plan - not an option according to Danie Smit. End of questions Minutes prepared by Ted Avis The South African National Parks Position Paper, August 2014, 7 page document is hereby appended as part of the record of the notes of the National Department of Environmental Affairs, SANParks and Hydro SA meeting and site visit. Eskom Network Planning 13. Dear Lebogang, I trust this finds you well. As you are aware, Tom Bezuidenhout recently submitted the Grid Application for the proposed project. I am currently finalising the Environmental Impact Assessment for the project and one of the conditions imposed by the Department of Environmental Affairs (“DEA”) is that we obtain a letter from Eskom expressing the need or desireability for such a project in the area. This is not a request usually imposed on an IPP. Discussions with Robin Buske at the Brackenfell office have lead me to you. Lebohang Motoai Grid access Unit, Eskom Holdings SOC, comment by e-mail, 07 April Dear Mercia, We do not write such letters to all IPP`S, We do not even have a template for such letters. I am sorry cannot assist you with such letter. Regards, Lebohang Motoai Grid access Unit For ease of reference I insert the clause from the letter received from DEA below. Given the current status quo and the fact that the project would feed into the National Grid - a national rather than even provincial shortage would be relevant. Kindly advise if you would be able to assist with such a letter and if not would you kindly point me in the direction of someone that could assist please. Comments & Response Report Page 9 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue Raised by April 2015 Response from CES EIA team or Hydro SA Best regards 14. Mercia Grimbeek Project Manager Good Day Mercia, Please find a summary of our discussion for the meeting regarding Hydro SA’s RVM project. Please note that the attached minutes do not bind or commit Eskom to anything but merely reflect a record our discussion. Robin Buske, Network Development Planning Engineer, Eskom Holdings SOC, comment by email, 07 April 2015 Meeting minutes of the Eskom-Hydro SA meeting regarding the transmission integration of the project are appended. Six page document. Formal commitment and costing for your connection is only done when you officially apply and pay for your CEL and Eskom provides you with a CEL. I believe this has been done and Eskom GAU has received your official application on the 2nd April 2015 as it was sent to me. This discussion also ignores the preferred connection of any selected bidder approved in Round 4, for which no announcement has been made yet by the DoE. Regards, Robin Issues Raised By Kobus van Coppenhagen, Gerhard Smit & Andrew Hockly 15. To whom it may concern Kobus van Coppenhagen, We have been informed several months ago by AURECON, Augrabies, that they are no longer acting as consultants for the above comment by ementioned application and that they are currently involved in mail, 05 March litigation with the applicant. This follows more than 18 2015. months of requests from us for a copy of the so called upgraded application form, which they have refused to provide, citing invalid reasons. Comments & Response Report Dear Mr van Coppenhagen Many thanks for your email. As you note, we are the new EAP on the project, and assure you that we will execute the EIA in a fair and transparent manner. Mr Bill Rowlston of CES is responsible for writing the EIA, as he has a large amount of expertise in this field, and I act as study leader. Public consultation is undertaken by Shawn Johnston, who specialises in this field, and has worked extensively in the area. I copy them both in. Further Page 10 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue We have come to the conclusion that the DEA is either indulging the applicants tardiness, for unknown reasons, or just don't care about our National Heritage, both of which are intolerable situations. Failing a prompt response from this department in due course, we will have no option but to approach the office of the Minister of Environmental Affairs directly, for relief. We are also putting on record the fact that it seems as if no water license application has been submitted, because we have also requested that document, without success. We want to re-iterate our prior concern that the application is procedurally and administratively flawed, because it seems as if the applicant is conducting this "upgraded" procedure on their own Terms of Reference, i.e. without the proper directions/instructions of the DEA and without any deadline for conclusion of the procedure and even without a consultant! If the DEA did issue a new set of instructions for this upgrade, after requesting the revised application on 18 June 2013, we would like to receive a copy of the full documentation. Regards Kobus van Coppenhagen 0836564498 Raised by April 2015 Response from CES EIA team or Hydro SA correspondence should be addressed to Shawn. I wish to confirm that we have all previous information, reports, communications and data from Aurecon to enable us to complete the EIA process. All of your previous comments were dealt with and incorporated into the Final Scoping Report, which we have reviewed together with the specialist studies to ensure all issues have been or will be dealt with. Would you like Shawn to give you a list of your communications we received from Aurecon, just to be certain? Currently we are updating and finalising the specialist reports to ensure that they address all issues and concerns raised by IAP’s, and that they deal with the single, 40 Mwatt project. We are currently initiating the drafting of the EIA report, and hope to circulate this towards the end of April. Shawn will notify all registered IAP’s of the exact date, and will also circulate an email updating everyone on the current status of the EIA phase. We will also schedule focus group meetings with key stakeholders during the EIA phase. We are not involved in the WULA application but I will ask Mercia, the HydroSA environmental manager (and copied herein), to send this to you when available. The other documents you refer to will be available as part of the DEIR. You will note that I have not copied all the parties you included in your email. In my experience the authorities and other officials prefer not to be copied in, as all correspondence is codified and included in the EIA report and its annexures. You are, of course, free to continue copying them in if you so choose. Regards Ted Avis Comments & Response Report Page 11 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. 16. Issue Subject: Hydro-electric power station in the Augrabies Falls National Park Dr. Avis We are a registered affected party for the above mentioned application, which was launched by three separate SPE's in Dec 2012 and which was subsequently "upgraded" to double the capacity of the proposed installation. For the sake of brevity we will not elaborate any further, assuming that your company is in possession of the details of all the registered IAP's together with all the correspondence which was exchanged between IAP's and AURECON. As a matter of interest; we have suggested 2 years ago that AURECON should be replaced as the consultants because they were conducting a procedurally flawed and administratively unfair process. This happened a few months ago and your company has the unenviable task of concluding the process in a transparent and fair manner. As a matter of record it must be noted that a precedent was set several years ago when another applicant was directed by the Competent Authority, to allow the IAP's to participate in the appointment of the consultants due to the impacts of the proposal, which was also our notion in this case, from the outset. Details of this directive can be provided on request and which would then serve as proof of precedent. Raised by Kobus & Hannecke van Coppenhagen, Augrabies, comment by email, 09 March 2015. April 2015 Response from CES EIA team or Hydro SA We confirm that we have all the relevant details of previously registered IAPs. We note your comment that another applicant was directed by the Competent Authority; to allow the IAP's to participate in the appointment of the consultants, but confirm that this was not a requirement in this case. Based on a perusal of the Issues and Response trail in the Final Scoping Report, it appears that a large amount of comemnts from you are included. However, we are not in a position to undertake an audit of your comemnts, as we do not have the original communications. You would be best placed to do so. We do respectfully request that your facilitator contact us (and perhaps others) to confirm our status as affected parties, especially due to our many valid concerns and the incompetent manner in which it was being dealt with. We also need to verify with the facilitator that your company is in possession of a full record our correspondence, for consideration. In the meantime we do need a copy of the valid upgraded application (requested by DEA 18 June 2013) together with Comments & Response Report Page 12 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. 