regulation 54 (a) iii environmental compliance audit …

REGULATION 54 (A) III

ENVIRONMENTAL COMPLIANCE

AUDIT REPORT

Longyuan Mulilo De Aar Wind Power (RF) (Pty) Ltd

December 2019 (amended February 2020)

Prepared by: AMATHEMBA Environmental Management Consulting CC

REGULATION 54 (A) III

ENVIRONMENTAL COMPLIANCE

AUDIT REPORT

1. INTRODUCTION

1.1 BACKGROUND TO THE REPORT

Amathemba Environmental Management Consulting was appointed by Longyuan Mulilo De Aar Wind Power (RF)

(Pty) Ltd. (hereafter referred to as the “DA1”) to conduct an external audit in terms of Regulation 54 (a) iii.

The audit is with regards to compliance with the conditions stipulated in the Environmental Authorisations (EAs) and Environmental Management Programme (EMPr) issued to its Wind Energy Facility (WEF) situated outside of

De Aar, Emthanjeni Local Municipality.

The National Environmental Management Act (Act No. 107 of 1998) (NEMA) Environmental Impact Assessment

Regulations were amended on the 7th April 2017.

The following significant regulation was added as GN 326 under transitional provisions section 54A:

(3) Where an environmental authorisation issued in terms of the ECA regulations or the previous NEMA regulations

is still in effect by 8 December 2014, the EMPr associated with such environmental authorisation is subject to the requirements contained in Part 3 of Chapter 5 of these Regulations and the first environmental audit report must

be submitted to the competent authority no later than 7 December 2019 and at least every 5 years thereafter for

the period during which such environmental authorisation is still in effect.

The implication of this for the holder of a valid Environmental Authorisation/RoD for any project, is to have an

environmental audit to gauge and report on compliance with the associated conditions of approval. For projects that are beyond construction phase, the EA/RoD is still valid if the EA/RoD and EMPr mentions the operational

phase with conditions and/or specifications. Compliance audits must be undertaken by an experienced,

independent Environmental Auditor. Failure to comply with the NEMA Regulations is considered a criminal offence.

A site visit was conducted on the 27th November 2019 after which a report is compiled and serves to document the External Audit proceedings, and is a record of all observations, recommendations and conclusions made during

the engagement.

1.2 ASSUMPTIONS AND LIMITATIONS

• The assumption is made that all information received from Longyuan Mulilo De Aar Wind Power (RF) (Pty)

Ltd whether written or verbal communication, on which this audit report is based is accurate and correct.

• The audit is based purely on the conditions as stipulated in the EAs and EMPrs issued for DA1.

1.3 SCOPE, PURPOSES AND OBJECTIVES OF THE AUDIT

1.3.1 External compliance audit in terms of Regulation 54 (a) III

The main objective of the compliance audit was to respond to the need for external independent compliance audit as required in terms of Regulation 54 (a) III. The facility operates under the following authorisations and

Environmental Management Programs:

Documents

audited:

Document Title Document Reference Number Date of Issue

DEA EA ENVIRONMENTAL

AUTHORISATION IN TERMS OF

THE NATIONAL

ENVIRONMENTAL

MANAGEMENT ACT, 1998: GN

R 386 & 387; PROPOSED

ESTABLISHMENT: OF A WIND

POWER GENERATING FACILITY

NEAR DE AAR, NORTHERN

CAPE PROVINCE

DEA REFERENCE NO.:

12/12/20/1651

15th August 2011

5th August 2014 (1st

Amendment)

3rd December 2015 (2nd

Amendment)

DENC EA ENVIRONMENTAL

AUTHORISATION FOR GN.

R544: ACTIVITY 11, 18: BASIC

ASSESSMENT FOR ADDITIONAL

ACTIVITIES AT AN AUTHORISED

DE AAR1 WIND ENERGY

FACILITY (100MW)

SMOUSPOORT FARM

(REMAINING EXTENT OF FARM

130) AND ZWARTEKOPlES

FARM (REMAINING EXTENT OF

PORTION 2 OF FARM 131), DE

AAR

DENC REFERENCE NO.:

NC/BA/05/PIX/EMT/DEA2/2014

24th July 2014 (Amendment)

7th January 2016 (Amendment)

25th January (Amendment)

DEA EA for

Transmission

line

ENVIRONMENTAL

AUTHORISATION FOR THE

CONSTRUCTION OF THE 132KV

TRANSMISSION LINE AND

ASSOCIATED INFRASTRUCTURE

FROM THE LONGYUAN MULILO

DE AAR MAANHAARBERG

WIND ENERGY FACILITY TO THE

HYDRA SUBSTATION NEAR DE

AAR, NORTHERN CAPE

PROVINCE

DEA REFERENCE NO:

14/12/16/3/3/1/1165/AM1

11th August 2014

EMPr (DEA &

DENC)

And EMPr

Transmission

line

Environmental Management

Programme for Longyuan

Mulilo De Aar Maanhaarberg

Wind Energy Facility

DEA REFERENCE NO.:

12/12/20/1651

DENC REFERENCE NO.:


May 2015

The scope of the audit was limited to compliance matters as they relate to the above-mentioned documents.

Please note that the transmission line was only audited with respect to the construction phase as it is handed

over to Eskom for the operational phase.

1.3.2 Meeting requirements of Appendix 7 of EIA Regulations (2014, as amended)

A further objective was to meet the requirements of Appendix 7 of the 2014 EIA Regulations, as amended, which contains the minimum content requirements for compliance audit reports. The specific requirements are detailed

in the table below, together with a reference of where this is responded to in this audit report.

Regulatory Ref # of Appendix 7

Details of requirement Report Section Reference

1 The environmental audit report must provide for recommendations regarding the need to amend the EMPr, and where applicable, the closure plan.

Section 4

2 (a) (i) Report on level of compliance with the conditions of the environmental authorisation and the EMPr, and where applicable, the closure plan.

Section 3

2 (a) (ii) Report on the extent to which the avoidance, management and mitigation measures provided for in the EMPr, and where applicable, the closure plan achieves the objectives and outcomes of the EMPr, and closure plan.

Section 4

2 (b) Identify and assess any new impacts and risks as a result of undertaking the activity.

Section 4

2 (c) Evaluate the effectiveness of the EMPr, and where applicable, the closure plan.

Section 4

2 (d) Identify shortcomings in the EMPr, and where applicable, the closure plan.

Section 4

2 (e) Identify the need for any changes to the avoidance, management and mitigation measures provided for in the EMPr, and where applicable, the closure plan.

Section 4

3 (1) a An environmental audit report prepared in terms of these Regulations must contain details of the—

(i) independent person who prepared the environmental audit report; and (ii) expertise of the independent person that compiled the environmental audit report

Section 2

3 (1) b a declaration that the independent auditor is independent in a form as may be specified by the competent authority;

Section 2.4

3 (1) c an indication of the scope of, and the purpose for which, the environmental audit report was prepared;

Section 1.3

3 (1) d a description of the methodology adopted in preparing the environmental audit report;

Section 1.4

3 (1) e an indication of the ability of the EMPr, and where applicable, the closure plan to— (i) sufficiently provide for the avoidance, management and mitigation of environmental impacts associated with the undertaking of the activity on an ongoing basis; (ii) sufficiently provide for the avoidance, management and mitigation

of environmental impacts associated with the closure of the facility; and (iii) ensure compliance with the provisions of environmental authorisation, EMPr, and where applicable, the closure plan;

Section 4

3 (1) f a description of any assumptions made, and any uncertainties or gaps in knowledge;

Section 1.2

3 (1) g a description of any public consultation process that was undertaken during the course of carrying out the environmental audit report;

Section 1.4.3

3 (1) h a summary and copies of any comments that were received during any public consultation process; and

NA

3 (1) i any other information requested by the competent authority.

No additional requirements known at this point.

1.4 AUDIT METHODOLOGY

This audit report is based on a site inspection undertaken on 27th November 2019, review of relevant

documentation and subsequent follow-up communication with the facility’s compliance officer and representatives

of Longyuan Mulilo De Aar Wind Power (RF) (Pty).

1.4.1 Pre-audit tasks

Review of the various approvals / documents relevant to the facility. These documents have included the findings

of the ECO construction closure report and operation environmental audits reports undertaken by NCC

Environmental Services (Pty) Ltd (NCC).

Preparation of audit report template, which includes transfer of conditions of approval and EMPrs into the report

to inform the auditor’s enquiries during the on-site inspection.

1.4.2 On-site audit

The site inspection served to give the auditor an understanding of the environmental setting and the specific operational aspects of the facility, especially as it relates to the relevant approvals. The day-to-day operations of

the facility were observed, and interviews held with key parties in relation to compliance aspects.

1.4.3 Reporting

Compilation of the audit report and compliance checklist (Appendix A) based on the information obtained during

the audit inspection and any subsequent follow up liaison with relevant role-players. The final report will be issued

to the client (electronically) and the appropriate environmental authority.

In terms of NEMA Chapter 5, Part 3 Regulation 34 (6):

Within 7 days of the date of submission of an environmental audit report to the competent authority, the holder

of an environmental authorisation must notify all potential and registered interested and affected parties of the

submission of that report, and make such report immediately available—

(a) to anyone on request; and

(b) on a publicly accessible website, where the holder has such a website.

A notification will be sent to all registered interested and affected parties and the report will be uploaded onto

the Amathemba Environmental management Consulting website under public documents:

http://amathemba.com/

2. EXPERTISE OF THE AUDITOR

2.1 BARRY WIESNER

Barry Wiesner of Amathemba Environmental Management Consulting has been the independent ECO on several

other large-scale wind energy facilities and is author of this audit report.

Barry completed a MPHIL in Environmental Management at the University of Cape Town. Barry also has read a

BA majoring in Archaeology and Environmental and Geographical Science and has a Higher Diploma in Education (HDE) from the University of Cape Town. He also has a Bachelor of Theology from the University of South Africa.

Barry is a Green Star SA Accredited Professional and a member of the International Association of Impact

Assessors.

Barry has extensive site experience working as an Environmental Control Officer at major construction sites and

in conducting Environmental Audits, EIAs, BARs and the compilation of numerous Environmental Management

Programmes (EMPrs) over the last 18 years.

2.2 STATEMENT OF INDEPENDENCE

Amathemba Environmental Management Consulting was appointed to carry out the external compliance audit

and compile this resultant Audit Report. Amathemba Environmental Management Consulting has any material

present or contingent interest in the outcome of this report, nor do they have any pecuniary or other interest that could be reasonably regarded as being capable of affecting their independence. Amathemba Environmental

Management Consulting has no beneficial interest in the outcome of this compliance audit, other than reasonable remuneration for work performed in undertaking the audit inspection and compiling this report (see Appendix B

for signed declaration).

3. COMPLIANCE RESULTS

Please refer to the comprehensive table below for the detailed audit report checklist (Appendix A) of compliance with the respective conditions of the Environmental Authorisations and EMPrs relevant to the project. Please note

that the Transmission line is not included as part of the operational phase audit as it is now the property and

responsibility of Eskom and not Longyuan Mulilo De Aar Wind Power (RF) (Pty) Ltd.

3.1 ENVIRONMENTAL AUTHORISATION - DEA REFERENCE NO.: 12/12/20/1651

There were one hundred and thirty-nine (139) EA conditions.

127 conditions are noted as compliant, 9 conditions are partially compliant. No non-compliances are noted, and 3 conditions are deemed to be not applicable.

Of the partial compliances, 5 relate to the changed layout design. Although the Layout was initially authorised, the Layout changed after some design changes occurred resulting in non-compliance to buffer zones. Approval from DEA for the deviations is underway but is still outstanding. An amendment application has been submitted. This has been verified with the EAP undertaking the amendment.

3 of the partial compliances relate to noise specification during construction phase, primarily with respect noise monitoring and verification of noise levels. None were critical, the site is in a rural area, no complaints were received, and the construction phase is now completed. Furthermore, appropriate PPE was used where required and plant was fitted with appropriate sound dampeners.

The final partial compliance is with respect the installation of spikes on the nacelle. This condition was not incorporated in the design phase. It was initially recommended by the specialist that anti-perching devices be installed on the highest rails above the weather station of the nacelle. However, the specialist accepted that bird spikes will not be installed (because of safety reasons) and that the situation will be monitored during post-construction, and therefore this minor partial non-compliance was acceptable to the relevant specialist.

Table 1: DEA EA summary of compliance

Compliant

Partially

Compliant

Non-

compliant

Not

Applicable

Total Conditions 127 9 0 3

Percentage

compliance 93.4%

3.2 ENVIRONMENTAL AUTHORISATION - DENC REFERENCE NO.: NC/BA/05/PIX/EMT/DEA2/2014

Fifty (50) EA conditions were considered with respect to the DENC EA. One is not applicable and was removed through an amendment.

Table 2: DENC EA compliance summary

Compliant

Partially

Compliant

Non-

compliant

Not

Applicable


Percentage

compliance 100%

3.3 DEA EA FOR TRANSMISSION LINE DEA REFERENCE NO: 14/12/16/3/3/1/1165/AM1

Thirty-five (35) EA conditions were considered with respect to the transmission line. 5 are not applicable.

Table 3: Transmission Line EA compliance summary

Compliant

Partially

Compliant

Non-

compliant

Not

Applicable


Percentage

compliance 100%

3.4 EMPRS CONSTRUCTION PHASE

WEF

Two hundred and seven (207) EMPr specifications are considered in the audit. 5 are noted as partially compliant

and 4 are not applicable.

Once again, the primary partial compliance (3 specifications) relate to the layout amendment. Although the Layout was initially authorised, the Layout changed after some design changes occurred resulting in non-compliance to buffer zones. Approval from DEA for the deviations is underway but is still outstanding. An amendment application has been submitted. This has been verified with the EAP undertaking the amendment.

One specification relates to the dust monitoring. Ambient quantities of particulate matter were not measured in accordance with Air Quality Act, 2004 (Act 39 of 2004), however, adequate dust suppression was implemented

such as speed limits, dust suppression etc. on site.

One specification relates to the storage of hazardous substances at the Operations and Maintenance (O&M)

building during construction phase. Evidence observed on site, but not for substances that were stored for O&M

(multiple drums of grease, oil etc.).

Table 4: WEF EMPr compliance summary

Compliant

Partially

Compliant

Non-

compliant

Not

Applicable


Percentage

compliance 97.58%

Transmission Line

One hundred and twenty-six (126) specifications are considered in this audit. Only one is a partial compliance. As above, the specification relates to the dust monitoring. Ambient quantities of particulate matter were not

measured in accordance with Air Quality Act, 2004 (Act 39 of 2004), however, adequate dust suppression was

implemented such as speed limits, dust suppression etc. on site.

Table 5: Transmission Line EMPr compliance summary

Compliant

Partially

Compliant

Non-

compliant

Not

Applicable


Percentage

compliance 99.2%

3.5 EMPRS OPERATIONAL PHASE

Sixty-four (64) specifications are considered for the operational phase audit. 51 are complied with, one partially

complied with and 14 are not applicable.

Table 6: Operational Phase compliance summary

Compliant

Partially

Compliant

Non-

compliant

Not

Applicable


Percentage

compliance 98.08%

4. CONCLUSION AND RECOMMENDATIONS

The external audit was undertaken as required by the need for external independent compliance audit in terms of Regulation 54 (a) III. This resultant audit report meets the requirements of Appendix 7 of the 2014 EIA

Regulations, as amended.

The following conclusions are drawn subsequent to the audit inspection and consideration of compliance with

conditions of approval:

• The overall impression was one of a very well-run facility with a strong commitment to achieving full

compliance.

• The partial compliances mainly relate to the layout amendment process which is underway. It is

recommended this process be concluded as soon as possible.

• The other partial compliance related to the construction phase and are no longer relevant during the

operation of the facility. They are just noted partial compliances from the construction phase and no further

action or mitigation is required.