17. Issue the subsequent instructions and directives issued by this competent authority, which would have validated the application and which would lead the consultants in the design of the Scoping and EIA Reports. We also need a copy of the water license application, together with the instructions and directives issued by DWA. Regards Kobus & Hannecke van Coppenhagen Augrabies. 0836564498 Subject: Re: Application for Hydroscheme in the Augrabies Falls National Park Good day We are not sure whether this e-mail is actually meant for the office of Mr. Gordon although his name appears on the related documents. In order to remove any ambiguity this email is adressed to the Director General; Ms. Nosipho Ngcaba, for attention. Regards 18. Kobus & Hannecke van Coppenhagen 0836564498 Good day Shawn Our telecon of this morning refers; Mr G Smit forwarded contact details of EOH CES on 9 March, after this e-mail was sent. Attached below is a copy of an e-mail which was sent to DEA on 5 March and which we redirected to the DG after discovering that M Gordon's portfolio did not include environmental authorization, although his details have been listed since the launch of the application. The same was true of DWA where the name of an official, which has retired years before the application, was used, but we cleared that Comments & Response Report Raised by April 2015 Response from CES EIA team or Hydro SA Kobus & Hannecke van Coppenhagen, Augrabies, comment by email, 10 March 2015. Noted Kobus van Coppenhagen, Augrabies, comment by email, 11 March 2015. Dear Mr. Kobus & Mrs Hannecke van Coppenhagen, Thank you for our telephone conversation early this morning. I wish to thank you both for highlighting your concerns about the proposed project. I look forward to engaging with you and other affected parties during the environmental impact assessment phase. I hereby acknowledge receiving your e-mail highlighting the communications with the National Department of Environmental Affairs and the concerns you have raised regarding the quality of reports and the correct facts. I will make sure these comments are passed onto Dr. Ted Avis and Dr. Bill Rowlston at EOH Coastal & Page 13 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue issue up by ourselves and notified the EAP. We want to bring your attention to the fact that documents should not be littered with obvious mistakes if you want to conduct a fair and transparent process. The trend of the document is self explanatory and now that we have your contact info, you could share it with the applicant. Raised by April 2015 Response from CES EIA team or Hydro SA Environmental Services. I look forward to meeting with you and other affected parties during the EIA phase. Sincerely, Shawn Johnston Regards 19. Kobus van Coppenhagen 0836564498 Good day Shawn and Ted The new BID which was forwarded for our attention refers; (1) Firstly, we do not want to have to correct you on certain aspects of this "application" on a constant basis. We have referred to the fact (to AURECON) that the PROJECT TITLE was ambiguous, because the public would not know that the site is located within the Augrabies Falls National Park (AFNP) and that the proposed activities would directly affect the status of this National Park, i.e. that the Park must be de-proclaimed in order to give effect to an approval. This would be a major upheaval and quite similar to what the Tasman Government wanted to do in a Tasman National Park in the recent past; to be able to conduct logging operations inside the National Park and then to re-proclaim it as a National Park again, afterwards. In actual fact, there is another example where they did exactly that, in order to achieve their goals. The IUCN opposed their latest proposal and we have also approached the IUCN in respect of this application inside the AFNP, but are still waiting for a response. (2) (You must be aware that the Tasman Government, via their wholly owned HYDRO ELECTRIC CORPORATION (HEC), which trades under the names Hydro Tasmania (HT) and Entura are partners in this (and other) applications and that they would be benefiting heavily from these projects? This is probably the origin of the culture of Comments & Response Report Kobus & Hannecke van Coppenhagen, Augrabies, comment by email, 13 March 2015. Dear Mr. Kobus van Coppenhagen, Thank you for your e-mail. I hereby acknowledge receiving your correspondence and will clarify it with the environmental impact assessment practitioner and the developer and revert back to you as soon as possible. Sincerely, Shawn Johnston 1. Project title - We note your comemnts, and refer you to section 2.4 of the EIAR, which provides details on a legal review and matters pertaining to land ownership and the management thereof which has a bearing opn the project’s title. 2. Proponent - We are aware of the associate between HydroSa and HydroTasmania, and note your reservations. 3. Changes to the application and applicant – 4. Fatally flawed application – The Department of Energy (DOE) initially had a 10MW cap on small hydro projects in the REIPPPP. Hydro SA therefore submitted three Basic Assessment Applications for three separate 10MW projects. The DOE subsequently increased the cap to 40MW. This Page 14 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue intolerance by the applicant to any form of objection, if you have investigated their modus operandi?). Anyway, the DEA accepted our objections regarding the naming of the project and their suggestion is reflected in the letter below and we have also used it in the subject title above. We propose that you confirm that this is the correct name in order to be able to move forward from the title page! (3) Secondly, the letter (below) dated 18/6/2013 requests that the RVM 1 Hydro Electric Power (Pty) Ltd, application document must be revised to reflect the increased capacity applied for, which has to be done in order for the Department to confirm the ToR for the continuation of the application. (We have asked for copies of this revised document for the last 18 months, with no success). However, this letter from DEA is silent regarding the activities applied for by RVM 3 Hydro Electric Power (Pty) Ltd (weir and conveyance infrastructure) which the consultants are attempting to transfer to RVM 1Hydro Electric Power (Pty) Ltd (a separate SPE) as it would become apparent in a letter of 3 June 2013, to DEA. A meeting between the applicant and DEA was held on 7 May and followed up by a letter from AURECON, dated 3 June 2013, addressed to Mrs. Linda Poll-Jonker (DEA) where the EAP falsely states on page 2 "Withdrawal of two application forms: Initially RVM1 applied for 3 separate projects ......." Which is patently false, because the notice dated 21/12/2012 (and many other docs) states on page one: Raised by April 2015 Response from CES EIA team or Hydro SA prompted Hydro SA to have only one project which can generate 40MW instead of three smaller projects. It would also reduce the environmental footprint substantially. As a result two of the three Basic Assessment applications were withdrawn and the remaining application was upgraded to a full Environmental Impact Assessment. The correct procedures were followed with the Department of Environmntal Affairs to execute this. Copies of all application forms are attached as appendices to the DEIR 5. Water balance aspects – Information on flow duration and hydrology are presented in Section 3.3 of the EIAR and elsewhere. Please note however, that this is a run of river scheme and hence is non consumptive. Nevertheless, the project is based on an annual power generation capacity of 235 gigawatt-hours (GWh). There will be periods when no power can be generated, as run of river is below the threshold of 30 cumecs required for the falls, but the financial model considers this. A positive IRR and NPV will be generated. 6. Turbidity – The risks of increased turbidity have been assessed as low in the EIAR. 7. Height of the weir – The weir will not be higher than 5m – see Section 3.2.1 of the EIAR. "1) Introduction: RVM 1 Hydro Electric Power (Pty) Limited, RVM 2 Hydro Electric Power (Pty) Limited and RVM 3 Hydro Electric Power (Pty) Limited, (RVM 1, 2 and 3) wishes to construct..........." Thus 3 separate legal entities (Special Project Vehicles/Entities as Mr Theron referred to it in the first public meeting) !!!!!!!! (4) This clearly demonstrates that the EAP/applicant made a Comments & Response Report Page 15 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue false statement, but the contractual relationship between the three SEPARATE ENTITIES is clearly illustrated in a Powerpoint presentation document titled: RVM Hydro Electric Project, Overview 30 July 2012, Kimberley on page 15, section 8. This document can be forwarded if required. Thus, the closure of the application which provides for the water conveyance infrastructure activities and weir, cannot be "revived/inherited immediately" by another entity, according to the regulations. In a document to AURECON, titled Hydrology of the Orange river, we did allude to the fact that the old Bophutatswana Government built a coal fired power station somewhere in what is now Northwest Province, but did not make allowance for the water needed and thus the plant never started up. From a procedural/administrative point of view this is a fatal flaw and if approved the RVM 1 application will have to be reviewed on this ground alone, because it has NEVER applied for the water conveyance infrastructure related activities, which also affects other properties. Raised by April 2015 Response from CES EIA team or Hydro SA (5) Thirdly, if your specialist investigations does not include a full water balance investigation this application would be useless, because we have already shown (hydrology doc and others) that there would be a deficit of more than 660 million cumec per annum in the Lower Orange River Valley in the near future, just because of Lesotho Highlands Water Scheme Phase II, which would transfer an additional 21 cumec/second to the Vaal Catchment Area. There are other increases in consumption which we have also alluded to, which the EAP seemed to ignore, because the viability of the project and also the rationale for the doubling of the capacity of the plant would have no scientific/reasonable basis. This was clearly demonstrated in a letter dated 2 July 2014, to AURECON by Dr. Riaan Wolhuter, who is an electrical engineer! On the other hand, it is possible that the applicant is only interested in the construction phase profits and does not care if the investors and community are saddled with a non-profitable installation. Obviously, this would be valid Comments & Response Report Page 16 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue comments for the other planned installations too. (6) Not a word has been mentioned by the EAP/applicant about the turbidity of the water of the Orange River, which is the highest in Africa and 4th highest in the world, which would not be good news for a water driven turbine operator, especially for higher elevation run-of-river type systems. Raised by April 2015 Response from CES EIA team or Hydro SA (7) Fourthly, the height of the weir is now suddenly increased to 5 m again, according to the BID. Are you busy with a copy and paste exercise, because if you are not serious, you might eventually regret becoming involved in this application! For the moment this will suffice and we would expect a proper response to the above-mentioned issues, because skirting around the them will not make it disappear? <DEA let re Upgrade to EIA 190613.pdf> 20. Regards Kobus and van Coppenhagen 0836564498 Dr. Avis' e-mail regarding comments of IAP's refer; Please consult the correspondence below, to verify that our comments were not considered for the FSR, due to unavailability of the documents. Regards Kobus and Hannecke van Coppenhagen 0836564498 Begin forwarded message: Kobus van Coppenhagen, Augrabies, comment by email, 16 March 2015. Dear Mr Kobus van Coppenhagen, Thank you for informing our team that your comments submitted to Aurecon during the final scoping phase have not been incorporated. I will incorporate your comments into the draft environmental impact assessment phase. Mr. van Coppenhagen, can you please submit the mentioned comments directly to me. Sincerely, Shawn Johnston From: Louise Corbett <[email protected]> Date: 09 Oktober 2013 7:43:14 nm. SAST To: Nelis Bezuidenhout <[email protected]>, "Kobus van Comments & Response Report Page 17 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue Coppenhagen" <[email protected]> Cc: Simon Clark <[email protected]> Subject: RE: PROPOSED HYDROPOWER STATION ON THE FARM RIEMVASMAAK, AUGRABIES, NORTHERN CAPE - RVM 1: DEA Ref: 14/12/16/3/3/1/681; NEAS Ref: DEA/EIA/0001403/2012 - AVAILABILITY OF THE FINAL SCOPING REPORT FOR REVIEW Raised by April 2015 Response from CES EIA team or Hydro SA Dear Kobus As noted on site today there will still be further opportunities to comment on the EIA Process. However, should you still wish to comment on the FSR you are welcome to do so. We will then forward your comment to DEA for their information and we will include and respond to it in our next report (the Draft Environmental Impact Assessment Report, unless DEA require us to revise the FSR). Kind regards Louise Louise Corbett Associate I Environmental Services I Aurecon T +27 21 526 6027 I F +27 86 667 3532 I E [email protected] Aurecon Centre 1 Century City Drive, Waterford Precinct Century City I South Africa aurecongroup.com From: Nelis Bezuidenhout Sent: Wednesday, October 09, 2013 8:03 AM To: Kobus van Coppenhagen Cc: Simon Clark; Louise Corbett Subject: RE: PROPOSED HYDROPOWER STATION ON THE FARM RIEMVASMAAK, AUGRABIES, NORTHERN CAPE - RVM 1: DEA Ref: 14/12/16/3/3/1/681; NEAS Ref: DEA/EIA/0001403/2012 - AVAILABILITY OF THE FINAL SCOPING REPORT FOR REVIEW Comments & Response Report Page 18 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue Raised by April 2015 Response from CES EIA team or Hydro SA Dear Mr Van Coppenhagen Please find attached the email correspondence with regards to the matter in your email below. The first email was sent on 23 September 2013 (11h32) followed shortly by a follow-up email (15h23). Kind Regards Nelis Nelis Bezuidenhout I MPhil Cum Laude, BA Development & Environment From: Kobus van Coppenhagen [mailto:[email protected]] Sent: Tuesday, October 08, 2013 7:21 PM To: Nelis Bezuidenhout; Simon Clark Subject: Fwd: PROPOSED HYDROPOWER STATION ON THE FARM RIEMVASMAAK, AUGRABIES, NORTHERN CAPE - RVM 1: DEA Ref: 14/12/16/3/3/1/681; NEAS Ref: DEA/EIA/0001403/2012 - AVAILABILITY OF THE FINAL SCOPING REPORT FOR REVIEW Good day Nelis & Simon We have still not received the courtesy of a reply to the matter below, would you be so kind to respond. Regards Kobus van Coppenhagen 0836564498 From: Kobus van Coppenhagen <[email protected]> Date: 23 September 2013 10:51:04 MGT+02:00 To: Simon Clark <[email protected]> Cc: Nelis Bezuidenhout <[email protected]> Comments & Response Report Page 19 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue Subject: Re: PROPOSED HYDROPOWER STATION ON THE FARM RIEMVASMAAK, AUGRABIES, NORTHERN CAPE - RVM 1: DEA Ref: 14/12/16/3/3/1/681; NEAS Ref: DEA/EIA/0001403/2012 - AVAILABILITY OF THE FINAL SCOPING REPORT FOR REVIEW Raised by April 2015 Response from CES EIA team or Hydro SA Good day Simon We are still not able to access the FSR for the abovementioned project on your website and request if you would extend the review period accordingly. Regards Kobus van Coppenhagen 0836564498 On 18 Sep 2013, at 14:58, <[email protected]> wrote: Simon Clark Dear Mr van Coppenhagen We apologise for the inconvenience, the entire site is currently down, we have technicians currently working on rectifying the access issues to the documentation. We will notify as soon as the website becomes available. Kind regards Simon Clark ,Aurecon From: Kobus van Coppenhagen [mailto:[email protected]] Sent: Wednesday, September 18, 2013 12:23 PM To: Simon Clark Subject: Re: PROPOSED HYDROPOWER STATION ON THE FARM RIEMVASMAAK, AUGRABIES, NORTHERN CAPE - RVM 1: DEA Ref: 14/12/16/3/3/1/681; NEAS Ref: DEA/EIA/0001403/2012 - AVAILABILITY OF THE FINAL SCOPING REPORT FOR REVIEW Comments & Response Report Page 20 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue Raised by April 2015 Response from CES EIA team or Hydro SA Good day Simon Thank you for the e-mail, but the FSR & several other documents are not yet posted to the website. Would you be so kind to inform us when this has been posted? Regards Kobus van Coppenhagen 0836564498 On 17 Sep 2013, at 16:44, <[email protected]> wrote: Simon Clark Dear Sir/ Madam PROPOSED HYDROPOWER STATION ON THE FARM RIEMVASMAAK (REMAINDER OF FARM NO. 497 AND PORTION OF FARM NO. 498), ON THE ORANGE RIVER IN THE VICINITY OF AUGRABIES FALLS NATIONAL PARK, NORTHERN CAPE RVM 1: DEA Ref: 14/12/16/3/3/1/681; NEAS Ref: DEA/EIA/0001403/2012; AVAILABILITY OF THE FINAL SCOPING REPORT FOR REVIEW The abovementioned project refers. This email serves to notify I&APs of the availability of the Final Scoping Report (FSR) for the above mentioned project for comment. 1. Introduction Following the comment period on the DSR, the Final Scoping Report (FSR) was compiled. The FSR includes comments and concerns that were raised by Interested and Affected Parties (I&APs) during the comment period of 40 days which Comments & Response Report Page 21 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue stretched from 19 July 2013 until 28 August 2013. 