• Although there have been several birds related incidents, the Project has implemented a mitigation measure

(installation of bird perches) to reduce the risk of electrocutions. The effectiveness of this is currently being monitored. Further mitigation measures to reduce the risk of turbine collisions is being developed in

consultation with BirdLife SA and the project’s avifaunal specialist.

• Further monitoring will determine the effectiveness of the bird perches and other proposed mitigations

(once implemented) and if there is any need for additional mitigation measures.

• There is no need for amendments to the Management Plans (Environmental Management Programme)

implemented by the facility.

• No new impacts or risks were identified.

• There is no intention to close the facility in the foreseeable future, and hence no closure plan is relevant

yet. Should decommissioning be planned it would be subject to the necessary regulatory processes and

the compilation and implementation of a closure plan.

The audit process itself had no implications for the rights of any parties, however in accordance with NEMA Chapter 5, Part 3 Regulation 34 (6): all registered IAPs will be notified that the required audit has been undertaken

and will be made available if requested and posted on Amathemba’s website for a minimum period of 30 days.

Yours sincerely

Barry Wiesner (0824626221)

LIST OF APPENDICES

APPENDIX 1: Audit Checklist

APPENDIX 2: Declaration of independence

APPENDIX 1: AUDIT CHECKLIST

AMATHEMBA Environmental Management Consulting Audit Checklist

1

APPENDIX 1 AUDIT CHECKLIST

Longyuan Mulilo De Aar Maanhaarberg Wind Energy Facility

Date: Site visit – Wednesday 27th November 2019

Participants: Barry Wiesner Amathemba Environmental Consultants

Documents audited: Document Title Document Reference Number Date of Issue DEA EA ENVIRONMENTAL AUTHORISATION IN TERMS OF THE

NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998: GN

R 386 & 387; PROPOSED ESTABLISHMENT: OF A WIND

POWER GENERATING FACILITY NEAR DE AAR, NORTHERN

CAPE PROVINCE

DEA REFERENCE NO.:

12/12/20/1651

15th August 2011

5th August 2014 (1st Amendment)

3rd December 2015 (2nd Amendment)

DENC EA ENVIRONMENTAL AUTHORISATION FOR GN. R544: ACTIVITY

11, 18: BASIC ASSESSMENT FOR ADDITIONAL ACTIVITIES AT

AN AUTHORISED DE AAR1 WIND ENERGY FACILITY (100MW)

SMOUSPOORT FARM (REMAINING EXTENT OF FARM 130)

AND ZWARTEKOPlES FARM (REMAINING EXTENT OF

PORTION 2 OF FARM 131), DE AAR

DENC REFERENCE NO.:


24th July 2014 (1st Amendment)

7th January 2016 (2nd Amendment)

25th January (3rd Amendment)

DEA EA for

Transmission line

ENVIRONMENTAL AUTHORISATION FOR THE

CONSTRUCTION OF THE 132KV TRANSMISSION LINE AND

ASSOCIATED INFRASTRUCTURE FROM THE LONGYUAN

MULILO DE AAR MAANHAARBERG WIND ENERGY FACILITY

TO THE HYDRA SUBSTATION NEAR DE AAR, NORTHERN CAPE

PROVINCE

DEA REFERENCE NO:

14/12/16/3/3/1/1165/AM1

11th August 2014

EMPr (DEA & DENC)

And EMPr

Transmission line

Environmental Management Programme for Longyuan

Mulilo De Aar Maanhaarberg Wind Energy Facility

DEA REFERENCE NO.:

12/12/20/1651

DENC REFERENCE NO.:


May 2015

Shading Key

Compliance Y Partial compliance Y/X Non-compliance X Not Applicable NA

2

Document

Reference

Number

Issue to Review Y/X/NA Rationale/Appendix/ Proof/Site observation

Notes and Recommendations

DEA EA

Scope of work

1.1 Layout Alterative 1 as described in the EIR dated November 2010 is

hereby authorised.

Y/X Although the Layout was initially authorised, the Layout changed

after some design changes occurred resulting in non-compliance to

buffer zones. Approval from DEA for the deviations is underway but is

still outstanding. An amendment application has been submitted

and the process is underway. This has been verified with the EAP

undertaking the amendment.

1.2 Authorisation of the activity is subject to the conditions contained in this

authorisation, which form part of the environmental authorisation and

are binding on the holder of the authorisation.

Y Noted

1.3 The holder of the authorisation shall be responsible for ensuring

compliance with the conditions contained in this environmental

authorisation. This includes any person acting on the holder's behalf,

including but not limited to, an agent, servant, contractor, sub-

contractor, employee, consultant or person rendering a service to the

holder of the authorisation.

Y "The licence holder took all reasonable measures to ensure conditions

of the EA were met.

Obligations towards the EA were included in the contracts issued to

the various sub-contractors/ service providers " – confirmed in the

construction closure report.

1.4 The activities authorised may only be carried out at the property as

described.

Y Noted and complied with.

1.5 The recommendations and mitigation measures recorded in the EIR

dated November 2010 must be adhered to.

Y Included in approved EMPr.

1.6 Any changes to, or deviations from, the project description set out in this

authorisation must be approved, in writing, by the Department before

such changes or deviations may be affected. In assessing whether to

grant such approval or not, the Department may request such

information as it deems necessary to evaluate the significance and

impacts of such changes or deviations and it may be necessary for the

holder of the authorisation to apply for further authorisation in terms of

the regulations.

Y/X Although the Layout was initially authorised, the Layout changed after

some design changes occurred resulting in non-compliance to buffer

zones. Approval from DEA for the deviations is underway but is still

outstanding. An amendment application has been submitted and the

process is underway. This has been verified with the EAP undertaking

the amendment.

1.7 This activity must commence within a period of three (3) years from the

date of issue. If commencement of the activity does not occur within

that period, the authorisation lapses and a new application for

environmental authorisation must be made in order for the activity to be

undertaken.

Y The activity commenced on 24 Aug 2015.

Although the initial EA was issued on 15 Aug 2011, it was amended in

24 Oct 2011, 31 July 2014 & 5 Aug 2014.

1.8 Commencement with one activity listed in terms of this authorisation

constitutes commencement of all authorised activities.


1.9 This authorisation does not negate the holder of the authorisation’s

responsibility to comply with any other statutory requirements that may

be applicable to the undertaking of the activity.


3

10.1 Relevant legislation that must be complied with by the holder of the authorisation includes inter alia:

·• Archaeological remains, artificial features and structures older than

60 years are protected by National Heritage Resources Act, 1999 (Act

No. 25· of ·1999). Should any archaeological artefacts be exposed

during excavation for the purpose of construction, construction in the

vicinity of the finding must be stopped immediately. A registered

Heritage Specialist must be called to the site for inspection. Under no

circumstances shall any heritage material be destroyed or removed

from the site and the relevant heritage resource agency must be

informed about the finding. Heritage. remains uncovered or disturbed

during earthworks must not be disturbed further until the necessary

approval has been obtained from the South African Heritage Resources

Agency and/or any of their delegated provincial agencies.

Y No archaeological artefacts were exposed during excavation for the

purpose of construction nor have any been noted during the

operational phase.

• Relevant provisions of the Occupational Health and Safety Act, 1993

(Act No. 85 of 1993).

Y Independent monthly OHS audits were undertaken during the

construction phase to verify compliance.

• Relevant provisions of the National Water Act, 1998 (Act No. 36 of

1998).

Y Noted and complied with, GA issued.

• Relevant provisions of the National Forests Act, 1998 (Act No. 84 of

1998).

Y Licence (NCU 6291215) allowed for the destruction of the protected

and slow growing Shepherd’s tree (Boscia albitrunca)

• Relevant provisions of the National Environmental Management

Biodiversity Act, 2004(Act No. 10 of 2004).

Y Based on the Biodiversity Permit Commitment Agreement, the permit

holder “Commit in providing update reports every six (6) moths on the

status of species destroyed, transplanted, exported and donated for

the Longyuan Mulilo De Aar Wind Power (RF) (Pty) Ltd development,

as per ODB 1905/2014. Semester reports (May/June and Dec/Jan)

were provided in accordance to the register format (template)

provided.

• Relevant provisions of' the National Environmental Management

Protected Areas Act, 2003 (Act No. 57 of 2003) and its Regulations.


• Relevant provisions of the National Environmental Management Waste

Act, 2008 (Act No. 59 of 2008) and its Regulations.


• Relevant provisions of the Hazardous Substance Act (Act No. 15 of

1973).


• Relevant Provisions of the National Environmental Management Air

Quality Act, 2004 (Act No. 39 of 2004).


Relevant provisions of the Civil Aviation Act, 2009 (Act No. 13 of 2009). Y Noted and complied with.

Should fill material be required for any purpose, the use of borrow pits

must comply with the provisions of the Minerals and Petroleum Resources

Development Act, 2002 (Act No. 28 of 2002) administered by the

Department of Mineral Resources.

Y Mining permits and DMR's acknowledgement for renewal was

received for two suppliers: a Borrow pit and De Aar Stone Crushers

• All outdoor advertising i.e. signage boards associated with this

proposed activity must be below the thresholds stipulated in the EIA

Regulations as it was not applied for as an activity for authorisation

during the Environmental Authorisation process. Should the holder of the

Environmental Authorisation wish to exceed these thresholds he/she

must submit an application for authorisation to this Department. Further,


4

all outdoor advertising associated with this proposed activity whether on

or off the property concerned, must comply with the applicable Local

Authority By-Law for the control of Outdoor Advertising or in the absence

of local legislative controls. must comply with the South African Manual

for Outdoor Advertising Control (SAMOAC).

1.11 The holder of an environmental authorisation has the responsibly to

notify the competent authority of any alienation transfer and change of

ownership rights in the property on which the activity is to take place.

Y EA was amended to include addition of the property descriptions into

the EA.

Notification of authorisation

2.1 The holder of the authorisation must notify' every registered interested

and affected party, in writing and within 12 (twelve) calendar days of

the date of this environmental authorisation, of the decision to authorise

the activity.

Y The letter from DJ Environmental Consultants confirmed notification

was sent to I&APP's

2.2 The notification referred to must Y Record could not be verified; however, this was "approved" during

financial close by the lawyers and no complaints were received from

I&APP's. 2.2.1 specify the date on which the authorisation was issued; Y

2.2.2 inform the interested and affected party of the appeal procedure

provided for in Chapter 7 of the Environmental Impact Assessment (EIA)

Regulations, 2010.

Y

2.2.3 advise the interested and affected party that a copy of the

authorisation will furnished on request, and

Y

2.2.4 give the reasons for the decision. Y

Management of the activity

3.1 The Environmental Management Plan (EMP) submitted as part of

application for environmental authorisation must be amended and

submitted to the Department for written approval prior to

commencement of the activity. The recommendations and mitigation

measures recorded in the EIR dated November 2010 must be

incorporated as part of the EMP.

Y The recommendations and mitigation measures were incorporated

into the approved EMPr.

3.2 Once approved the EMP must be implemented and adhered to. The

amended EMP must also include the following:


3.2.1 Comprehensive rescue and storage in a suitable constructed nursery

and storage area of plants deemed to be requiring either rescue for

replanting and plants that will be useful during rehabilitation.

Y No nursery was used. All plants were safely relocated directly to

adjacent land. Search & Rescue reports were provided. Appendix 9

of EMPr.

3.2.2 A detailed Revegetation and Rehabilitation Plan to be implemented

during construction and operation.

Y Appendix 10 of EMPr.

3.2.3 A Rehabilitation Plan must be compiled to minimize adverse

environmental impacts whilst maximizing the future utilization of the

property and


3.2.4 An Open Space Management Plan must be incorporated in the EMP.

The Open Space Management Plan must incorporate ecological

process areas into the buffer as recommended by the wetland

specialist.

Y Appendix 15 of EMPr.

Monitoring

5

4.1 The applicant must appoint a suitably experienced independent

Environmental Control Officer (ECO) for the construction phase of the

development that will have the responsibility to ensure that the

mitigation/rehabilitation measures and recommendations referred to in

this authorisation are implemented and to ensure compliance with the

provisions of the EMP.

Y NCC Environmental Services (Pty) Ltd were appointed.

4.2 The ECO shall be appointed before the commencement of any

authorised activity.

Y Evidence of appointment was provided.

4.3 Once appointed, the name and contact details of the ECO must be

submitted to the Director Compliance Monitoring of the Department.

Y Evidence of notification to the Department including CV's and

change in ECO were provided.

4.4 The ECO shall keep a record of all activities on the site problems

identified, transgressions noted, and a task schedule of tasks undertaken

by the ECO.

Y ECO Concerns register and Weekly environmental reports were

provided.

4.5 A detailed incident (including spillage of bitumen, fuels, chemicals, or

any other material) and complaint register must be kept on site

indicating how these issues were addressed, what rehabilitation

measures were taken and what preventative measures were

implemented to avoid re-occurrence of incidents/complaints.

Y Weekly environmental reports were provided.

4.6 In addition, the ECO must maintain the following on site:

4.6.1 A daily site diary Y Records kept.

4.6.2 Copies of all reports submitted to the Department. Y Noted.

4.6.3 A schedule of current site activities including the monitoring of such

activities.

Y Records kept.

4.7 The ECO shall remain employed until all rehabilitation measures, as

required for implementation due to construction damage, are

completed and the site is ready for operation.

Y NCC were on site as required.

4.8 Records relating to monitoring and auditing must be kept on the site and

made available for inspection to any relevant and competent authority

in respect of this development.

Y Audit reports and records available.

Recording and reporting to the Department

5.1 All documentation e.g. audit/monitoring/compliance reports and

notifications, required to be submitted to the Department in terms of this

authorisation, must be submitted to the Director: Compliance

Monitoring at the Department.


5.2 The holder of the authorisation must submit an environmental audit

report to this Department upon completion of the construction and

rehabilitation activities.

Y NCC completed the required report.

5.3 The environmental audit report must Y NCC completed the required report.

5.3.1 Be conducted by an independent environmental auditor. Y

5.3.2 Indicate the date of the audit, the name of the auditor and the

outcome of the audit.

Y

5.3.3 Evaluate compliance with the requirements of the approved EMO and

this environmental authorisation.

Y

6

5.3.4 Include measures to be implemented to attend to any non-

compliances or degradation noted.

Y

5.3.5 Include copies of any approvals granted by other authorities relevant to

the development for the reporting period and

Y

5.3.6 Highlight any outstanding environmental issues that must be addressed,

along with recommendations for ensuring these issues are appropriately

addressed.

Y

5.4 The audit report must be submitted prior to commencement of the

operation phase of the project.

Y NCC completed an submitted the required report.

Commencement of the activity

6.1 The authorised activity shall not commence within twenty (20) days of

the date of signature of authorisation.

Y The activity commenced on 24 Aug 2015.

Although the initial EA was issued on 15 Aug 2011, it was amended in

24 Oct 2011, 31 July 2014 & 5 Aug 2014.

6.2 An appeal under section 43 of the National Environmental

Management Act (NEMA). Act 107 of 1998 (as amended), does not

suspend an environmental authorisation or exemption, or any provisions

or conditions attached thereto, or any directive, unless the Minister, MEC

or delegated organ of state directs otherwise.

Y Noted.

6.3 The applicant must obtain a Water Use License from the Department of

Water Affairs (DWA) prior to the commencement of the project should

the applicant impact on any wetland or water resource. A copy of the

license must be submitted to the Director Environmental Impact

Evaluation at the Department.

Y The project had a GA for borehole abstraction and stream crossings

and informed DWS of the change in the water crossing positions.

6.4 The applicant must submit a final layout plan for the entire wind energy

facility for approval to the department, prior to commencement of

construction. The layout should indicate the following:

Y Although the Layout was initially authorised, the Layout changed



still outstanding. This has been verified with the EAP undertaking the

amendment.