2. Raised by April 2015 Response from CES EIA team or Hydro SA Changes made to FSR This FSR is an update of the DSR, including additional information on the current status of the public participation process and amendments made in light of some of the comments made. Substantive changes to the Draft Scoping Report are reflected as underlined text, while deletions are reflected with strikethrough text. For your convenience we have attached the non-technical summaries (English & Afrikaans) to this email. The following annexures have been updated: Annexure B (includes updated database and proof of I&AP correspondence); and Annexure C (includes Comments and Response Report 2 and comments received). 3. Way forward The FSR will be available from 16 September 2013 until 7 October 2013 for a 21-day review and comment period at the Kakamas Public Library, at Reception at Augrabies Falls National Park and on Aurecon’s website (www.aurecongroup.com please change the current location to “South Africa” and follow the “public participation”- link). The FSR is also available at each of the three Riemvasmaak Community Trust offices or alternatively contact Mr Bennie Kordom on 071 443 9277. If the proposed project crosses your land and you are the landowner, but not the occupier of the property, please inform the occupier of the land on which the proposed project is located or advise us of their contact details so that we may do so. To ensure that all Interested and or Affected Parties (I&APs) are informed of the proposed project we kindly request that, should you know of someone that would be interested in or affected by the proposed project, you ask Comments & Response Report Page 22 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue them to contact us. Alternatively please inform us and we will contact them directly. Raised by April 2015 Response from CES EIA team or Hydro SA If you would like to obtain more information, submit any comments or register as an I&AP, please contact Nelis Bezuidenhout at Aurecon: Tel: 021 526 6031, Fax: 021 526 9500, E-mail: [email protected] or P.O. Box 494, Cape Town, 8000 on or before 7 October 2012. Any comments received on the FSR will not be captured in a Comments and Response Report, but will be forwarded directly to the Department of Environmental Affairs for their consideration and responded to in the EIA Phase only. Should you have any further queries, please contact the undersigned. Yours sincerely, AURECON 21. Simon Clark on behalf of Nelis Bezuidenhout Dr Avis Subject: Proposed Augrabies Hydro Power Plant, Northern Cape.(2) We believe that you need to be informed that we are not against any type of renewable energy project, as a matter of principle, but rather that applications should only be launched in appropriate areas, which would exclude National Parks from the outset. We have been living in challenging conditions, with no services (off-grid and brackish drinking water), for the last 7 years, with only our own resources to rely on. Thus, the need for the generation of renewable energy from sustainable sources, weigh heavily on our minds. In that regard, the record will show that we have suggested to the DEA and the applicant that the site alternatives to the Augrabies Falls National Park, being Neusberg and Boegoeberg, should be considered for approval, since they are brownfield sites. It is also quite clear Comments & Response Report Kobus & Hannecke van Coppenhagen, Augrabies, comment by email, 17 March 2015. Dear Mr. Kobus van Coppenhagen, I hereby acknowledge receiving your correspondence date 17 March 2015, at 11:09:36 SAST. I will process these comments into the draft environmental impact assessment report's comments and response report. Thank you for placing these comments on record for the EIA phase. Sincerely, Shawn Johnston Dear Mr. Kobus van Coppenhagen, Find attached the response I have received from HydroSA relating to your request for information on the WULA Application. Page 23 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue from authoritative documents that the development of conservation areas for non-aligned activities, in biodiversity priority areas are unacceptable e.g. 1) Study Name: Orange River Integrated Water Resources Management Plan Raised by April 2015 Response from CES EIA team or Hydro SA Sincerely, Shawn Johnston Dear Shawn, Report Title: Environmental Considerations Pertaining to the Orange River (p61) Authors: R Heath, C Brown Date of issue: August 2007 "Due to electric power generation (that is between Gariep and Vanderkloof Dams and below Vanderkloof Dam for some 200 km) loss of species diversity is severe. The river immediately below Vanderkloof has been described above as an ecological desert. The creation of further "ecological deserts" would not be desirable. They would be unacceptable in parts of the river of particular conservation importance." In response to Mr Van Copenhagen’s request for a copy of the WULA for RVM. We are quite happy to oblige once the application is complete. 2) Siyanda Environmental Management Framework Report 2008 (p76) Kind regards Mercia Grimbeek Project Manager In the instance of the Lower Gariep Alluvial Vegetation, conservation is the only acceptable use of the area because it represents: that can already not be attained anymore due to the extent of transformation that has already occurred; and The developers met with the Department of Water Affairs on 10 February 2015 to discuss the draft application. This application is now being finalised for submission and once submitted we will supply a copy for Mr Van Copenhagen’s perusal. (1 & 2) Ww note with thanks the references provided relating to the conservation importance of the Orange River and related habitats. Imopacts associated with weir construction and the off-channel imtake are discussed and assessed in the EIAR. dynamic and subject to natural physical change over time due to the interaction between the alluvial nature of the area and flood events. 3) We would also appreciate your comment on the legitimacy of this application against the background of the Park Management Plan and exactly how the NEM: PAA and its regulations must be waived to allow for this installation, Comments & Response Report (3) The role and function of SANParks and the Augrabies falls Management Plan are discussed, inter alia, in the Page 24 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue which would initiate the dismantling of our protected areas system, if approved. The notion that the lease of a protected area can be negotiated for non-aligned activities (for up to 100 years, according to Mr Theron in press), is fraught with unimaginable complications. Soon, applications for wind farms on Table Mountain National Park and Solar installations in other National Parks would follow JUST BECAUSE THE POTENTIAL EXIST and a precedent would have been set for its approval. Raised by April 2015 Response from CES EIA team or Hydro SA Fauna Specialist Report and the EIAR. As far as we are concerned one of the most important aspects of this project is the diversion of water away from the currently active river channel and waterfall (over a distance of 9km) together with the impact of that proposal on the environment, which is a protected area. A water license have not been applied for, according to your submission. Whenever this happens we would also want to register as an IAP for that process. We do also continue to insist on receiving a copy of the "upgraded" application from the EAP/applicant (as provided for in the application form, note 8 on page 1) You must please also check on the "RVM1" application document page 8, where it states: Please note that any authorisation that may result from this application will only cover activities applied for We have carefully perused the regulations and listed activities, and are confident all possible listed activities are included in the application and the EIAR. For your convenience we are recording the details of what is being applied for (page 8 of application form), etc. Please make your own conclusions, considering the above statement. (Is it possible to entrust someone with the care of our National Heritage if they cannot grasp this most basic information, even after 18 months of requests?) 3.0 OTHER AUTHORIZATIONS REQUIRED, 3.1 Do you need any authorizations in terms of any of the Comments & Response Report Page 25 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue Raised by April 2015 Response from CES EIA team or Hydro SA following laws? 3.1.1 National Environmental Management : Waste Act ....................applicant stated: No??? 3.1.2 National Environmental Management : Air Quality Act .............applicant stated: No 3.1.3 National Environmental Management : Protected Areas Act ....applicant stated: No??? 3.1.4 National Environmental Management : Biodiversity Act ...........applicant stated: No??? 3.1.5 ........ 3.1.6 National Water Act ......................................................................ap plicant stated: Yes 3.1.7 National Heritage Resources Act ............................................... applicant stated: Yes 3.1.8 ... 3.2 Have such applications been launched already?...........................applicant stated: N/A??? Notwithstanding note 5 on page one, which specifically warns against the use of N/A, because the application can be rejected if it relates to material information, the applicant used the term N/A. We hope that the deficiencies in this "RVM 1"application are now apparent to you as the new EAP and that our contentions in the next paragraph starts to make sense to you. It is clear that the applicant also wants to collect a water license without specifically applying for it and following the licensing procedure. We have requested that an IWULA (integrated water use license application) procedure must be conducted because of the impact on the Augrabies Falls National Park. This would require a full verification process by Department of Water Affairs, to determine whether the quantity of water could be allocated. Thus, a (future) water balance determination is crucial, because of the quantity of water applied for and the Comments & Response Report Page 26 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue statement of the EAP (AURECON), that all future water allocations upstream, would have to consider the requirements (power factor) of the proposed installation, which is a misconception and shows a lack of knowledge of the NWA and its regulations. This highlights the general lack of a professional approach to this very controversial proposal in an area of the highest protected status in South Africa. Another matter of concern is that investors might be led to believe that the schemes are viable because for example in the case of Neusberg, ENTURA (a beneficiary) has been appointed to evaluate the feasibility of the proposed project. (CDM Validation Report, p18). IS THE EAP AWARE OF THIS PRACTICE OF THE APPLICANT, APPOINTING ITS PARTNERS FOR VERIFICATION PURPOSES? The applicant has admitted in a meeting that they have only considered historical records for the determination of the "dispatchability/power factor" of the proposed Hydro power installation, which is a grave error in the case of the Lower Orange River, due to planned changes in the water balance upstream. As far as our correspondence is concerned we need to inform you that AURECON published the FSR too late for all the comments to be submitted timeously and was thus not incorporated into the FSR. (We have forwarded correspondence to that effect). It would be essential to receive a list of all our correspondence (in your possession) in date order to determine whether you have all the documents. We are however convinced of the fact that the "application" has lapsed or is invalid, at least due to the inadequate documentation, lack of ToR from DEA and that the starting point, for the Scoping Report, should have been timeous rectification of this document. We are very concerned about DEA's tolerance/indulgence of the "tardiness" of the applicant to revise and submit the application in due time, because the application lapses if an instruction is not complied within 6 months (21 months have elapsed in the meantime). We are committed to the Comments & Response Report Raised by April 2015 Response from CES EIA team or Hydro SA The banks (lenders) accepted the verification provided by Entura – Neusberg was successfully constructed within time and within budget The applicant was granted an extension to 30 April 2015. Page 27 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue administrative process but then it MUST be fair and transparent. In the meantime we have approached the office of the DG of DEA for action in this regard. Failing a proper response we would be forced to approach the office of the Minister of Environmental Affairs in due course. Raised by April 2015 Response from CES EIA team or Hydro SA If the applicant was the owner of the land and it was situated outside of the protected area and its buffer zones, the scenario would be different (as far as location is concerned) and we expect that the EAP must always keep this in mind. Regards 22. Kobus & Hannecke van Coppenhagen 0836564498 From: Kobus van Coppenhagen [mailto:[email protected]] Sent: 15 April 2015 12:44 PM To: Ted Avis Cc: M Gordon; Danie Smit; A B Abrahams; Howard Hendricks; Lucius Moolman; Frans Van Rooyen; Mike Knight; Gene Visser; Gerhard Smit; Andrew Hockley; Angus Tanner Subject: Re: Hydro-electric power station in the Augrabies Falls NationalPark Dr Avis We have requested more than 4 weeks ago, that you should furnish us with the copy of the valid application form date stamped by the DEA and according to which the ToR for your EIA has been determined. You have failed to provide us with this document, without which the application is invalid and the procedurally flawed. Do you refuse to provide this document? Your response is urgently required. Regards Kobus van Coppenhagen 0836564498 Comments & Response Report Kobus & Hannecke van Coppenhagen, Augrabies, comment by email, 15 April 2015. Dear Mr van Coppenhagen Thanks you for your email. My apologise for the late response, but we are in the final stages of completing all documents for the HydroSA project and somewhat busy. Our engagement process, and indeed that of the EIA process, is to gather all correspondence from IAPs and integrate this into a comments and response trail, in preference to individual and piece-meal responses. The latter is an inefficient and somewhat exclusive way of engaging, whereas including concerns and responses in the comments trail of the EIAR is a more transparent and inclusive manner of engaging with IAPs. This way everyone is privy to the debate, rather than a select few. With regard to the application form, it will be included in the Draft EIAR as an appendix for all to see. Regards Ted Avis Page 28 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. 23. Issue From: Gerhard Smit [mailto:[email protected]] Sent: 09 March 2015 12:20 PM To: Dr T Avis Subject: Augrabies hydro-electric power station. Raised by Gerhard Smit, comment by email, 09 March 2015 Good afternoon, I watched the TV News last night and noticed that the Planned Hydro-electric power station in the Orange River is still on-going. I would herewith request to be registered as an I&AP for this project. Please confirm to this email address receipt of this message and also that I have been registered as requested. Please also advise me at what stage the process is and also please forward all relevant documentation to me. Your kind co-operation in this matter is appreciated. Kind regards Gerhard Smit 0164283497 24. Hi Shawn, Dankie Gerhard Please register me as an interested and affected party for this unsolicited proposal of a Hydro Electric Scheme in the primitive and remote areas of the Augrabies Falls National Park and the Riemvasmaak Community Conservancy. April 2015 Response from CES EIA team or Hydro SA Dear Mr. Gerhard Smit, Thank you for your e-mail dated 09 March 2015. I hereby confirm that you are registered as a interested and affected party for the proposed Riemvasmaak Hydro Project EIA. The project is now in the environmental impact assessment phase. EOH Coastal & Environmental Services are the new environmental impact assessment practitioners on the project. Their team are lead by Dr. Ted Avis and Dr. Bill Rolston. EOH Coastal & Environmental Services are currently drafting the draft environmental impact assessment report for release towards the end of April 2015. A copy of this document will be sent to you as soon as it becomes available. Andrew Hockly, comment by email, 11 March 2015 Sincerely, Shawn Johnston Dear Mr. Andrew Hockly, In order for a realistic assesmanty of the proposal I hereby request the documents from which this new set of consultants will be referring to in making this assessment. In particular: Thank you for your e-mail. I hereby acknowledge receiving your request to register as an interested and affected party and confirm that you have been registered on the stakeholder database. I will be forwarding you a copy of the draft environmental impact assessment report when it becomes available. The environmental impact assessment practitioner (EAP) is currently draft the report. I'm passing your request for information onto EOH Coastal & Environmental Services. Any document calculating the amount of water which could be available. Preferably from DWAF. I look forward to engaging with you during the EIA phase of the proposed project assessment. Any Geological data, in particular the Earthquake Risk assessment. Sincerely, Shawn Johnston Comments & Response Report Page 29 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue A fine scale contour map of the proposed Diversion Weir and Outtake structures, covering the full island, the island and in particular the potential for the erosion of the entire island. Raised by April 2015 Response from CES EIA team or Hydro SA The EIAR report needs to be circulated, and the validity of the report assessed by IAPs. It is not a requirement to send IAPs the reports and data which the EIAR draws from, if this is indeed the nature of this (unclear) request. A n assessment of the noise pollution inevitability during construction covering all weather variations and wind directions. Particularly important is the winter cold periods when any sound stays low and carries. An assessment of the water quality as returned to the river just above the man made lake from Vredesvallei. Adding dead water to dead water appears unadvisable. Any research on the Cape Clawless Otter. Thanks and regards Andrew Hockly P.O.Box 20 Augrabies 8874 079 888 9502 Job Creation 25. Will there be enough job opportunities for the Riemvasmaak Community? What are the timeframe for developing and building the project? What about job creation amngst the youth? What about developing ourselves and having sustainable livelihoods? Most of us are unemployed and in need of skills. 