● Turbine positions Y Indicated as required. Note WTG 13, 14, 40, 46, 57 changed.

● Foundation footprint Y Indicated as required.

● Permanent laydown area footprint Y No permanent laydown required

● Construction period laydown footprint Y Indicated as required.

● Internal roads indicating width (construction period width and

operation period width) and with numbered sections between

the other site elements which they serve (to make commenting

on sections possible)

Y Indicated as required.

7

● Wetlands, drainage lines, rivers, streams and water crossing of

roads and cables indicating the type of bridging structures that

will be used.

Y The water crossing positions are indicated, but type of bridging

structures is not displayed, which were approved by DEA - consists of

mostly ditch drains and some pipe culverts.

● Heritage sites that will be affected by the turbines and

associated infrastructure

Y Indicated as required

● Substations(s) and/or transformer(s) sites including their entire

footprint

Y Indicated as required

● Cable routes and trench dimensions (where they are not along

internal roads)

Y Cable routes are indicated but run above ground not in trenches.

Cables run above ground with bird flappers

● Connections routes to the distribution/transmission network Y Indicated as required

● Cut and fill areas at turbine sites along roads and at

substation/transformer sites indication the expected volume of

each cut and fill

Y Terrain is of such nature that only the total cut & fill volumes are

indicated

● Borrow pits Y External supplier was used.

● Spoil heaps (temporary for topsoil and subsoil and permanently

for excess material)

Y Temporary spoil heaps were either used in construction or used for

rehabilitation. No permanent spoil heaps were left on site.

● Buildings including accommodation and Y Only 132kV Substation and O and M building.

8

● All “no-go” areas. Y Indicated as required, except for 100m ridge buffer, but specialist

approval was provided

6.5 The applicant must appoint a qualified botanical and fauna specialist

to ground-truth every turbine footprint and their recommendation must

form part of the final layout of the Wind Energy Facility and EMP to be

submitted to the department for approval.

Y Botanical and fauna specialist ground-truth reports were provided as

species were relocated form the footprint.

Notification to authorities

7.1 Fourteen (14) days written notice must be given to the Department that

the activity will commence. Commencement for the purposes of this

condition includes site preparation. The notice must include a date on

which it is anticipated that the activity will commence. This notification

period may coincide with the period contemplated in 6.1 above.

Y Notification given

Operation of activity

8.1 Fourteen (14) days written notice must be given to the Department that

the activity operational phase will commence.

Y Notification given

8.2 The applicant must compile an operational EMP for the operational

phase of the activity or alternatively, if the applicant has an existing

operational environmental management system. It must be amended

to include the operation of the authorised activity.

Y Appendix 4 of the EMPr

Site closure and decommissioning

9.1 Should the activity ever cease or become redundant, the applicant

shall undertake the required actions as prescribed by legislation at the

time and comply with all relevant legal requirements administered by

any relevant end competent authority at that time.

Y Noted.

Specific conditions

10.1 Avifauna and bats

10.1.1 A bird and bat monitoring programme must be implemented to

document the effect of the operation of the wind energy facility on

avifauna and bats. This should commence prior to construction and

continue during operation of the wind energy facility.

Y Pre-construction Bat & Bird Monitoring reports were provided.

Operational monitoring did not commence once the first turbine

started turning as stipulated (which should've started in Aug 2017).

Bird and bat monitoring commenced in December 2017, by Chris

Van Rooyen and Animalia respectively.

10.1.2 The results of the pre-constructed bird monitoring programme must

inform the final layout and the construction schedule of the wind energy

facility.

Y Complied with.

10.1.3 Reports regarding bird monitoring must be submitted to the relevant

provincial environmental department, Birdlife South Africa, the

Endangered Wildlife Trust (EWT) and this Department on a quarterly

basis. The report will assist all stakeholders in identifying potential and

additional mitigation measures and to establish protocols for a bird

monitoring programme for wind energy development in the country.

Y Pre-construction reports were submitted, and operational reports are

submitted to:

Bird reports are sent to:

'[email protected]';

'[email protected]'; '[email protected]';

'[email protected]'; '[email protected]'; '[email protected]';

'[email protected]';

Bat reports are sent to the above, but also '[email protected]';

9

10.1.4 The baseline data collected and documented during the survey must

be shared with the EWT and Birdlife South Africa for a better

understanding of the distribution or breeding behaviour of any of the

priority species.


10.1.5 Habitat destruction must be kept to an absolute minimum by keeping

the lay-down areas as small as possible, reducing the number and

size/length or roads and reducing the final extent of the developed

area.

Y Laydown areas were fenced, NE lay-down was not utilised, cut/fill

operations were big because of the terrain, but kept reasonably

practical.

10.1.6 The applicant must ensure the lighting on the turbines is kept to a

minimum and is coloured (red or green) and intermittent, rather than

permanent and white, to reduce confusion effects for nocturnal

migrants.

Y

Technical specs were provided.

10.1.7 The facility must be designed to discourage their use as perching or

roosting substrates by birds and bats.

Y/X This condition was not incorporated in the design phase. It was initially

recommended by the specialist that anti-perching devices be

installed on the highest rails above the weather station of the nacelle.

However, the specialist accepted that bird spikes will not be installed

(because of safety reasons) and that the situation will be monitored

during post-construction.

Bird diverters have been included on the transmission lines and within

the substation.

As per the recommendation of the avifaunal specialist T perches

have recently been erected on the internal transmission lines as an

alternative perch to limit contact with livewires to mitigate potential

electrocution impacts.

10.2 Vegetation, wetlands and water resources

10.2.1 All species of special concern (SSC) must be identified and every effort

must be made to rescue them.

Y Botanical Search and Rescue was undertaken.

10.2.2 Vegetation clearing must be limited to the required footprint. Mitigation

measures must be implemented to reduce the risk of erosion and the

invasion of alien species.

Y Noted. Storm water measures were implemented, and invasion of

alien species were monitored in the weekly report

10.2.3 Service and construction roads must be restricted to the power line

servitude area or existing roads and need to be maintained in a manner

as not to encroach onto any sensitive areas adjacent to the approved

servitude or site.

Y

No-go areas were discussed during inductions

10.2.4 Critical available biodiversity information must be consulted for the final

placement of turbines and infrastructure.







10.2.5 The applicant must ensure that the continuous monitoring and removal

of alien plant species is undertaken. An alien removal program must be

developed and implemented.

Y

Monitoring was noted in weekly and biodiversity reports

10.2.6 A “Plant Rescue and Protection” plan which allows for the maximum

transplant of conservation important species from areas to be

Y A Plant Rescue Plan was Incorporated as an Appendix 9 of the EMPr.

Botanical Search and Rescue was undertaken.

10

transformed must be compiled by a vegetation familiar with the site in

consultation with the ECO. This plan must be implemented prior to

commencement of the construction phase.

10.2.7 Before the clearing of the site, the appropriate permits must be obtained

from the Department of Agriculture, Forestry and Fisheries (DAFF) for the

removal of plants listed in the National Forest Act and from the relevant

provincial department for the destruction of species protected in terms

of the specific provincial legislation. Copies of the permits must be

submitted to the Department for record keeping.

Y

Evidence of records were provided (for both permits: NCU 6291215 &

ODB 1905/5/2014 FLORA 154/5/2015)

10.2.8 Construction activities must be restricted to demarcated areas to restrict

impact on vegetation and animals.

Y No-go areas were discussed during inductions

10.2.9 A comprehensive habitat rehabilitation plan must be developed for the

site. Restoration must be undertaken as soon as possible after

completion of construction activities to reduce the amount of habitat

converted at any one time and to speed up recovery to natural

habitats.

Y

Incorporated as an Appendix 10 of the EMPr.

10.2.10 All areas of disturbed soil must be reclaimed using only indigenous grass

and shrubs Reclamation activities should be undertaken as early as

possible on disturbed areas.

Y Revegetation (hydro seeding) occurred on barren areas.

All disturbed areas were hydroseeded, recovery is varied

10.2.11 All electrical collector lines must be buried in a manner that minimizes

additional surface disturbance.

Y 33kV is above ground to minimise botanical impacts associated with

blasting in the said terrain.

10.2.12 Topsoil from all excavations and construction activities must be salvaged

and reapplied during reclamation.

Y Topsoil was salvaged where possible

10.2.13 No trapping or killing of animals is allowed in and around the

construction site. The construction site must be clearly demarcated.

Y Included in inductions and awareness posters. Site is within fenced

farms.

11

10.2.14 The applicant is required to inform the relevant provincial department

and/or this Department should the removal of protected species,

medicinal plants and “data deficient” plant species be required.

Y Evidence of records were provided (for both permits: NCU 6291215 &

ODB 1905/5/2014 FLORA 154/5/2015). Results provided in Biodiversity

Update reports

10.2.15 All hard infrastructures should be located within existing areas of low

sensitivity as far as possible.







10.2.16 All turbine and infrastructure must be located at least 100m from the

edge of any highly sensitive areas.







10.2.17 No exotic plants may be used for rehabilitation purposes, only

indigenous plants of the area may be utilized.


10.2.18 No activities will be allowed to encroach into a water resource without

a water use license being in place from the Department of Water Affairs.

Y The project had a GA for borehole abstraction and stream crossings

and the DWS has been informed of the change in the water crossing

positions.

10.2.19 Appropriate erosion mitigation must be implemented to prevent any

potential erosion.

Y Evidence observed on site.

10.2.20 Cleared alien vegetation must not be dumped on adjacent intact

vegetation during clearing but should be temporarily stored in a

demarcated area.

Y

Noted and complied with.

10.2.21 Removal of alien invasive species or other vegetation must be in

accordance with the Conservation of Agricultural Resources Act (Act 43

of 1983), and follow-up procedures for the duration of the project.

Y

Noted alien management plan in appendix 11 of the EMPr.

10.2.22 The applicant must ensure that all the "No-go” areas are clearly

demarcated (using fencing and appropriate signage) before

construction commences.

Y

Camps/ laydown areas were fenced off.

10.2.23 Contractors and construction workers must be clearly informed of the

no-go areas.

Y Covered in inductions & toolbox talks.

10.2.24 Siting of turbines should adhere to >500m setbacks from large water

bodies, riparian vegetation and rocky crevices, if and where high bat

occurrence is found after monitoring.

Y

Evidence of required records were provided

10.2.25 Where roads pass right next to major water bodies provision should be

made for fauna such as toads to pass under the roads by using culverts

or similar.

Y


10.2.26 Bridge design must be such that if minimis impact to the riparian areas

with minimaI alterations to water flow and must be permeable to

movement of fauna and flora.

Y

Evidence observed on site.

10.2.27 During construction the footprint of the Impact should be kept to a

minimum. All construction activities and/or earthworks must be carried

Y No go areas identified in ENVIRONMENTAL EXCLUSION ZONES layout

map.

12

out within the limits of the authorised site. No go areas must be identified

to minimise compaction of soil and potential erosion.

10.3 Roads and transportation

10.3.1 Access to the Swartkoppies section must be gained through the

Smauspoort Road and not the R348. The Smauspoort Road must be

surfaced as per the recommendation of the Traffic Impact Assessment

Report in the EIR dated November 2010.

Y All roads are being maintained as required.

10.3.2 Existing road infrastructure must be used as far as possible for providing

access to proposed turbine positions. Where no road infrastructure exists,

new roads should be placed within existing disturbed areas or

environmental conditions must be taken into account to ensure the

minimum amount of damage is caused to natural habitats.

Y


10.3.3 A transportation plan must be developed, particularly for the transport

of turbine components, main assembly cranes and other large pieces of

equipment. A permit must be obtained from the relevant transport

department for the transportation of all components (abnormal loads)

to the sites.

Y


10.3.4 A traffic management plan must be prepared for the site access roads

to ensure that no hazards would result from the increased truck traffic

and that traffic flow would not be adversely impacted.

Y

Noted.

10.3.5 Signs must be placed along construction roads to identify speed limits,

travel restrictions, and other standard traffic control information. To

minimize impacts on local commuter, consideration should be given to

limiting construction vehicles traveling on public roadways during the

morning and late afternoon commute time.


10.3.6 Roads must be designed so that changes to surface water runoff are

avoided and erosion is not initiated.


10.3.7 Internal access roads must be located away from drainage bottoms

and avoid wetlands, if feasible


10.3.8 Internal access roads must be located to minimize stream crossings. All

structures crossing streams must be located and constructed so that

they do not decrease channel stability or increase water velocity.


10.3.9 Existing drainage must not be altered, especially in sensitive areas Y Noted and complied with.

10.3.10 A designated access to the site must be created and clearly marked to

ensure safe entry and exit.


10.3.11 Signage must be erected at appropriate points warning of turning traffic

and the construction site.


10.3.12 Construction vehicles carrying materials to the site should avoid using

roads through densely populated built-up areas so as not to disturb

existing retail and commercial operations.


10.3.13 Road borders should be regularly maintained to ensure that vegetation

remains short and that they therefore serve as an effective firebreak.


10.4 Noise

13

10.4.1 Construction staff to be given training in action to minimise noise

impacts.

Y/X No training was done, but plant was fitted with the appropriate sound

dampeners. Site is in rural area away from social developments.

10.4.2 Noise from the turbines at the identified noise sensitive areas must be less

than 45 dB(A) limit for rural areas presented In SANS10103.

Y/X The noise levels were not measured to comply to the limit however,

activities occurred in rural areas with no complaints received from

the adjacent landowners.

10.4.3 The applicant must ensure that the Naliona1 Noise Control Regulations

and SANS10103:2008 are adhered to and reasonable measures to limit

noise from the work site are implemented.

Y/X Adherence to SANS could not be verified however, reasonable

measures was taken, and plant were fitted with the appropriate

sound dampeners, staff wore normal H&S PPE etc.

10.4.4 The applicant must ensure that the construction staff working in areas

where the 8-hour ambient noise levels exceed 75 dBA must wear ear

protection equipment

Y

Appropriate PPE was used.

10.4.5 The applicant must ensure that all equipment and machinery are well

maintained and equipped with silencers.


10.4.6 The applicant must provide a prior warning to the community when a

noisy activity e.g. blasting is lo take place.


10.4.7 All construction operations should only occur during daylight hours if

possible.

Y Dept was notified and approved the night work.

DENC authorisation: Condition 39 was amended to allow working at

night.

10.4.8 All wind turbines should be located at a setback distance of 500 m from

any homestead and a day/night noise criteria level at the nearest

residents of 45 dB (Al should be used to locate the turbines. The 500 m

setback distance can be relaxed if local factors; such as high ground

between the noise source and the receiver, indicates that a noise

disturbance will not occur


10.4.9 Positions of turbines jeopardizing compliance with accepted noise levels

should be revised during the micro-siting of the units in question and

predicted noise levels re-modelled by the noise specialist in order to

ensure that the predicted noise levels are less than 45 dB(A).


10.5 Visual resources

10.5.1 The applicant must reduce visual impacts during construction by

minimizing areas of surface disturbance, controlling erosion, using dust

suspension techniques and restoring exposed soil as closely as possible

to their original contour and vegetation.


10.5.2 A lighting engineer must be consulted to assist in the planning and

placement of light fixtures in order to reduce visual impacts associated

with glare and light trespass.


10.5.3 Signs near wind turbine should be avoided unless they served to inform

the public about wind turbines and their function.


10.5.4 Commercial messages and graffiti on turbines must be avoided. Y Authorisation will be amended to include a commercial logo, to be

displayed on the turbines. See condition 1.10.12. Currently however,

no logos exist on the turbines.

10.5.5 The applicant must ensure that the painting of the wind turbines is in

accordance with the Aviation Act, 1962, Thirteenth Amendment of the

Civil Aviation Regulations, 1997.

Y

The turbines are white

14

10.5.6 Laydown areas and stockyards should be located in low visibility areas

(e.g. valleys between ridges) and existing vegetation should be used to

screen them from view where possible.

Y


10.5.7 Construction activities must be restricted to daylight hours in order to

negate or reduce visual impact associated with lighting.

Y This condition has been amended and removed by DEA.

10.5.8 Night lighting of the construction sites should be minimized within the

requirements of safety and efficiency.

Y MS and Risk Assessment was done.

10.6 Human health and safety

10.6.1 The health and safety program must be developed to protect both

workers and the general public during construction, operation and

decommissioning of the wind energy facility. The program must establish

a safety zone for wind turbines from: residents and occupied buildings,

roads, right-of-way and other public access areas that is sufficient to

prevent accidents resulting from the operation of the wind turbines.

Y

A safety management plan was provided and approved by Dept of

Labour.

10.6.2 Potential interference with public safety communication systems (e.g.

radio traffic related to emergency activities) must be avoided.


10.6.3 The applicant must ensure that the operation of the wind facility has

minimal electromagnetic interference (EMI) (i.e. impacts to microwave,

radio and television transmissions) and should comply with the relevant

communication regulations.


10.6.4 The applicant must obtain a written permit or approval from South Africa

Civil Aviation Authority That the wind facility will not interfere with the

performance of aerodrome radio Communication, Navigation and

Surveillance (CNS) equipment expressly the radar prior to

commencement of the activity. Their approval/permit must be

submitted to the Director Environmental Impact Evaluation.


10.6.5 The applicant must train safely representatives, managers and workers

in workplace safety. The construction process must be compliant with all

safety and health measures as prescribed by the relevant act.

Y


10.6.6 Liaison with landowners/farm managers is to be done prior to

construction in order to provide sufficient time for them to plan

agriculture activities. If possible, construction should be scheduled to

take place within the post-harvest, pre planting season when fields are

lying fallow.

Y

Open communication was noted.

10.6.7 No open fires for cooking or heating must be allowed on site. Y Noted and complied with.

10.7 Hazardous materials and waste management

10.7.1 Areas around fuel tanks must be bunded or contained in an appropriate

manner as per the requirements of SABS 089: 1999 Part 1.

Y Concrete & earth bunds were used.

10.7.2 Leakage of fuel must be avoided at all times and if spillage occurs, it

must be remedied immediately.

Y Drip trays used; spill kits available

10.7.3 Hazardous waste such as bitumen, oils, oily rags, paint tins etc. must be

disposed of at an approved hazardous waste landfill site.

Y EnviroServ and Oilkol manifest provided.

10.7.4 An effective monitoring system must be put in place during the

construction phase of the development to detect any leakage or

Y Appropriate inspections undertaken.

15

spillage of all hazardous substances during their transportation,

handling, use and storage. The applicant must ensure that

precautionary measures are in place to limit the possibility of oil and

other toxic liquids from entering the soil or stormwater system.

10.7.5 Streams, rivers, pans, wetlands, dams and their catchments and other

environmental sensitive areas must be protected from direct or indirect

spillage of pollutants.

Y


10.7.6 No dumping or temporary storage of any materials may take place

outside designated and demarcated laydown areas, and these must all

be located within areas of low environmental sensitivity.

Y


10.7.7 Hazardous substances must not be stored where there could be

accidental leakage into surface or subterranean water.

Y Stored on impermeable surfaces.

10.7.8

Hazardous and flammable substances must be stored and used in

compliance with the applicable regulations and safety instructions.

Furthermore, no chemicals must be stored nor may any vehicle

maintenance occur within 350m of the temporal zone of wetlands, a

drainage line with or without an extensive floodplain or hillside wetlands.

Y


10.7.9 Temporary bunds must be constructed around chemical storage to

contain possible spills.

Y Concrete & earth bunds were used.

10.7.10 Spill kits must be made available on-site for the clean-up of spills. Y Noted and complied with.

10.7.11 An integrated waste management approach must be implemented

that is based on waste minimisation and must incorporate reduction,

recycling, re-use and disposal where appropriate. Any solid waste shall

be disposed of at a landfill licensed in terms of section 20(b) of the

National Environment Management Waste Act, 2008 (Act No. 59 of

2008).

Y

Evidence of licensed landfill was provided. Wood, scrap metal and oil

were recycled where applicable.

10.7.12 Temporary ablution facilities must be provided for staff at all times during

the construction phase. The ablutions must be cleaned regularly with

associated waste being disposed of at a registered/permitted waste site

and must be removed from the site when the construction phase is

completed.

Y


10.8 Excavation and blasting activities

10.8.1 Underground cables and internal access roads must be aligned as

much as possible along existing infrastructure to limit damage to

vegetation and watercourses.

Y Cables are above ground.

10.8.2 Foundations and trenches must be backfilled with originally excavated

materials as much as possible. Excess excavation materials must be

disposed of only in approved areas or if suitable stockpiled for use in

reclamation activities.

Y All spoil was used as fill material

10.8.3 Borrow materials must be obtained only from authorized permitted sites. Y Mining permits and DMR's acknowledgement for renewal was

received for two suppliers: a Borrow pit and De Aar Stone Crushers.

10.8.4 Anti-erosion measures such as silt fences must be installed in disturbed

areas.

Y Only attenuation structures exist inside drainage channels which are

enough at this stage.

10.9 Air emissions

16

10.9.1 Dust abatement techniques must be used before and during surface

clearing, excavation, or blasting activities.

Y Covered blasting was not feasible. Periodic watering of roads was

done which suppressed dust.

10.9.2 Appropriate dust suppression techniques must be implemented on all

exposed surfaces during periods of high wind. Such measures may

include we suppression, chemical stabilisation, the use of a wind fence,

covering surfaces with straw chippings and re-vegetation of open areas.

Y

Dust suppression undertaken.

10.10 Historical/cultural/ paleontological resources

10.10.1 If there are any changes to the layout of the turbines, then additional

survey work will be required in order to ensure that no sites are directly

impacted and/or to identify the need for an excavation permit.


10.10.2 Should any graves be found, all construction activities must be

suspended, and an archaeologist be contacted immediately. The

discovered graves must be cordoned off.

Y No graves were found.

10.11 Stormwater management

10.11.1 A comprehensive stormwater management plan must be developed

for the site to ensure compliance with applicable regulations and to

prevent off-site migration of contaminated storm water or increased soil

erosion. The comprehensive stormwater management plan should form

part of the EMP.

Y Stormwater management plan in appendix 14 of EMPr.

10.11.2 Construction must include appropriate design measures that allow

surface and subsurface movement of water along drainage lines so as

not to impede natural surface and subsurface flows. Drainage measures

must promote the dissipation of stormwater run-off.


10.12 Turbines position

10.12.1 Erection of wind turbines in areas classified as high sensitivity areas is

prohibited.


10.12.2 Turbines must be positioned in such a way that they are at least 500m

away from residents or farm buildings.


10.12.3 Turbines must be positioned in such a way that shadow flicker does not

affect any farm buildings.


10.12.4 The applicant must ensure that the placement of turbines on ridges is

avoided.


10.12.5 Wind turbines and its associated laydown areas and access roads which

could potentially impact on sensitive areas, must be shifted in order to

avoid these areas of high sensitivity.


10.13 Overhead power line substation

10.13.1 The 132kV power line corridor may only be constructed at the following

co-ordinates:

Starting points 30°4337.37"S 23°54'32.16°E

Mid Points

30*43*25.15-S 23°55'35.62*E

30°43'25.00'S 230572.23E

NA

This condition refers to an older version/ alternative of the 132kV line

which was not constructed. The current 132kV line has a separate EA

and EMP where compliance was evaluated.

17

End Points 30°42'25.8923°58'50.23"

10.13.2 A walk-through survey of the final survey power line corridor must be

undertaken by botanical specialist, an ornithologist and a heritage

specialist to identify areas where mitigation may be required. The result

of this walkthrough must be communicated to the Northern Cape

Heritage Authorities.

NA

This condition refers to an older version/ alternative of the 132kV line



10.13.3 All sections of the proposed power line passing over, or in close proximity

of grasslands, rivers, wetlands, and dams, especially the section of the

132kV power line located adjacent to the proposed substation site(point

1228 on Map D100-01), must be marked with suitable bird flight diverters

in order to deter large birds from colliding with the powerline. Additional

areas of high sensitivity along the preferred alignment must be identified

by an avifaunal specialist for the fitment of anti-collision devices

according to Eskom Transmission Guidelines.

NA This condition refers to an older version/ alternative of the 132kV line



10.13.4 The substation site must be located at 30°43’.37” S and 23°54’32” E, and

the proposed control building right next to it.


11 General

11.1 A copy of this authorisation must be kept at the property where the

activity will be undertaken. The authorisation must be produced to any

authorised official of the Department who requests to see it and must be

made available for inspection by any employee or agent of the holder

of the authorisation new works or undertakes work at the property.


11.2 Where any of the applicant’s contact details change, Including the

name of the responsible person where the applicant is a juristic person,

the physical or postal address and/or telephonic details, the applicant

must notify the Department as soon as the new details become known

to the applicant


11.3 The holder of the authorisations must notify the Department, in writing

and within 48 (forty-eight) hours, If any condition of this authorisation

cannot be or is not adhered to. Any notification in terms of this condition

must be accompanied by reasons for the non-compliance. Non-

compliance with a condition of this authorisation may result in criminal

prosecution or other actions provided for in the National Environmental

Management Act, 1998 and the regulations.


11.4 National government, provincial government, local authorities and

committees appointed in terms of the conditions of this authorisation or

any other public authority shall not be held responsible for any damages

or losses suffered by the applicant or his successor in the title in any

instance where construction or operation subsequent to construction be

temporarily stopped for reasons of non-compliance by the applicant

with the conditions of authorisation as set out in this document or any

other subsequent document emanating from these conditions of

authorisation.


18

EA Transmission Line

Scope of Authorisation

1

The preferred power line Route Alternative A with the abovementioned

co-ordinates as indicated in the Application for Amendment of the

Environmental Authorisation (date of application 2015), is hereby

authorised.


2

Authorisation of the activity is subject to the conditions contained in this

environmental authorisation, which form part of the environmental

authorisation and are binding on the holder of the authorisation.


3

The holder of the amended environmental authorisation is responsible

for ensuring compliance with the conditions contained in this

environmental authorisation. This includes any person acting on the

holder's behalf, including but not limited to, an agent, servant,

contractor, sub-contractor, employee, consultant or person rendering a

service to the holder of the authorisation.


of the EA were met. Obligations towards the EA were included in the

contracts issued to the various sub-contractors/ service providers " –

confirmed in the construction closure report.

4 The activities authorised must only be carried out at the property as

described above.


5

Any changes to. or deviations from. the project description set out in this

environmental authorisation must be approved, in writing, by the

Department before such changes or deviations may be affected. In

assessing whether to grant such approval or not, the Department may

request such information as it deems necessary to evaluate the

significance and impacts of such changes or deviations and it may be

necessary for the holder of the authorisation to apply for further

environmental authorisation in terms of the regulations.

Y Although the "project description" did not change, some design

changes occurred within the allowable corridors

6

The holder of an environmental authorisation must apply for an

amendment of the environmental authorisation with the competent

authority for any alienation, transfer or change of ownership rights in the

property on which the activity is to take place.

Y Proof of ownership transfer were provided.

7

This activity must commence within a period of three (3) years from the

date of issue of this environmental authorisation. If commencement of

the activity does not occur within that period, the authorisation lapses

and a new application for environmental authorisation must be made

in order for the activity to be undertaken.


8 Commencement with one activity listed in terms of this environmental

authorisation constitutes commencement of all authorised activities.


9

The holder of an environmental authorisation must notify the competent

authority of any alienation, transfer and change of ownership rights in

the property on which the activity is to take place.

Y The ownership of the EA was transferred to Eskom in May 2017

Notification of authorisation and right to appeal

10

The holder of the amended environmental authorisation must notify

every registered interested and affected party, in writing and within 14

(fourteen) calendar days of the date of this amended environmental

authorisation, of the decision to authorise the activity.

Y

Records were provided which serves as evidence.

19

11.1 The notification referred to must specify the date on which the

amended environmental authorisation was issued;

Y Records were provided which serves as evidence.

11.2 inform the interested and affected party of the appeal procedure

provided for in the National Appeal Regulations, 2014;


11.3 advise the interested and affected party that a copy of the amended

environmental authorisation will be furnished on request; and


11.4 give the reasons of the competent authority for the decision. Y Records were provided which serves as evidence.

12.1 The holder of the amended environmental authorisation must publish a

notice- 12.1. informing interested and affected parties of the decision;


12.2 informing interested and affected parties where the decision can be

accessed; and


12.3

drawing the attention of interested and affected parties to the fact that

an appeal may be lodged against this decision in terms of the National

Appeal Regulations, 2014.

Y


Commencement of the activity

13 The authorised activity shall not commence within twenty (20) days of

the date of signature of the amended environmental authorisation.


Management of the activity

14

The Environmental Management Programme (EMPr) submitted as part

of the Application for EA is hereby approved. This EMPr must be

implemented and adhered to.


Monitoring

15

The holder of the authorisation must appoint an experienced

independent Environmental Control Officer (ECO) for the construction

phase of the development that will have the responsibility to ensure that

the mitigation/rehabilitation measures and recommendations referred

to in this environmental authorisation are implemented and to ensure

compliance with the provisions of the approved EMPr.


15.1. The ECO must be appointed before commencement of any authorised

activities.


15.2. Once appointed, the name and contact details of the ECO must be

submitted to the Director: Compliance Monitoring of the Department

Y Evidence of notification to the Department including CV's and

change in ECO were provided.

15.3. The ECO must keep record of all activities on site, problems identified,

transgressions noted, and a task schedule of tasks undertaken by the

ECO.


provided

15.4. The ECO must remain employed until all rehabilitation measures, as


completed and the site is ready for


Recording and reporting to the Department

16

All documentation e.g. audit/monitoring/compliance reports and

notifications, required to be submitted to the Department in terms of this

authorisation, must be submitted to the Director: Compliance

Monitoring at the Department.


20

17

The holder of the authorisation must submit an environmental audit

report to the Department within 30 days of completion of the

construction phase (i.e. within 30 days of site handover) and within 30

days of completion of rehabilitation activities.


18

The environmental audit report must indicate the date of the audit, the

name of the auditor and the outcome of the audit in terms of

compliance with the environmental authorisation conditions as well as

the requirements of the EMPr.


19

Records relating to monitoring and auditing must be kept on site and




Notification to authorities

20

Fourteen (14) days written notice must be given to the Department that



which it is anticipated that the activity will commence, as well as a

reference number. This notification period may coincide with the notice

of intent to appeal period.


Operation of the activity

21 Fourteen (14) days written notice must be given to the Department that


NA A letter was sent to Eskom highlighting this condition, since the

ownership of the EA was transferred to Eskom in May, and

operational phase commenced in July 2017.

Site Closure and Decommissioning

22 and 23

Should the activity ever cease or become redundant, the applicant

shall undertake the required actions as prescribed by legislation at the

time and comply with all relevant legal requirements administered by

any relevant and competent authority at that time.

NA Noted.

Specific Conditions

24

A permit from the Department of Water and Sanitation must be

obtained prior to any construction that is to be undertaken within 32

meters of all sensitive areas (rivers, wetlands and riparian zones).

NA DWS confirmed withdrawal of WULA (Feb 2015) for the 132kV

transmission line.

25 Concrete mixing on site during construction (if mixed on the ground)

must be conducted on plastic sheeting.


26

One (1) chemical toilet must be provided for every 15 construction

workers on site and must be located 1OOm away from the river/stream

systems. The toilets must be in working condition and serviced once a

week.