26. Our biggest concern is unemployment and job creation. We need clarity on what the job opportunities for the Riemvasmaak community will be. Please clarify this issue for us. Comments & Response Report The power plant will create jobs during construction and operations. During the construction phase approximately 150 -200 jobs will be available for the local community. This includes the Riemvasmaak community. Patrick Regent, Nolukholo Nkuphu, Nomthandazo Masheqa, Thandiswa Macando, Welma Kariato, Wendall Jors, Gcobani Mapikana and John Cloete, The power plant will create jobs during construction and operations. During the construction phase approximately 150 -200 jobs will be available for the local community. This includes the Riemvasmaak community. Page 30 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue Project Support 27. Renewable energy decision. The community agreed that the bid of Hydro SA must be supported and added that a renewable energy mobilising committee be established which will ensure that Riemvasmaak has developers submitting compatible bids for solar power and hydro-electricity. The Development Committee must engage the Augrabies Falls, SANParks and all other stakeholders. 28. The Riemvasmaak community support the development of the proposed hydro energy facility and the community provided the various Riemvasmaak committees to persue and investigate renewable energy opportunities further. 29. In our area there is a shortage of power. It would be a good idea to have a power station here. We will have less power cuts in the area. Our community support the project. 30. We support the Riemvasmaak hydro project. Comments & Response Report April 2015 Raised by comment by reply form, 19 March 2015. Response from CES EIA team or Hydro SA Riemvasmaak Committee Meeting decision, held at Sending Hall, 27 November 2014 The communities project support are noted as an affected party input. Ben Vass at information session with Riemvasmaak Development Committee, Governance Committee, Repatritation Committee, Planning Committee, 10 February 2015 Antonia Vass & Zolike Hoorn, comment by reply form, 20 March 2015 Theresia Hampira, Ketelien Kotze, Nomule Mafikata, Mzingisi Nkupu, Eunice, Niklaas Tieties, Dennis Vass, Christopher Kotze, Dawid van Comment noted. Comment noted. Comment noted. Page 31 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. 31. 32. 33. 34. Issue I like the idea that you would want to assist the community of Riemvasmaak with te project. It would assist us when we have a major power cut. I hope the work can start so that the Riemvasmaak community can benefit from it. I’m quite excited about te project. Ihave visited the Neusberg project and have seen what have been achieved there. I hope they can do the same on our property at Riemvasmaak. It will assist us greatly in dealing with unemployment and job creation for our families and children. We do not have any concerns about the animal life as it will adapt to the noise and the people will make a plan with the plants. This will be a very good job creation opportunity for the community of Riemvasmaak. We need the power station here. There is enough space to locate the project on the site. I do not have a problem with the project. My wish is that our community benefit from the project during construction to create jobs. Comments & Response Report Raised by Wyk, Loot Kariato, Yekani Mate, Norman Rhyn, Masixole Booi, Leonard Roman, Christina Hendricks, Ethel Vass, Silvester Frans, Sinethemba Mathe, Isak Green, Magdalene Bostander, comment by reply form, 20 March 2015 Leon Kopers, comment by reply form, 20 March 2015 Gloria Adams, comment by reply form, 20 March 2015 LJ Mblankomo,Noms a Vass, Frans Blaauw, Nwabisa Damane & Desmond Blaauw, comment by reply form, 19 March 2015 Regina Jaar, comment by reply form, 19 March 2015 April 2015 Response from CES EIA team or Hydro SA Comment noted. Comment noted. Comment noted. Comment noted. Page 32 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. 35. Issue I support the idea of the project as it holds numerous benefits for the community of Riemvasmaak, such as job creation and to reduce power cuts. Please conduct a information session in Vredes Valley as soon as possible. I hope we can cooperate in the future. Lets proceed with the project. 36. We are extremely positive about the development. I hope the project contribute to more stable and sustainable energy needs of Blouputs and Augrabies. Melkbosrant Community Concerns 37. My problem is that the original Melkbosrant community was not involved in this project. What happenes to the graves and nature on Melkbosrant? The Melkbosrant Committee representing the Melkbosrant Community need to be engaged. Conduct a workshop with the Marchand community. It is a large project and it can destroy the forna and flora. 38. My concerns is the community conflict that might delay the development of the project. Comments & Response Report April 2015 Raised by Isak Vass, Demetheo Beukes, daniel van Weyers, Norbert Coetzee, Petronella Basson, Ricardo Malgas, Claudia Lukas, Andreas Adams, Henry Augus, Jan Frans, Benjamin Vass, Dirk van Wyk, Jacobus Basson, comment by reply form, 20 March 2015 Alwyn Dippenaar and Namein Gagiano, Blouputs Framers Association, comment by reply form, 10 March 2015 Response from CES EIA team or Hydro SA Comment noted. Bernard Bezuidenhout & Markus Basson, Melkbosrant Community, comment by reply form, 19 March 2015 Feitjie Basson, comment by reply form, 20 March 2015 Meetings will take place during the review period of the EIAR, during which these issues can be discussed. Comment noted. The PPP will deal with this process related issue. Page 33 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. 39. Issue My concern is the long lead time to develop the project and the relationship and agreement between the park and the community. 40. The process must be completed as soon as possibe ad the community need to be provided with all of the project information. Road Network 41. Good morning Shawn, Thank you for your email. Thank you for the google map. Will it be possible to forward me a map indicating the national road and properties involved. Kind regards, Rene, April 2015 Raised by Michael Basson, comment by reply form, 20 March 2015 Charlotte Dawids, Governance Committee Riemvasmaak, comment by reply form, 20 March 2015. Response from CES EIA team or Hydro SA Noted. Unfortunately large complex projects take a long time to develop. Rene de Kock, South African National Roads Agency (SANRAL), comment by email, 31 March 2015 Dear Rene, Comment noted. Thank you for your e-mail. This project is about 60km away from the N14 and not near the National Road. It is off the road to Riemvasmaak. Do you deal with the district roads in this area? Sincerely, Shawn Johnston Thank you Shawn, Please take note that SANRAL must be consulted before the transport of abnormal loads on national roads. Please forward Transport Plan to Garth Julius from this office at [email protected] if SANRAL is affected. Kind regards Rene SANParks Submission (Frans van Rooyen) 42. 1, The destruction of the habitat in which at least one endemic species (Augrabies Flat lizard) occurs. This lizard does not occur anywhere else in the world, only in a small radius around the waterfall. Comments & Response Report Frans van Rooyen, Park Manager: Augrabies Falls The re submission of this four page document by Frans van Rooyen, Park Manager: Augrabies Falls National Park is hereby acknowledge. Page 34 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue 2. The destruction of the geology and possible weakening of the wall of the canyon on the northern side in the construction. Especially when considering that this area is already prone to earth tremours and that the river is situated on a fault line. 3. Flow of the waterfall – This waterfall is a MAJOR attraction not only in the Northern Cape but also in South Africa. During the 2010/11 floods, people travelled from all over SA to come and see the falls. Once the project is completed then there will be no control over how much water is diverted, the cost of the project and the need to supply electricity will be more important. 