27 Anti-collision devices such as bird flappers must be installed where the

power line crosses avifauna! corridors, pans and drainage lines.

NA No BFD's were recommended by specialist

28

The applicant is instructed to inform the Northern Cape Department of

Environmental Affairs and Nature Conservation and this Department,

should the removal of protected species, medicinal plants and "data

deficient" plant species be required.

NA

Duly noted by the Licence Holder. No botanical issues were identified

during the detailed survey of the proposed project area

21

29

A final walk-through of the alignment must be conducted by a

biodiversity and a freshwater specialist to assist in the placement of the

pylons.


30 Existing access roads must be utilised as far as possible to protect

biodiversity sensitive areas.


31

An integrated waste management approach must be implemented

that is based on waste minimisation and must incorporate reduction,

recycling, re-use and disposal.


32

Any solid waste must be disposed of at a landfill licensed in terms of

section 20 (b) of the National Environment Management Waste Act,

2008 (Act No.59 of 2008).


General

33

A copy of this amended environmental authorisation and the approved

EMPr must be kept at the property where the activity/ will be

undertaken. The amended environmental authorisation and approved

EMPr must be produced to any authorised official of the Department

who requests to see it and must be made available for inspection by any

employee or agent of the holder of the amended environmental

authorisation who works or undertakes work at the property.


34

The holder of the amended environmental authorisation must notify

both the Director: Strategic Infrastructure Developments and the

Director: Compliance Monitoring at the Department, in writing and

within 48 (forty-eight) hours, if any condition of this amended

environmental authorisation cannot be or is not adhered to. Any

notification in terms of this condition must be accompanied by reasons

for the non-compliance.


35

National government, provincial government, local authorities or

committees appointed in terms of the conditions of this amended

environmental authorisation or any other public authority shall not be

held responsible for any damages or losses suffered by the applicant or

his successor in title in any instance where construction or operation

subsequent to construction be temporarily or permanently stopped for

reasons of non-compliance by the applicant with the conditions of

amended environmental authorisation as set out in this document or any

other subsequent document emanating from these conditions of

amended environmental authorisation.


DENC EA

Scope of authorisation:

1.

Authorisation of the activity is subject to the conditions contained in this

authorisation, which conditions form part of the environmental

authorisation and are binding on the holder of the authorisation.

Y Noted

2. The holder of the authorisation shall be responsible for ensuring

compliance with the conditions by any person acting on his or her


of the EA were met.

22

behalf, including but not limited to, an agent, sub-contractor, employee

or person rendering a service to the holder of the authorisation.

Obligations towards the EA were included in the contracts issued to

the various sub-contractors/ service providers " – confirmed in the

construction closure report.

3. The activity(s) which is authorised may only be carried out at the

property indicated above.


4.

Any changes to, or deviations from, the project description set out in this

authorisation must be approved, in writing, by the Department before

such changes or deviations may be affected. In assessing whether to

grant such approval or not, the Department may request such

information as it deems necessary to evaluate the significance and

impacts of such changes or deviations and it may be necessary for the

holder of the authorisation to apply for further authorisation in terms of

the regulations.


5.

This authorisation does not negate the holder of the authorisation's

responsibility to comply with any other statutory requirements that may

be applicable to the undertaking of the activity.


General conditions:

6.

A copy of this authorisation must be kept at the property where the

activity will be undertaken. The authorisation must be produced to any

authorised official of the Department who requests to see it and must be

made available for inspection by any employee or agent of the holder

of the authorisation who works or undertakes work at the property.


7.

Where any of the applicant's contact details change, including the

name of the responsible person, the physical or postal address and/ or

telephonic details, the applicant must notify the Department as soon as

the new details become known to the applicant.


8.

The holder of the authorisation must notify the Department, in writing

and within 24 (TWENTY-FOUR) hours, if condition 16 (sixteen) of this

authorisation cannot be or is not adhered to. In all other cases, the

holder of the authorisation must notify the Department, in writing, within

7 (SEVEN) days if a condition of this authorisation is not adhered to. Any

notification in terms of this condition must be accompanied by reasons

for the noncompliance.


9.

Non-compliance with a condition of this authorisation may result in

criminal prosecution or other actions provided for in the National

Environmental Management Act, 1998 and the regulations.


10.

This authorization is subject to the approval by the relevant local

authorities i.e. in terms of any relevant legislation administered by those

local authorities.


11.

The activity may not commence without the necessary

permits/licenses/approvals and/or service agreements, where it is

relevant, from or with the relevant regulatory authorities whether

national, provincial or local (these include but are not limited to National

Department of Water Affairs, Department of Environmental Affairs ,

National Department of Agriculture, Forestry and Fisheries, Department


23

of Cooperative Governance and Human Settlement, Department of

Mineral Resources, Department of Energy, Department of Roads &

Public Works, Department of Transport, Department Arts & Culture,

Department of Sports and Recreation, South African Heritage Resources

Agency, South African Civil Aviation Authority).

12.

The activity, including site preparation, may not commence before the

thirty (30) day appeal period expires or until such time as the

Department has considered any appeals that have been lodged.


A One week's written notice must be given to the Administration clerk

(Impact Management Unit) before commencement with the activity.


B Such notice shall make clear reference to the site location details and

the reference number given above.


C

The said notice must also include proof of compliance with the following

conditions described herein:

Conditions: 11 and 23.


13.

The applicable conditions of this authorization must form part of all

contractors' and sub-contractors' conditions of contract. A

performance-based requirement with regard to environmental impact

management must be included in all contracts related to any aspect of

this authorization.


14. The applicant must carry out regular environmental audits to establish

compliance with the conditions of this authorization and contracts.

Y Weekly environmental reports were provided.

15.

Any complaints regarding the said development must be brought to the

attention of the Department within 24 hours after receiving the

complaint. A complaints register must be kept up to date for inspection

by the Department.


provided.

16.

Records relating to the compliance/non-compliance with the

conditions of the authorization and contracts must be kept in good

order. Such records must be made available to the Department within

7 (seven) days of receipt of a written request by the Department for such

records.


17.

0fficials in the employ of the Department shall be given access to the

property as described above (see detailed description of the activity)

for the purposes of assessing and/or monitoring compliance with the

conditions contained in this Environmental Authorization. Where the

activity is located on a third party's property the applicant shall be

responsible to arrange access for departmental officials.

Y Noted.

18.

This Department may add to, change and/or amend any of the

conditions in this authorization if, in the opinion of the Department, the

addition, change of amendment is environmentally justified. In event

that such impacts exceed its significance as predicted in the

independent consultant's environmental scoping report and supporting

documentation, the authorization may be withdrawn after proper

procedures were followed.

Y Noted.

24

19.

In the event of any dispute concerning the significance of a particular

impact, the opinion of this department in respect of its significance will

prevail.

Y Noted.

20.

This Department and any national department, provincial department,

local authorities or committees appointed in terms of the conditions of

this Environmental Authorization or any other public authority or

organization shall not be held responsible for any damage of losses

suffered by the applicant or his successor in title in any instance where

construction or operation subsequent to construction be temporarily or

permanently stopped for reasons of non-compliance by the applicant

with the conditions of approval as set out in this document or any other

subsequent document emanating from these conditions of approval.

Y Noted.

21. The applicant shall be responsible for all costs necessary to comply with

the above conditions unless otherwise specified.


22.

The applicant must apply the principle of best practicable

environmental option for all technologies used/ implemented during

construction.

Y Noted.

Appeal of authorisation:

23.

The holder of the authorisation must notify every registered interested

and affected party, in writing and within 12 (twelve) calendar days, of

receiving notice of the Department's decision to authorise the activity.


24. The notification referred to condition 23 must Y Noted and complied with.

• specify the date on which the authorisation was issued; Y Noted and complied with.

• inform the interested and affected party of the appeal procedure

provided for in Chapter 7 of the regulations; and


• Advise the interested and affected party that a copy of the

authorisation and reasons for the decision will be furnished on request.


25.

If the applicant should appeal against this Environmental Authorisation,

he/she must inform all interested and affected persons that such an

appeal is being lodged with the MEC and if requested, the

applicant/appellant must provide those persons with reasonable access

to a full copy of the appeal within a reasonable time before expiry of

the thirty day appeal period.

Y Noted.

Monitoring:

26.

The applicant must appoint a suitably experienced Environmental

Control Officer (ECO) for the construction phase of the development

that will have the responsibility to ensure that the mitigation I

rehabilitation measures and recommendations referred to in this

authorisation are implemented.


27. The ECO shall be appointed before commencement of any land

clearing or construction activities.

Y Evidence of appointment was provided.

28.

The ECO shall keep record of all activities on site, problems identified,

transgressions noted, and a task schedule of tasks undertaken by the

ECO.


provided.

25

29.

The ECO shall remain employed until all rehabilitation measures, as


completed and the site is ready for operation.


30.

Records relating to monitoring and auditing must be kept on site and




Recording and Reporting to the Department:

31.

Where any of the applicant's contact details change, including the

name of the responsible person, the physical or postal address and/or

telephonic details, the applicant must notify the Department as soon as

the new details become known to the applicant.


32.

In all other cases, the holder of the authorisation must notify the

Department, in writing, within 7 days if a condition of this authorisation is

not adhered to. Any notification in terms of this condition must be

accompanied by the reason for non-compliance.


33.

Records relating to the compliance/non-compliance with the

conditions of the authorisation and contracts must be kept in good

order. Such records must be made available to the Department within

7 days of receipt of a written request by the Department for such

records.


34.

Any complaints regarding the said development must be brought to the

attention of the Department within 24 hours after receiving the

complaint. A complaints register must be kept up to date for inspection

by the Department.


Commissioning of the activity:

35.

Fourteen (14) days written notice must be given to the Department that



which it is anticipated that the activity will commence.


36. The authorised activity shall not commence within thirty (30) days of the

date of signature of the authorisation.


37.

Should you be notified by the minister of a suspension of the

authorisation pending appeal procedures, you shall not commence

with the activity unless authorised by the minister in writing.


Operation of the activity:

38. Fourteen (14) days written notice must be given to the Department that



39.

Construction activities must be restricted within the normal working

hours, and measures to control level of noise must comply with the

National Noise Control Regulations and SANS10103:2008.

NA This condition was removed via an amendment.

40.

The level of dust in the construction site during the construction phase

must be kept as low as possible at all the times and comply with the dust

regulations promulgated under the Air Quality Act, 2004 (Act 39 of 2004).


26

41.

The construction of access roads must not cause changes to surface

water runoff and proper measures to prevent soil erosion must be

implemented.


42.

All the waste material which will be generated during the construction

phase must be collected and transported by a roadworthy vehicle to a

licenced waste disposal facility.


43. All forms of pollution must be prevented, or where it cannot, should be

minimized or remedied.


44. The appropriate toilets must be supplied for the entire construction

period and must be serviced on regular basis.


45.

In the event of oil spillages and contamination of soil by hazardous

substances that contaminated area must be cleaned up immediately

by removing the contaminated soil and disposing it off into the

designated hazardous skip bin for correct disposal.


46. The clearing of vegetation must be restricted within the development

footprint.


47.

The protected trees such as shepherd's tree (Boscia a!bitrunca) which

occurs in the application site must not be affected by the proposed

development; alternatively the permit for removal of the protected trees

must be applied and granted by the Department of Agriculture Forestry

and Fisheries, prior to the commencement of the proposed activity.


48.

The spreading of alien vegetation must be avoided where possible. In

the event of occurrence of invasive alien vegetation, the removal must

be in accordance with the Conservation of Agricultural Resources Act

(Act 43 of 1983).


49.

The Environmental Management Plan must be amended, if it has

already been amended, it must be properly implemented as per the

Environmental Authorization by Department of Environmental Affairs.


50. All the mitigation measures outlined in the Environmental Management

Plan must be adhered to.


WEF EMPr

Project description

2.1

Final layout Detailed designs have been undertaken as part of the pre-

construction phase. The final layout is included in Appendix 16 together

with the Preliminary Design Report prepared by AECOM. In developing

the final layout, AECOM have taken into consideration the mitigation

measures and buffer zones proposed by the respective specialists as well

as sensitive onsite ecological features (Figure 1).







4. ENVIRONMENTAL SENSITIVITY AND MITIGATORY MEASURES

Table 2: Mitigatory measures to be implemented as proposed by the various specialist consultants

4.1 Archaeology

4.1.1 The access road to the wind turbine location sites on the Kasarmberge

on the Farm Smauspoort must avoid the very important site known as

NA An alternative access route was used to avoid this area. Therefore, no

fencing was erected.

27

zwk95 that contains graves, stone artefacts and portable art. The

affected section of the road must be moved at least 10 – 15 m away

from the archaeological site. The site must also be permanently fenced

off during the proposed upgrading of the road. The fencing must be

undertaken under the supervision of the archaeologist. A gate should

be included that will provide access to the site. The site must not be

disturbed in any way.

4.2 Botany

4.2.1 i. All turbines and the substation must be located at least 30 m from any

mapped highly sensitive areas on site (see Figure 1).

Y Authorised layout plan

4.2.2

ii. If the sensitive habitats on the dolerite hills and flats can be largely

avoided this is the best way to reduce botanical impacts of the

proposed development. This means that all depressions and pan like

areas should be avoided and buffered from any development by

natural vegetation.







4.2.3

iii. An ECO must inspect the site twice weekly throughout the road

construction, cable laying, turbine foundation excavation and blasting,

and during the erection of the turbines.

Y

Monthly/ Weekly reports provided.

4.2.4

iv. Any excavation, including those for cables, must be supervised by the

ECO. No excavation may be left open for more than 1 week, and they

should preferably be closed within 1 day, using the carefully stockpiled

soil that came out of the trench. In the case of turbine footings some

45m3 of soil and rock will presumably be displaced by the concrete, and

this should not be dumped on any undisturbed natural vegetation, but

must rather be set aside within a portion of the turning circle of the trucks

that deliver the components, and must be spread over the foundations

once the turbines are erected, or used as access road fill elsewhere on

the site.

Y

All fill material was used for construction purposes.

4.2.5

v. In order to minimize blasting and excavation impacts in very rocky

areas cable trenches should not be excavated in these areas, and the

cables should instead run above ground or on the surface.

Y

33kV cables are above ground

4.2.6 vi. No dumping or temporary storage of any materials may take place

outside designated and demarcated laydown areas.


4.2.7

vii. An EMP and OEMP should be drawn up, which must outline

management steps for all areas of natural vegetation on the site (refer

to the Open Space Management Plan included in Appendix 13).


4.2.8

viii. Alien vegetation management, included in Appendix 11, must be

undertaken in the powerline servitude and along the edges of all on-site

infrastructure on an annual basis.

Y Evidence of record keeping was provided in Weekly & Biodiversity

update reports

4.3 Avian

4.3.1 Lesser Kestrel and Amur Falcon:

4.3.1.1 Counts must be conducted during the summer months at the De Aar

roosting sites.

Y Records were provided which serves as evidence. In 2016 only Lesser

Kestrels were counted (excluding Amur Falcons). In 2017 both sp. was

counted (only in town).

28

4.3.1.2

Potentially suitable roosting sites in the vicinity of the WEF must be

identified and inspected to establish if the birds are using these sits as

roosting sites.

Y

Pre-construction Phase - Evidence of record keeping was provided

4.3.1.3

Lesser Kestrel and Amur Falcon: Counts must be conducted during the

summer months at the De Aar roosting sites and at any additional

roosting sites that were identified during the pre-construction phase in

the vicinity of the WEF.

Y Records were provided which serves as evidence. In 2016 only Lesser

Kestrels were counted (excluding Amur Falcons). In 2017 both sp. was

counted (only in town).

4.3.1.4

Adaptive management must be implemented for the influx of Lesser

Kestrel linked to locust invasions during the summer season at the WEF

area. Temporary shut-down of turbines at certain times in a day (i.e. two

hours after dawn or two hours prior to sunset) may be required during

periods of high bird traffic.

Y

This has not been required.

4.3.1.5 Counts must be conducted during the summer season at the De Aar

roosting sites and any additional roosting sites in the vicinity of the WEF.

Y Counts were conducted in January 2019 and data collected by an

ornithologist as part of independent monitoring. Weekly to monthly

undertaken.

4.3.2 Verreaux’s Eagle

Pre-construction Phase:

• Initiate an Argos / GPS satellite tracking programme to record the

exact number of eagle pairs, their movements, main hunting areas,

home ranges and use of different habitats, nests and cliffs. The expected

duration of the programme is three years. This satellite tracking

programme commenced in January 2014 with the tagging of one

eagle.

• Implement a 100m set-back from ridges and cliffs to reduce risk to

slope soaring eagles and other soaring species. This has already been

implemented in the final lay-out.

• Implement an 800m no development buffer zone around all VE nests

that have been identified at the WEF. This buffer zone is required for two

reasons (1) to minimize the collision risk to the juvenile bird in the first few

months when it learns to fly properly and (2) to minimize disturbance of

breeding birds. This has already been implemented in the final lay-out

(subject to the next point).

• Where the 800m no development buffer zone cannot be implemented

due to engineering constraints or existing public infrastructure (e.g. nest

numbers VE2 and V3), alternative measures must be implemented (see

Construction Phase and Operational Phase below).

Y

Records and/or reports were provided which serves as evidence, see

Pre-con monitoring reports

Construction Phase:

Continue with the Argos / GPS satellite tracking.

Y This was limited to three years.

Monitor the breeding activity of eagles in the area by assessing the

number of pairs and breeding success (productivity and fledgling rates),

including (if feasible) the identification of individual adult birds.

Y


Nest VE2: This nest is situated on transmission tower, 200m from a public

road. This road will be used during construction. The following mitigation

measures must be implemented within an 800m zone around the nest

for the period April – October (breeding season): (1) a speed limit of

Y


29

60km/h (2) no hooting (3) no parking on the side of the road (4) no

venturing off the road. Under no circumstances should the nest be

approached on foot.

Nest VE3: No construction activity should take place between May

– July and again for a period in October in an 800m zone around nest

number VE3.

Y


In June/July 2015, an inspection must be conducted by the avifaunal

specialist to establish if nest VE3 is active. If nest VE3 is active, a

monitoring programme must be initiated between November 2015 and

February 2016 to record the flight patterns of the fledgling. The aim of

this programme will be to assess if any of the turbines could potentially

pose a risk

Y Monitoring did take place until March 2019, when the tracker came

loose and fell off the bird.

This mitigation measure will be amended stating that a monitoring

programme should be initiated for an adult bird. Currently, the

monitoring programme is postponed until further notice by the

avifaunal specialist which will roll-over to O&M phase

Operational Phase:

• Continue with the Argos / GPS satellite tracking.

• If need be, implement adaptive management for the Verreaux’s

Eagle based on the satellite tracking monitoring results.

• If results of the initial monitoring at nest VE3 indicate any potential risky

turbines, further monitoring should be implemented at these turbines.

Based on the results of this monitoring, adaptive management should

be implemented (if need be) to effectively reduce any risk to the

fledgling eagle.

• Monitor the breeding activity of eagles in the area by assessing the

number of pairs and breeding success (productivity and fledgling rates),

including (if feasible) the identification of individual adult birds.

Y GPS Satellite tracking continued during operations until March 2019

(when the tracker fell of the eagle). The bird specialist has confirmed

that tracking do not have to continue indefinitely and a new eagle

do not have to be tagged.

No adaptive management based on the satellite tracking monitoring

results was recommended by the specialist who did the tracking.

The results of the additional monitoring at VEs showed that no

additional mitigation was recommend at the time to reduce the risk

to the fledgling eagle.

Operational monitoring did not commence once the first turbine


However, a service provider has since been appointed and

monitoring began in December 2017.

Monitoring of breeding activity at the nest sites is part of the ongoing

operational monitoring survey efforts.

4.4 General recommendations

Use tubular rather than lattice-design turbine towers to deter birds from

perching.


Prior to the electrification of the wind farm, an on-site “walkthrough”

should be conducted by the ornithological consultant to identify the

sections of power line between the turbines which require marking with

Bird Flight Diverters as an anti-collision measure.

Y Although a "walk-through" was conducted in Feb 2017, effective

installation of mitigation measures was not yet complete at the time

the lines were energised in August 2017. This is however now

completed.

During the operational phase, regular surveys of the intra-turbine power

lines will be conducted as part of the post-construction monitoring

programme to assess if there are collision mortalities, and any additional

spans identified as high risk should be marked with Bird Flight Diverters.

Y Monitoring began in December 2017.

30

In addition to that, the 132kV grid connection should also be inspected

at least once a quarter to establish if there is any significant collision

mortality.

NA To implement during the Operational Phase however, a transfer in

ownership occurred making Eskom responsible for this particular

condition.

The avifaunal specialist should communicate on a constant basis with

the design engineers to ensure that the proposed pole design for the

intra-turbine power lines will not pose an electrocution risk to large

raptors. The final pole design must be approved by the avifaunal

specialist.

Y The specialist commented on the design, additional mitigation

measures were also being investigated since several bird

electrocutions occurred. Bird perches have been installed.

The fitting of Bird Flight Diverters on the 33 kV power line which crosses

the narrow kloof between Smouspoort and Swartkoppies is

recommended.


Exterior lighting at night should be reduced to a minimum. Where

possible, the following measures must be implemented:

o Use long-wavelength (red or orange) or energy-saving lights.

o Use minimum lumen or wattage in fixtures. Use directional fittings,

down-lights and shielded fixtures.

o Install sealed light fittings so that insects cannot reach the light source.

o Control lighting with timers so that non-essential lights do not stay on

all night.

o Screen interior lighting with blinds, curtains, etc., to prevent exterior

light pollution.

o Limit mounting heights of lighting fixtures or use footlights or bollard-

level lights.

o Warning lights should be flashing, not constant, to avoid attraction of

animals. o Use motion-detectors on security lighting.


Reduce the noise associated with construction and maintenance

activities as far as possible. If blasting is necessary, employ techniques

that minimise noise, vibration and dust.

Y Noted and complied with. Activities occurred in rural areas with no

complaints received from the adjacent landowners. Blasting

notifications were also sent out.

Keep construction and maintenance periods as short as possible. Y Noted and complied with.

• Minimise the size of the construction footprint. Y Noted and complied with.

During construction, demarcate the footprint area of each construction

site and do not allow construction activities to spread beyond the

demarcated area.


Rehabilitate all disturbed areas, including access roads not required for

the post decommissioning functioning of the WEF, immediately after the

completion of construction.

Y Noted and complied with. Areas ripped and hydroseeded.

4.5 Social

Employment creation

During the construction phase, local contractors and service providers

need to be utilised as far as possible.


Increased Pressure on Infrastructure

The increase in labourers to the local area might put a strain on the

current housing conditions in the local town but can be managed via


31

proper communication with the local and regional communities in order

to prevent possible unrest in the towns.

Safety and Security

Potentially harmful areas on the construction site as well as en route to

the proposed wind farm site, should be demarcated and managed in

order to prevent any accidents.

Y Applicable road signs used.

Noise, Pollution and Loss of Tranquility

Only the required erection procedures should be done on site.


Loss of Visual Value

The turbine masts, rotors and nacelle should all be finished in a

nonreflective matte white paint without decals or logos. There must be

no visual clutter visible on the site.


The main visual aim of a layout should be to convey a sense of clarity,

as there is concern that the various groups of turbines will bring a degree

of discord into the visual landscape.


4.6 Visual

Location of construction access:

The contract time must be kept to the minimum, the road junctions

needs to have good sightlines, traffic control measures needs to be in

place as well as good signage.


Dust generation, movement of machinery and vehicles: Access roads to

be kept clean and storage of materials to be screened. Storage of

builder’s rubble to be controlled.


Visibility of site offices / construction camps:

Site offices should be limited to single storey and they should be sited

carefully using topography to screen from the wider landscape.


Fires and litter:

All site operatives should receive training in awareness of fires and litter.

In particular, no fires will be allowed. Littering is regarded as a serious

offence and no contaminants will be allowed to enter the environment

by any means.


Infrastructure

New roads into the site

The existing roads will be upgraded and should be gravel roads if

appropriate to the needs of construction traffic. Required is a 4 m wide

road with 15 m turning circles.


Roadways should be low-key in appearance; gravel is the most

appropriate surface material as there are many gravel roads locally.

Roadways should fit onto the land as closely as possible with the

minimum of cut and fill. Too much disturbance will result in wide scarring

of the landscape.


Concrete footings

Following construction of the foundation, installation of the turbine, and

removal of spoil and rock, only local scarring around the foundation will

remain. If surplus rock is visible, it should be removed from the site.


32

Buildings and other infrastructure

The largest would be the sub-station and the control building. It is

proposed that these are placed where they are least visible to the

greatest numbers of people, be finished in materials and colours which

fit in with the landscape, and in places where topography can offer

shielding.


Transmission towers, whether pylons or monopoles

It is noted that the proponent intends to underground certain lengths of

cable where local geology renders this feasible. Ideally the power lines

should be buried as they introduce horizontal lines above ground which

conflict with the strong vertical element of the turbine structures,

affecting their visual clarity.

NA Underground cabling was not feasible.

Lighting at night

The Masts will carry aircraft warning lights; there are no mitigation

measures to propose, as this is a requirement of the South African Civil

Aviation Authority, however it may be possible to consider shields to limit

downward light.

Y Technical specifications provided.

The Psychological Effect of the turbines in the Landscape

By use of certain materials and finishes

• The use of plain galvanised finish seems to imply to most receptors that

this is a technically primitive installation

• It is generally preferable to use white as a finishing colour

• Blades, nacelle and tower should all be the same colour.


4.7 Heritage

That should work at Maanhaarberg proceed the mitigation measures,

relating to the construction phase, the turbine finishes and the

involvement with the public are undertaken.


That use of pylons rather than monopoles which are not used locally. Y Noted and complied with.

Turbine masts, rotors and nacelle will all be finished in a nonreflective

matte white paint without decals or logos.


4.8 Bats

Construction phase

(i) Lighting should be kept to a minimum and passive motion sensors

installed on all lights, unless safety or security reasons renders this

impractical.

(ii) Earth works and other construction activities must be kept to a

minimum and keep to the designated roads, storage and laydown

areas.

(iii) Personnel must be informed and trained on the potential effects of

human disturbances on bat roosts and roost disturbances prohibited.

(iv) The turbine layout as it stands on 21 May 2015 is acceptable.


Implement an Operational Phase Bat Monitoring programme (included

in Appendix 8). Note that should any conflict be perceived between the

recommendations pertaining to bats contained within this table, and

Y Operational monitoring did not commence once the first turbine


However, a service provider has been appointed for the operational

phase. The actual monitoring began in December 2017.

33

the requirements of Appendix 8, the recommendations contained within

Table 2 of the EMP shall prevail.

4.9 Traffic

It is recommended that instead of using the proposed access off the

R348, access to the Swartkoppies section of the development should be

pursued off the Smauspoort Road in the vicinity of the De Aar Dumping

Site


It is recommended that Smauspoort Road should be maintained on a

regular basis. The road should be graded and sprayed with water

regularly to improve the road surface and restrict dust pollution and

gravel loss.

Y Although graded, watering was not feasible.

After construction of the development is completed, the Smauspoort

Road must be repaired where necessary and restored to satisfactory

condition (refer to Traffic Impact Assessment Addendum in Appendix 6).


4.10 Palaeontological

i. Given the limited effective palaeontological potential of rocks in the

region, the comparatively small footprint of the proposed wind farm and

the shallow excavations envisaged here, no further palaeontological

mitigation is recommended for this development.


ii. Should substantial fossil remains be exposed during construction;

however, the ECO should alert SAHRA so that appropriate action (e.g.

recording, sampling or collection) can be taken by a professional

palaeontologist.

Y No remains were found.

6. CONSTRUCTION PHASE

6.2

ECO Visits - the ECO should visit the site twice weekly for the duration of

the construction period. The ECO shall remain employed until all

rehabilitation measures, as required for implementation due to

construction damage, are completed and the site is ready for

operation. On the performance of the contractor, the frequency of the

site visits may be altered. In the event of repeated and/or serious non-

compliance with the EMP, the ECO may recommend the imposition of

a financial penalty on the Contractor, to the Engineer. The magnitude

of such penalty shall be determined by the guidelines provided in

Section 12 of the EMP.


6.3

Contractors Environmental Officer - The Contractor shall appoint an

Environmental Officer (EO) who shall have some experience and

training in Environmental Compliance Monitoring, and will be

responsible for undertaking a daily site inspection to monitor compliance

with this Specification, and for liaising with the ECO in respect of any

environmental incidents or not compliances observed. The EO shall be

permanently on-site, on a (minimum) half day basis. The Contractor shall

submit the name of the Contractor’s Environmental Officer to the

Engineer for his approval seven days prior to the date of the

environmental awareness training course.


34

6.4

Appropriate Machinery - The contractor shall at all times carefully

consider what machinery is appropriate to the task while minimising the

extent of environmental damage. Areas where machinery and vehicles

are stored and used must be bunded to prevent pollutants such as fuel

and oil from spilling onto the soil.


6.5

Soil erosion and sedimentation control - The Contractor shall, as an

ongoing

exercise, implement erosion and sedimentation control measures to the

satisfaction of the ECO and Engineer (Stormwater and Erosion

Management Plan included in Appendix 12).


Any runnels or erosion channels developed during the construction or

maintenance period shall be backfilled and compacted and the areas

restored to a proper condition.


Traffic and movement over stabilised areas shall be restricted and

controlled, and damage to stabilised areas shall be repaired and

maintained to the satisfaction of the ECO. In areas where construction

activities have been completed and where no further disturbance

would take place, rehabilitation and revegetation should commence

as soon as possible (refer to Vegetation Rehabilitation Plan contained

within Appendix 10).


6.6

Fires – No fires may be lit on site (including fires for cooking or heating).

Any fires, which occur, shall be reported to the Engineer immediately.

Smoking shall not be permitted in those areas where it is a fire hazard.

Such areas shall include the workshop and fuel storage areas and any

areas where the vegetation or other material is such as to make liable

the rapid spread of an initial flame. In terms of the Atmospheric Pollution

Prevention Act, burning is not permitted as a disposal method.

Y Other than explosives associated waste, no fires were lit on site.

The Contractor shall appoint a Fire Officer who shall be responsible for

ensuring immediate and appropriate actions in the event of a fire and

shall ensure that employees are aware of the procedure to be followed.


The Contractor shall ensure that there is adequate fire-fighting

equipment available on Site at all times.


Contractor should provide fire-fighting training to selected construction

staff.


6.7

Health and Safety – All people working on site are responsible for their

own safety and those of others on site. Contractors and Engineers must

comply with all the Regulations as including the Occupational Health

and Safety Act, 1993 (Act No. 85 of 1993, as amended). A

comprehensive first aid kit and suitably trained personnel should be

available on site at all times.


6.8

Traffic disruption – traffic and personnel using the road that provides

access to the site shall not be disrupted and standard traffic

management procedures will be implemented in these areas where

necessary to maintain access at all times.


35

Signage and safety measures during the construction of the access

roads shall comply with the guidelines as set out in the latest issue of the

SADC Road Traffic Signs Manual. Standard “construction ahead”

warning signs should be placed on all relevant roads in the area. Ensure

access roads are kept clean and storage of materials is screened and

that that all road junctions have good sightlines.


For further requirements kindly refer to the Road Maintenance Plan

(Appendix 6).