4. Destruction and disturbance to ecology and biodiversity during construction. This is a sensitive arid environment where rehabilitation will be very difficult if not almost impossible. 5. The ethics of the Park will be compromised. 6. SA does not have many waterfalls therefore they should be protected in their pristine state. Surely, at dams (where destruction has already taken place) hydo projects can be put in place. 7. The noise and disturbance during the long construction period will chase tourists away and they will probably not return as they will conjure up their own ideas/pictures of what the falls and park will look like afterwards. 8. For the small amount of electricity to be produced the total destruction is not worth it. It should not even be considered within a National park 9. The different Cormorants that nest and breed close to the area were the proposed weir is planned is a big concern, Comments & Response Report Raised by National Park, comment by email, 16 March 2015 April 2015 Response from CES EIA team or Hydro SA 1. The faunal specialist report investigated this and Impact 4 of section 7.3.4 of the EIAR discusses this. 2. A specialist study to investigate seismic risks was undertaken. Section 6.5 of the EIAR presents a summary of the findings, and Sections 7.2.9; 7.3.9. and 7.4.9 of the EIAR respectively assess design, construction and operatyional phase impacts. 3. The weir is designed with a broad crested profile at level 616.0m, and a 7.5m-wide low-flow slot left of the channel centreline, which will allow the agreed environmental flow of 30m3/sec to pass through the weir structure unimpeded to ensure that to ensure that at least 30m³/s flows through the low-flow slot before water is diverted into the HPP headrace. See Figure 3.7 and Section 3.3 of the EIAR for further details. 4. This issue is addressed in both the Faunal and Botanical specialist studies, and impacts are discussed in Chapter 7 of the EIAR. 5. Deproclamation would not be required. However, the project will occur in areas classified by the SANParks Management Plan as remote. 6. Most of the suitable sites for HEP generation in South Africa have already been developed. Chapter 13 of the EIAR provides further details. 7. A specialist study on noise impacts was undertaken, and the impacts are discussed in Chapter 7 of the EIAR. The outcome of increased noise stated here is conjecture. There are no indications that this will or will not be an outcome, although it is highly unlikely given the low impacts associated with noise. 8. The justification for the project is discussd in Chapter 4 of the EIAR. 9. This issue is dicussed in the Faunal specialist Page 35 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue they will be disturb. 10. The forebay will be above ground level, how will they camouflaged it to prevent visibility once people visit the lookout points? 11. The place where they planned to put the water back in a dry stream is also a concern because there is currently no water the plants and trees will die if you put water all of a sudden there the plants are well adapted to the dryness of the stream. Dear Nelis Bezuidenhout and Louise Corbett South African National Parks (SANParks) acknowledge the opportunity to comment on the Draft Scoping Report for the Proposed Hydropower Station on the farm Riemvasmaak (Remainder of Farm no.497 and Portion of Farm no. 498) on the Orange River, in the vicinity of Augrabies, Northern Cape Province. SANParks submits that South Africa’s economy is energy intensive, mainly from mining, pulp and paper, and smelting. To date, almost 90% of South Africa’s current Electricity Generation Capacity is provided by coal. There is almost no renewable energy generation. It is for this reason that South Africa explores and invest in generating alternative electricity from renewable resources. SANParks therefore supports renewable energy generation traditionally provided by technologies such as hydro, wind, solar and biogas. To this effect, SANParks seeks an alignment between the proposed hydropower station development and the National Environmental Management: Protected Areas Act, 2003 (Act No. 57 of 2003), (NEM:PAA) being the primary Act for managing protected areas in the country for the following reasons; Comments & Response Report Raised by April 2015 Response from CES EIA team or Hydro SA study, and impacts of the weir are discussed in sections 7.2.4.and 7.3.of the EIAR. See for example impact 3 in section 7.3.4. 10. The headpond and forebay – the intake to the penstocks – is located at the downstream end of the headrace, immediately upstream of and adjacent to the site of the power chamber. There is no need to camouflage it as it is a small structure and will only be visible when one is close to it. 11. This has been assessed in the Aquatic specialist study, and in Section 7.4.2 of the EIAR as an impact of low significance. The following responses the numbered comments to the left: 1. Legislative issues are discussed in the EMPr. 2. The Department of Energy (DOE) initially had a 10MW cap on small hydro projects in the REIPPPP. Hydro SA therefore submitted three Basic Assessment Applications for three separate 10MW projects. The DOE subsequently increased the cap to 40MW. This prompted Hydro SA to have only one project which can generate 40MW instead of three smaller projects. It would also reduce the environmental footprint substantially. As a result two of the three Basic Assessment applications were withdrawn and the remaining application was upgraded to a full Environmental Impact Assessment. The correct procedures were followed with the Department of Environmntal Affairs to execute this. Copies of all application forms are attached as appendices to the DEIR 3. Section 2.6 of the EIAR, based on a legal opinion, explains the issue of land ownership and land management. Page 36 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue 1. Discrepancies between the proposed development and SANParks mandate must be regarded within all the applicable environmental legislation both nationally and internationally, not just NEM:BA as the draft scoping report alludes; 2. The draft scoping report provides no procedural explanation for the valid application upgrade from approximately two 10 x 10 MW substations to one 40 MW substation, including the regulatory framework that provided for three applications which were lodged by RVM1Hydro Electric (Pty) Ltd, RVM 2 Hydro Electric (Pty) Ltd and RVM 3 Hydro Electric (Pty) Ltd, respectively in comparision with Department of Energy lifting the cap of ≤10 MW; 3. Whilst the draft scoping report provides the fundamental arguments for “Riemvasmaak land, owned by the Riemvasmaak Community Trust, located within the borders of the Augrabies Falls National Park” followed their forced removal in 1973/1974 during Apartheid, the report uses such notion of land ownership interchangeable to avoid referencing the cabinet decision of parliament that such land must be used for the purpose of conservation, hence the current contractual agreement between SANParks and the Riemvasmaak Trust including the acceptance of an annual ex gratia payment – this highlights the need for clarity on land ownership and the appropriate landuse thereof; 4. While not explicitly forbidden in the NEM:PAA, the provision of land for infrastructure linked to the commercial generation of power is not listed as one of the functions of SANParks and it is therefore questioned if SANParks is in a position to lease or otherwise provide rights for power generation infrastructure such as those contained in the proposed development; Comments & Response Report Raised by April 2015 Response from CES EIA team or Hydro SA 4. Construction of the project-related infrastructure across Remainder of farm Waterval No 497 will require the establishment of a servitude or servitudes, for which application must be made to the Department of Public Works. Construction of the project-related infrastructure on Portion 1 of Farm Riemvasmaak 498 will require the Applicant and the Trust to enter into a long term Lease Agreement. Such an arrangement has been drafted and currently is being reviewed prior to approval via a special general meeting of the Trustees and beneficiaries of the Trust. See section 2.6 of the EIAR. 5. This issue has been resolved, and has no significant bearing on the EIA, since a full Scoping and EIA study is, in any avent, required. 6. SANParks concern about diverting a sizable portion of the river’s flow from the falls that would have a negative impact on the visitor experience to the falls has been assessed. See especially section 7.3.2, 7.3.7 and 7.4.7. These impacts are low as a minimum flow regime will be guaranteed. 