6.9

Fauna – Catching of wild animals (including reptiles, amphibians, birds

and invertebrates, etc.) by any means, including setting of snares,

poisoning, shooting and trapping is illegal. All incidents of harm to any

animal must be reported to the ECO.


6.10

Archaeology and Palaeontology – Should anything of an

archaeological nature be found on site by the Contractor (or any other

party), e.g. stone hand tools, remnants of old structures not previously

visible, old ceramic shards etc, work is to be stopped in the area

immediately, and the ECO / Engineer notified, as well as the relevant

Heritage Authorities (see contact details below). Failure to notify the

ECO of a find will result in a penalty.

Y Noted and complied with. No remains were found.

6.11

6.11 Excavation and Trenching - During excavation and trenching

activities, care is to be taken to ensure that the stockpiling of top

material is kept separate from sub-soils. Top material saved is to be

replaced as top material and is to serve as the final layer when back-

filling.


In the event of material removed during trenching being excessive after

backfilling or being unsuitable as overburden, the excess material must

be removed from the construction site to a site agreed upon by the

Engineer.

Y Noted and complied with. All fill material was used for construction

purposes.

Dewatering systems shall make use of filtered extraction points to

prevent silt uptake and extracted water shall be released in such a

manner as to avoid erosion on the site and prevent siltation or pollution

of any stormwater system.


6.12

6.12 Blasting - Any blasting is to be executed by a suitably qualified

person. Controlled blasting techniques shall be employed to minimise

dust and fly rock during blasting.

Y Noted and complied with. Although executed by a suitably qualified

person (African Drill & Blast), Controlled blasting techniques were not

feasible.

Prior to blasting the Contractor shall notify the relevant occupants/

owners of surrounding land and address any concerns.


6.13

Protection of Natural Vegetation - Clearing of natural vegetation shall

be kept to a minimum. The removal, damage and disturbance of

natural vegetation without the written approval of the ECO are

prohibited.


The use of herbicides is prohibited unless approved by the ECO. Y Noted and complied with.

6.14 Protection of fauna and avifauna – The Contractor shall ensure that no

hunting, trapping, shooting, poisoning or otherwise disturbance of any


36

fauna takes place. The feeding of any wild animals is prohibited. The use

of pesticides is prohibited unless approved by the ECO.

Prior to the electrification of the wind farm, an on-site “walk-through”

should be conducted by the ornithological consultant to identify the

sections of power line between the turbines which require marking with

Bird Flight Diverters as an anti-collision measure.


A. Specific construction phase requirements in respect of Bats:

Lighting should be kept to a minimum and passive motion sensor

installed on all lights, unless safety or security reasons renders this

impractical.


Earth works and other construction activities must be kept to a minimum

and keep to the designated roads, storage and laydown areas.


Personnel must be informed and trained on the potential effects of

human disturbances on bat roosts and roost disturbances prohibited.


B. Specific construction phase requirements in respect of Avifauna

6.15

6.15 Community relations - Maintain a register that shall contain details

of the measures taken to resolve complaints and the details of the

communication of these measures to the person who raised the

complaint.


*DENC EA 34 Any complaints must be brought to the attention of the Dept within 24h

and a complaints register kept up to date.


6.16

Drinking Water - The Contractor shall ensure that drinking water is

available for all staff on site. If no potable water source is available on

site, then the Contractor shall import drinking water to the site.


6.17

Eating Areas - If employees are to eat elsewhere on site other than in the

campsite, the Contractor shall designate restricted places for eating

within the specified working areas, in consultation with the ECO. The

Contractor shall provide adequate refuse bins with lids in all these

places.


6.18

Working Hours – The hours of operation shall be restricted to those

stipulated by the Employer and/or the local authority. All construction

operations should only occur during daylight hours if possible.

NA Dept was notified and approved the night work.

DENC authorisation: Condition 39 has been amended to allow

working at night, and DEA amendment, which states that condition

10.5.7 has been removed.

6.19

Dust Control - The level of dust in the construction site during the

construction phase must be kept as low as possible at all the times and

comply with the dust regulations promulgated under the Air Quality Act,

2004 (Act 39 of 2004).

Y/X Ambient quantities of particulate matter were not measured in

accordance with Air Quality Act, 2004 (Act 39 of 2004), however,

adequate dust suppression was implemented such as speed limits,

dust suppression etc. on site.

7. MATERIALS MANAGEMENT

7.1

All potentially hazardous substances should be stored in a defined area

(hazardous substances store), which is covered, has secondary

containment and has restricted access, and complies with the

requirements of SABS 089:1999 Part 1. This area should be constructed in

such a manner that any spillages can be contained within this area and

to prevent entry into the underlying subsoil and groundwater.

Y/X Evidence observed on site, but not for substances that were stored

for O&M (multiple drums of grease, oil etc.).

37

Depending on the types of materials stored on site, suitable product

recovery materials should be readily available.


All fuel is to be stored within a demarcated, bunded area in the

Contractor’s Camp. No refuelling of vehicles or machinery is to take

place outside of this demarcated area unless authorised by the

Engineer.


Areas for storage of fuels and other flammable materials shall comply

with standard fire safety regulations and may require the approval of the

Municipal Fire Prevention Officer.


The Contractor shall ensure that there is adequate fire-fighting

equipment at the fuel stores.


The Contractor shall ensure that there is always a supply of appropriate

material readily available to absorb/breakdown and where possible be

designed to encapsulate minor hydrocarbon spillage.


7.2

The contractor shall keep Material Safety Data Sheets on site for all

potentially hazardous materials used. Suitably trained personnel shall be

available on the site during working hours so that in the event of human

exposure to any hazardous materials that the correct first aid actions are

taken.


7.3

All material used by the contractor during the construction phase shall

be managed in such a way that it does not cause pollution, or that

minimises pollution. All building materials should be stored away and the

areas bunded appropriately such that there will be no runoff from these

areas. All building materials must be removed after construction.


7.4

Concrete works – cement powder has a high alkalinity which can

contaminate soil, groundwater and surface water. The following

recommendations are made:


Mixing areas to be defined on site and carefully located. Y Noted and complied with.

Cement contaminated water should be fed to a container, neutralised

and suitably disposed of (to sewer if acceptable to the Municipality) or

sent to a suitable landfill site. In the latter case, chain of custody

documentation should be provided to ensure a suitable end recipient.

The latter should be kept with the environmental register.

Y Noted and complied with. Contaminated water was re-used for

construction purposes

If possible, the use of ready-mix concrete should be considered. Y Noted and complied with.

Cement bags should be suitably stored, and the used bags disposed of

via the solid waste stream.


Excess or spilled concrete should be disposed of to a suitable landfill site,

with chain of custody documentation provided.


Cement is to be stored in a secure weatherproof location to avoid

contamination of the environment.


Suitable screening and containment shall be in place to prevent

windblown contamination associated with bulk cement silos, loading

and batching.


38

7.5

No materials containing invasive plant seeds, litter or contaminants may

be imported to site. The Engineer shall be informed of the sites of origin

of imported gravel, sand, stone etc. and shall have the authority to

reject imported material if deemed necessary.


7.6

All imported materials (e.g. sand) must be stockpiled within the

Contractor’s camp or agreed demarcated area. Stockpile areas must

be approved by the Engineer before any stockpiling commences.


Material stockpiles must be protected against wind and water erosion

(for prevention of dust, clogging of the stormwater system and other

problems).


8. WASTE HANDLING: SOLID WASTE

8.1

Waste should be categorised by the contractor and disposed of in a

suitable manner into different waste streams (including general and

hazardous waste). Wherever possible recycling should be carried out.

No dumping within the surrounding area is to be permitted.


Where potentially hazardous substances are being disposed of, a chain

of custody document should be kept with the environmental register as

proof of final disposal.


General waste is to be collected either by the Municipality or via a waste

disposal contractor. The frequency of collections will be such that waste

containment receptacles do not overflow.


8.2

The contractor should provide an adequate number of waste

receptacles for general waste at points around the construction site,

and a single collection point for hazardous waste.


The contractor will be responsible for emptying these at regular intervals

and for ensuring that the site is kept clean from litter.


8.3

The contractor shall be required to prepare a method statement to

indicate how and where solid waste will be disposed of based on the

following requirements:


Hazardous waste

o Hazardous wastes shall only be disposed at landfill sites registered for

hazardous waste;

Y Noted and complied with. EnviroServ and Oilkol manifests provided.

o Spills or leaks of construction hazardous materials including but not

limited to concrete curing compounds, asphalt products, paints,

petroleum products from equipment operation and maintenance,

pesticides and herbicides, shall be monitored and remediated

immediately if detected.


o No hazardous waste may be buried or burned under any

circumstances.


o A certificate of disposal by shall be obtained the Contractor and kept

on file, if relevant.

Y Noted and complied with. EnviroServ and Oilkol manifests provided.

o MSDS shall be available for all hazardous substances stored on site. Y Noted and complied with.

o Appropriate hazardous waste spill kits shall be available on site. Y Noted and complied with.

39

o An approved waste disposal contractor must be employed to remove

and recycle waste oil, if practical.


o Burying or burning of solid waste shall not be allowed.

Y Noted and complied with. Except for explosive associated waste,

which according to explosives act has to be burnt on site in a

controlled manner.

General waste

o Regular disposal of general waste to registered landfill sites shall be

required to prevent nuisance factors such as odours, vermin and flies.

No burning of waste shall be allowed.



controlled manner.

o Provide adequate waste bins. Y Noted and complied with.

o Set up system for regular waste removal to an approved landfill facility. Y Noted and complied with.

o Minimise waste by sorting wastes into recyclable and non-recyclable

wastes, if practical.


o No waste may be buried or burned under any circumstances.



controlled manner.

o A housekeeping team should be appointed to regularly maintain the

litter and rubble situation on the construction site.


o Littering by the employees shall not be allowed under any

circumstances.


o The ECO shall monitor the neatness of the work sites as well as the

Contractor campsite.


o Skip waste containers should be maintained on site. These should be

kept covered and arrangements made for them to be collected

regularly to prevent vermin and odours.





9. WASTE HANDLING: WASTEWATER

9.1 No construction fluids should be allowed to enter any watercourses or

onto any adjacent land.


9.2 No wastewater shall be disposed of into the soil. Y Noted and complied with.

Sewage waste

9.3

Chemical toilet facilities are to be supplied and managed by the

contractor. These are to be located in a specific area agreed to by the

ECO prior to placement and to be used by all personnel. A minimum of

one toilet per 15 persons.


Washing, whether of the person or of personal effects, and acts of

excretion and urination are strictly prohibited other than at the facilities

provided.


Latrine and ablution facilities and first-aid services shall comply with the

regulations of the local authority concerned and shall be maintained in

a clean and sanitary condition to the satisfaction of the Engineer.


40

No staff are permitted to commence with work on a site without suitable

toilet facilities available for them. Sanitary facilities shall not be closer

than 50 m to any water body.


These toilets must have doors and locks and shall be secured to prevent

them blowing over. Toilet paper shall be provided.


The Contractor shall ensure that suitable sanitation facilities are provided

for or by all his sub-contractors on site.


Toilets are to be emptied prior to builders’ holidays. The contractor shall

ensure that no spillage occurs when the toilets are cleaned or emptied

and that the contents are removed from site. Discharge of waste from

toilets into the environment and burial of waste is strictly prohibited.


If the Contractor fails to provide and/or maintain all site sanitation

facilities in a clean and hygienic condition, the Engineer may order the

Contractor to suspend any or all work on the site until these requirements

are met.


No payment shall be made for any delays or disruption of the Works

caused thereby nor shall extensions of time be granted for such delays.


10. MACHINERY MANAGEMENT

10.1

All vehicles, equipment, fuel and petroleum services and tanks must be

maintained in good condition that prevents leakage and possible

contamination of soil or groundwater.


An effective monitoring system to detect any leakage or spillage of all

hazardous substances during their transportation, handling, use and

storage shall be implemented. This shall include precautionary measures

to limit the possibility of oil and other toxic liquids from entering the soil or

storm water systems.

Y Noted and complied with. Vehicles were inspected daily.

Measures should include:

• Daily vehicle inspection to detect any leakages and or spillages.


• Weekly visual inspection of plant and standing equipment. Y Noted and complied with.

• Weekly visual inspection of fuel tanks. Y Noted and complied with.

• A record of these inspections needs to be kept to demonstrate

compliance.


• The contractor needs to provide a method statement for “emergency

procedures to deal with leakage and spillage of hazardous substances”.


• Spill remediation kits shall be kept on site and all staff members shall be

informed of where it is located.


Construction machinery should be located away from sensitive areas

when parked for extended periods of time. A dedicated parking area

should be defined with drip trays beneath any leaking equipment.

Fuel/lubricant absorbing media (peat/moss type products) within these

drip trays should be used to hold the spilled liquids.


Fuel/lubricant absorbing media (peat/moss type products) within these

drip trays should be used to hold the spilled liquids. These materials

should be replaced regularly to prevent over-saturation and potential


41

spillage of free product. This material should be disposed of as hazardous

waste and be collected by an approved contractor/delivered to a

suitable waste site.

10.2 Machinery should not be located beneath the foliage of any trees. Y Noted and complied with.

All spills are to be recorded in the Environmental Register, including any

clean-up actions taken to remediate the spillage. Such actions are to

be agreed with the ECO prior to taking place.


11. NOISE

11.1

Noise generation is likely to be one of the most significant impacts at the

site during the construction phase. Every attempt should be made to

reduce noise levels considering the construction site.


11.2

The Contractor shall limit noise levels (e.g. install and maintain silencers

on machinery). When working in any areas within audible distance of

residents whether in urban, periurban or rural areas, the Contractor shall

provide and use suitable and effective silencing devices for pneumatic

tools and other plant that would otherwise cause a noise level

exceeding 85 dB(A) during excavations and other work.


Where activities are likely to produce undue noise disturbance to

communities and adjacent landowners (viz noise levels in excess to 85

decibels), these activities shall be restricted to normal working hours

(08h00 – 17h30 on weekdays and Saturdays). Where this is not possible,

affected parties shall be consulted.

Y Noted and complied with. Records were provided which serves as

evidence of blasting notices

All plant and equipment shall be in good working order and vehicles

shall adhere to the relevant noise requirements of the Road Traffic Act

(93 of 1996). Appropriate directional and intensity settings are to be

maintained on all hooters and sirens and no amplified sound shall be

allowed on site other than in an emergency situation.


No amplified music shall be allowed on Site. The use of radios, tape

recorders, compact disc players, television sets etc shall not be

permitted unless the volume is kept sufficiently low as to avoid any

intrusion on any potential noise receptors within range. The Contractor

shall not use sound amplification equipment on Site unless in emergency

situations.


The Contractor’s attention is drawn to the National Noise Regulations as

promulgated in terms of the Environment Conservation Act and relevant

Local Authority bylaws, as well as the requirements of SANS 10103:2008,

all of which must be complied with.


11.3

No noise generating work can be conducted after 8 p.m. and before 7

a.m. on any workday or during any Sunday, without the prior approval

of the engineer. Due to contractual commitments, it is possible the

contractor may need to work longer periods than those stipulated to

avoid being penalised for time delays. Any such issues will be discussed

and agreed upon by the engineer, contractor and ECO.


14. POST CONSTRUCTION

42

14.1

Final site cleaning and rehabilitation - the contractor shall clear and

clean the site and ensure that everything not forming part of the

permanent works is removed from site before issuing the completion

certificate or as otherwise agreed.


The Vegetation Rehabilitation Plan, included in Appendix 10, shall be

implemented. The construction footprint associated with the activity

shall be re-vegetated with indigenous vegetation, as directed by this

rehabilitation plan. Rehabilitation of disturbed areas shall commence as

soon construction of the specific section have been completed.