7. Please refer to Section 3.2 for details on this. The maximum rate of diversion from the river to the hydropower station will be 38m3/s. A 7.5m-wide low-flow slot left of the channel centreline, with a broad crested profile at level 616.0m, will allow the agreed environmental flow of 30m3/sec to pass through the weir structure unimpeded 8. The AFNP Management Plan has been carefully considered in the EIA process. As explained in section 2.6 there is no need to change the current environmental zoning of primitive and remote, and this is not recommended. 9. This has been noted. 10. Please refer to Chapter 5 of the EIAR for a discussion on alternatives. 11. The land ownership issues are discussed in Page 37 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue 5. The difference of opinion between DEA and the Aurecon regarding Listing Notice 2 (GN No. R545) of the NEMA EIA Regulations must be resolved with immediate effect, rather than just prior to the submission of the final EIA Report for decision-making; 6. The draft scoping report ignored SANParks concern about diverting a sizable portion of the river’s flow from the falls that would have a negative impact on the visitor experience to the falls – instead, the report confuses this concern with the visual impact group rather than a tourism experience which highlight the shortcoming of the draft scoping report in defining a tourism experience as merely a visual impact; Raised by April 2015 Response from CES EIA team or Hydro SA Section 2.6. Chapter 4 discusses the need and desirability of the project, in accordance with the EIA regulations. 12. The issues raised here are all comprehensively discussed in the Faunal specialist study. 13. A Socio-economic and tourism specialist study has been prepared to deal with this issue. 7. The draft scoping report is silent on the planned volume of water to be diverted during the low flow period; the minimum reserve flow is required to maintain ecosystem integrity whilst an additional amount of volume of water will be required to provide a heightened tourism experience at the falls; 8. The revision of an approved Park Management Plan is the prerogative of the Minister in accordance to NEM:PAA Section 40 (2), whereas the change of a particular zone within a National Park is subject to Section 41 (g) of the same Act compelling SANParks to change such zones with predetermined conservation objectives and activities for all the national parks in the country to allow for the proposed project – the conservation objective is to maintain remote and primitive zones in as near to a natural state as possible with no impact on biodiversity pattern or processes, essentially these areas retaining an intrinsically wild appearance and character, or capable of being restored to such and which is undeveloped, there are no permanent improvements or any form of human habitation, and provides outstanding opportunities for solitude with awe inspiring natural characteristics; Comments & Response Report Page 38 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue Raised by April 2015 Response from CES EIA team or Hydro SA 9. SANParks notes that the proposed development is not in accordance with the spirit of the National Strategy on Buffer Zones around National Parks; 10. The draft scoping report uses location alternatives interchangeable between alternatives sites along the Orange River versus alternative sites in the country which limits a proper understanding of what feasibility studies were done towards alternatives sites for the waterfall, no indication is given as to where the 12 sites along the Orange River were located (Ps. both Neusberg and Boegoeberg are ideal alternative sites to the Augrabies Falls National Park site which together is likely to deliver at least 30% of the 75MW allocation for small hydro stations); 11. It is a grave concern that the draft scoping report down plays the status of a National Park with the high positive social impact that the project will have (especially for the landowners, i.e. Riemvasmaak Community), as well as the contribution it will make to the energy grid in South Africa as the best practicable environmental option for the proposed site of development thereby disregarding regrettably the importance of a National Park and the legal status thereof; 12. From a species management point of view, the scoping report falls short on the importance the park provides towards the conservation of many species to this environment, including large breeding colony of birds nesting in trees along the river and on a small islands whilst the disturbance of normal riverine habitat and the interference with the flow and stratum of the river bed and bank are likely to permanently flood many large rocks in the vicinity of the weir thereby disturbing a watercourse that would otherwise have been used as Comments & Response Report Page 39 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue perching sites for birds such as cormorants which constitutes a prohibition in NEM:PAA Regulations; Raised by April 2015 Response from CES EIA team or Hydro SA 13. SANParks submits grave concern about the fact that the draft scoping report incorporates the impact on tourism synonymous with the visual impact of the proposed development and loosely as part of the impact on the socio-economic environment – the impact on tourism has merit to be investigated on its own, hence a separate and additional specialist study will be required. In anticipation that these comments receive your consideration it will allow SANParks to optimally manage Augrabies Falls National Park within the confines of the regulatory framework for protected areas in the country as well as international obligations. 43. Telkom 44. Good Day Shawn We acknowledge receipt of your application. Our reference is CAHS0170-15 for further enquiries in this regard. Regards, Aletta Gabaitumele, NIP: Wayleave Management 45. Good Day Shawn, Attached find our cover letter for your application. Although we are not affected, Mr. Vivian Groenewald must be contacted at 054-338 6501 / 081 362 6738 before any commencement of work Mantwa Gabaitumele, Telkom Wayleave Management, comment by email, 19 March 2015 Mantwa Gabaitumele, Telkom Wayleave Management, comment by email, 26 March 2015 Dear Mantwa, Thank you for your e-mail, your commnent are noted. Sincerely, Shawn Johnston Dear Mantwa, Thank you for your e-mail and attached Telkom letter, your comments are noted and will be clarified within the environmental impact assessment. Sincerely, Shawn Johnston Regards, Aletta Gabaitumele NIP: Wayleave Management Your letter dated 13 March 2015. I hereby inform you that Telkom SA SOC Ltd approves the proposed work on your drawing in principle in terms of Section 29 of the Electronic Communications Act No. 36 of 2005 as amended. Comments & Response Report Page 40 PROPOSED HYDRO SA RIEMVASMAAK RUN-OF-RIVER HYDRO ENERGY FACILITY & ASSOCIATED INFRASTRUCTURE, NORTHERN CAPE PROVINCE Draft Environmental impact Assessment Report No. Issue Raised by April 2015 Response from CES EIA team or Hydro SA Although we are not affected, Mr. Vivian Groenewald must be contacted at 054 338 6501/081 362 6738 before any commencement work. As per supplied sketches it would appear as if Telkom S Ltd infrastructure would not be affected. However care should be taken should it become evident that there is in fact Telkom network present at the actual sites. Such lines should be treated in accordance with, and clearance stipulated in the Occupational Health and Safety Act no 85 of 1993, Electrical Machinery regulations 20 – Crossings, and Electrical Machinery Regulations 15 – Clearance of Power Lines. If the specifications could not be met, all deviations costs will be for the applicant’s account. We also refer to section 25 of the Electronic Communications Act 36 of 2005. Any changes/deviations from the original planning or prior to construction must immediately be communicated to this office. On completion of this project, please certify that all requirement as stipulated in this letter have been met. Please note that should any of Telkom SA SOC Ltd infrastructure has to be relocated or altered as a result of your activities the cost for such an alteration or relocation will be for the account in terms of section 25 of the Electronic Communications Act. This approval is valid for 6 months only, after which reapplication must be made if the work has not been completed. Please notify this office and forward an as built plan, within 30 days of completion of construction. Although we are not affected, Mr. Vivian Groenewald must be contacted at 0543386501/081 362 6738 before any commencement of work. Should Telkom SA SOC Ltd infrastructure be damaged while work is undertaken, kindly call the Toll free number – 0800 203957. Comments & Response Report Page 41
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