14.2 Fourteen (14) days written notice must be given to the DEA and DENC

that the projects operational phase will commence.


17. GENERAL

In conclusion it should be noted that the EMP should be regarded as a

living document and changes should be made to the EMP as required

by project evolution, while retaining the underlying principles and

objectives on which the document is based. Any proposed

modifications to the EMP shall take account the requirements of

Regulation 37 of GN R982, which in the case of any amendments to the

"impact management outcomes or objectives" requires an approval

process from the competent authority, prior to the implementation of

any EMPr amendments.







EMPr – Transmission line

GENERAL

The EMPr for DA1-Tx has followed exactly the same template as the EMPr for DA2N-WEF, which was managed by the same Principle contractor (Longyuan Engineering) in the

same way. Therefore, please refer to the EMPr for DA2N-WEF below:

Noteworthy conditions/ subclauses added from: GENERAL ENVIRONMENTAL SPECIFICATION FOR CONSTRUCTION (Apx B)

Specific conditions which are not referred to in the EMPr for DA2N-WEF, which were applicable for the EMPr for DA1-Tx are included below:

4.3 Specification Data: ENVIRONMENTAL MANAGEMENT (SDEMA)

SDEM 4.3.1 Materials handling, use and storage (Subclause 2.4.11)

The Engineer shall be advised of the areas that the Contractor intends

to use for the stockpiling of both natural and manufactured materials.

No stockpiling shall occur outside of the working area (as designated by

the engineer) and without the Engineer’s prior approval of the proposed

stockpiling areas. Imported material shall be free of litter, contaminants

or exotic plant seed. The Contractor shall ensure that material is not

stockpiled along the border of any water body (permanent or

seasonal).


Location and treatment of material stockpiles shall take consideration

of prevailing wind directions and dwellings. Stockpiles shall be stored

under cover so as to prevent erosion and run off during rainy periods. No

rubble, earth or other material shall be dumped within the Eskom

servitude restriction area.


43

Topsoil (100 -150 mm) from construction areas where vegetation

clearing is required shall be removed and stockpiled for rehabilitation

purposes. This shall be spread over the top of the turbine foundation

after the turbine has been erected and any other disturbed areas which

are to be rehabilitated and seeded with indigenous species. Ground

shall be returned as far as possible to original levels/gradients and any

excess material shall not be left in piles but shall be removed off-site.


Dust suppression measures shall be used particularly during dry periods

of weather during the summer months.


2.4.12 Dust

*Apx B

As required by the National Dust Control Regulations, promulgated in

terms of section 53(o) of National Environmental Air Quality Act (Act 39

of 2004) the Contractor shall establish of a network of dust monitoring

points using method ASTM D1739: 19702 (or equivalent), sufficient in

number to establish the contribution of the person to dust fall in

residential and non-residential areas in the vicinity of the premises, to

monitor identified or likely sensitive receptor locations, and to establish

the baseline dust fall for the district.. The following standards will apply: ·

For residential areas the dust fallout may not exceed 600mg/m2/day (on

a 30-day average) more than two times a year and not on sequential

months. · For non-residential areas the dust fallout may not exceed

1200mg/m2/day (on a 30-day average) more than two times a year

and not on sequential months.

Y/X Ambient quantities of particulate matter were not measured in

accordance with Air Quality Act, 2004 (Act 39 of 2004), however,

adequate dust suppression was implemented such as speed limits,

dust suppression etc. on site.

All materials on the construction sites should be properly stored and

contained. Storage of materials and builders’ rubble shall be screened

from public view.


Cut material shall be used, where possible in construction or on site (e.g.

in grading gravel roads) or removed from site.


SDEM 4.3.2 Hazardous substances (Subclause 2.4.9.3)

Procedures detailed in the Materials Safety Data Sheets (MSDS) shall be

followed in the event of an emergency situation. Potentially hazardous

substances shall be stored, handled and disposed of as prescribed by

the Engineer.


An effective monitoring system to detect any leakage or spillage of all

hazardous substances during their transportation, handling, use and

storage shall be implemented. This shall include precautionary measures

to limit the possibility of oil and other toxic liquids from entering the soil or

storm water systems.


Measures should include:

• Daily vehicle inspection to detect any leakages and or spillages.


• Weekly visual inspection of plant and standing equipment. Y Noted and complied with.

• Weekly visual inspection of fuel tanks. Y Noted and complied with.

• A record of these inspections needs to be kept to demonstrate

compliance.


44

• The contractor needs to provide a method statement for “emergency

procedures to deal with leakage and spillage of hazardous substances”.


• Spill remediation kits shall be kept on site and all staff members shall be

informed of where it is located.


SDEM 4.3.3 Shutter oil and curing compound (Subclause 2.4.9.1)

Shutter oil and curing compound shall be stored and dispensed within a

bunded area, and not located closer than 32m from the top of the

riverbanks/water courses/drainage lines.


4.4 Requirements

SDEM 4.4.1 Ablution facilities (Subclause 2.4.20)

A sufficient number of chemical toilets shall be provided by the

Contractor in the construction camp area and at appropriate locations

approved by the Engineer. Temporary/ portable toilets shall not be

located within 100 m from the top of the riverbanks/water

courses/drainage lines. The ratio of ablution facilities for workers should

not be less than that required by the Construction Regulations of 2003 of

the Occupational Health and Safety Act. All temporary/ portable toilets

shall be secured to the ground to prevent them from toppling due to

wind or any other cause.


SDEM 4.4.2 Solid Waste Management (Subclause 2.4.9)

The contractor shall be required to prepare a method statement to

indicate how and where solid waste will be disposed of based on the

following requirements:


• Hazardous waste

o Hazardous wastes shall only be disposed at landfill sites registered for

hazardous waste;


Spills or leaks of construction hazardous materials including, but not

limited to, concrete curing compounds, asphalt products, paints,

petroleum products from equipment operation and maintenance,

pesticides and herbicides shall be monitored and remediated

immediately if detected.


All hazardous waste materials must be carefully stored as advised by the

ECO, and then disposed of at a licensed landfill site.


No hazardous waste may be buried or burned under any circumstances.


which according to explosives act has to be burnt on site, which

happened in a controlled manner.

A certificate of disposal by shall be obtained the Contractor and kept



o MSDS shall be available for all hazardous substances stored on site. Y Noted and complied with.

o Appropriate hazardous waste spill kits shall be available on site. Y Noted and complied with.

o An approved waste disposal contractor must be employed to remove

and recycle waste oil, if practical.

Y Noted and complied with. Oil recycling not feasible.

45

o Burying or burning of solid waste shall not be allowed.


which according to explosives act has to be burnt on site, which

happened in a controlled manner.

• General waste

o Regular disposal of general waste to registered landfill sites shall be

required to prevent nuisance factors such as odours, vermin and flies.

No burning of waste shall be allowed.


o Provide adequate waste bins. Y Noted and complied with.

o Set up system for regular waste removal to an approved landfill facility. Y Noted and complied with.

o Minimise waste by sorting wastes into recyclable and non-recyclable

wastes, if practical.


o No waste may be buried or burned under any circumstances. Y Noted and complied with.

o A housekeeping team should be appointed to regularly maintain the

litter and rubble situation on the construction site.


o Littering by the employees shall not be allowed under any

circumstances.


o The ECO shall monitor the neatness of the work sites as well as the

Contractor campsite.


o Skip waste containers should be maintained on site. These should be

kept covered and arrangements made for them to be collected

regularly to prevent vermin and odours.





SDEM 4.4.3 Contaminated Water (Subclause 2.4.7)

The Contractor shall prevent the discharge of any pollutants, such as

soaps, detergents, cements, concrete, lime, chemicals, hydrocarbons,

glues, solvents, paints and wastewater into the surrounding terrestrial

and aquatic environment. No discharge would be allowed, and all

contaminated soil, contaminated water and hazardous materials shall

be disposed at a registered facility.


SDEM 4.4.4 Site Structures (Subclause 2.3)

No site structures shall be located within 32 m from the top of the

riverbanks/water courses/drainage lines. Construction yards should be

restricted in extent as far as possible and should be screened by visually

impermeable material. No structures to be occupied or frequented by

people shall be built within delineated servitude areas.


Ensure the construction yards are neat and tidy at all times. Site offices,

if required, should be limited to single storey and should be sited carefully

using temporary screen fencing to screen from the wider landscape.


SDEM 4.4.5 Noise control (Subclause 2.4.4)

Construction traffic shall be routed as far as practically possible from

potentially sensitive receptors.


A good working relationship between the contractor and all potentially

sensitive receptors shall be ensured by establishing communication

Y Noted and complied with. No noise related complaints were

received during construction phase.

46

channels to ensure prior notice to the sensitive receptor if work is to take

place close to them. Information that should be provided to the

potential sensitive receptor(s) include:

o Proposed working times; Y Noted and complied with.

o how long the activity is anticipated to take place; Y Noted and complied with.

o what is being done, or why the activity is taking place; Y Noted and complied with.

o contact details of a responsible person where any complaints can be

lodged should there be an issue of concern.


When working within 500 m of a potential sensitive receptor, the number

of simultaneous activities (e.g. construction of access roads, trenches,

etc) shall be limited to the minimum as far as possible. Furthermore,

working time shall be co-ordinated with periods when the receptors are

not at home, where possible. An example would be to work within the

08:00 to 14:00 timeslot to minimize the significance of the impact

because potential receptors are most likely at school or at work,

minimizing the probability of an impact happening.

Y Noted and complied with. Farm occupants were >500m from

activities.

Use of the smallest/quietest equipment for the particular purpose shall

be considered.


Ensure that equipment is well-maintained and fitted with the correct and

appropriate noise abatement measures.


2.4.5 Lighting

*Apx B

The Contractor shall ensure that any lighting installed on the site for his

activities does not interfere with road traffic or cause a reasonably

avoidable disturbance to the surrounding community or other users of

the area. Subject to meeting the minimum requirements of the OHSA

and general security, lighting shall be kept to the minimum. Care will be

taken to ensure lighting is task specific and does not spill into the

surrounding environment through appropriate placement and shielding.

Floodlighting of expansive work areas or up- or down lighting of vertical

structures or natural features shall only be permitted if approved by

Engineer.


SDEM 4.4.6 Fuel (Petrol and Diesel) and oil (Subclause 2.4.6)

Fuels in the form of diesel and petrol shall not be stored within 32 m from

the top of the riverbanks/water courses/drainage lines.


SDEM 4.4.7 Equipment Maintenance and Storage (Subclause 2.4.10)

A designated area with an impermeable surface shall be available for

the washing of equipment and vehicles. Wastewater generated from

the washing of vehicles and equipment shall drain via an oil and water

separator into a bunded area. The oil should be removed as required by

a registered service provider to a register facility. The water

accumulated in the bunded area can evaporate. If solids area

accumulated in the bunded area over time, if should be removed by a

registered contractor and disposed at a registered facility. Wastewater

generated from construction or the washing of vehicles shall not be

Y Noted and complied with. Only wastewater from concrete wash-

bays were applicable.

47

permitted to enter water courses, either directly or via a stormwater

system.

SDEM 4.4.8 Stormwater Erosion Control (Add Section 2.4.8)

The Contractor shall take reasonable measures to control the erosive

effects of stormwater runoff. Any runnels or erosion channels developed

during the construction period or during the maintenance period shall

be backfilled and compacted to limit the impacts of sediment

deposition into the surrounding aquatic environment.


A stormwater management plan shall be implemented (see Appendix

I). The plan shall ensure compliance with applicable regulations and

prevent off-site migration of contaminated storm water or increased soil

erosion. The plan shall include the appropriate measures that allow

surface and subsurface movement of water along drainage lines so as

not to impede natural surface and subsurface flows. Drainage measures

shall promote the dissipation of storm water run-off.


Run-off over any exposed areas should be mitigated to reduce the rate

and volume of run-off and prevent erosion occurring on the site and

within the freshwater features and drainage lines. Contaminated runoff

from the construction site(s) should be prevented from entering the

rivers/streams.


SDEM 4.9 Method Statements (Subclause 2.2)

The following additional method statements shall be provided by the

Contractor within 14 days of the receipt of the Letter of Acceptance

and prior to the activity covered by the Method Statement being

undertaken:

• Logistics for the environmental awareness course for all the

Contractors employees.


• Emergency procedures for fire, accidental leaks and spillages of

hazardous materials including:

o who shall be notified in the event of an emergency, including contact

numbers for the relevant local authority,

o where and how any hazardous spills will be disposed of,

o the size of spillage which the emergency procedures could contain,

o location of all emergency equipment and an indication of how

regularly the emergency equipment will be checked to ensure that it is

working properly.


• Location and layout of the construction camp in the form of a plan

showing offices, stores for fuels, hazardous substances, vehicle parking,

access point, equipment cleaning areas and staff toilet placement.


• Location, layout and preparation of cement/concrete batching

facilities including the methods employed for the mixing of concrete

and the management of runoff water for such areas. An indication shall

be given of how concrete spoil will be minimised and cleared.


• Method of undertaking earthworks, including spoil management,

erosion, dust and noise controls.


48

• Method of undertaking blasting. Y Noted and complied with.

• Method to detect leakages based on Section 4.3.2. Y Noted and complied with.

• Management measures to be undertaken in instances where traffic

flows may be interrupted.


• Extent of areas to be cleared, the method of clearing and the

preparation for this clearing so as to ensure minimisation of exposed

areas.


• Measures to be put in place during temporary closure periods, e.g.

December holidays.


• Measures to be put in place to limit sediment deposition into the

surrounding terrestrial and aquatic environment.


• Method statement on integrated waste management shall be

compiled by the contractor based on SDEM 4.4.2.


SDEM 4.4.10 Site Clearance (Subclause 2.7.1)

Removal of vegetation (uprooting) must be kept to a minimum. Only

those areas where it is imperative to remove vegetation i.e. construction

areas, identified storage areas, roads and minor tracks should be

cleared. If uprooting is required, the Contractor shall store the top


material and root material of cleared vegetation (top 300 mm layer), for

subsequent use during rehabilitation and re-vegetation. All other areas

should remain vegetated. If brush-cutting is required as a minimum

intervention, this should be applied with discretion; however, it would

always be preferred to uprooting. If vehicle movement is required off

designated roads and tracks, it would be advisable to drive over the

shrubs (crush) rather than to uproot them. This would prevent loss of these

shrubs since they would be able to regrow if not uprooted.


The Contractor shall not make use of herbicides or other chemical

methods to clear the proposed site especially near the identified water

courses. In order to limit erosion, the Contractor shall retain original

groundcover, as far as practically possible, adjacent to the aquatic

environment and to the trenching line as per the Revegetation and

Rehabilitation Plan in Appendix G.


SDEM 4.4.11 No go areas (Subclause 2.3.3)

All works to be undertaken shall be within the boundary of the site, refer

to the Open Space Management Plan in Appendix K. A “no go” area

shall extend on either side of the working area i.e. all areas outside of

the defined working area and designated access roads. The working

area shall be demarcated in an appropriate manner determined by the

Engineer.


Based on the ecological importance, all construction activities shall

remain outside of all aquatic environments, with special efforts

implemented to maintain a 32 m buffer between construction related

activities and any rivers/water courses/drainage lines. These no-go areas


49

shall stay in place until construction of the infrastructure within the buffer

area must commence.

No equipment associated with earthworks shall be allowed outside of

the site and defined access routes, or within “no go” areas, unless

expressly permitted by the Engineer.


The recommended ecological sensitivity and buffer areas indicated in

Figure 1 shall be demarcated as “no go” areas and construction

activities shall remain outside these designated areas.


No mechanical equipment, including mechanical excavators or high

lifting machinery, shall be used in the vicinity of Eskom’s apparatus

and/or services, without prior written permission having been granted by

Eskom. If such permission is granted the Contractor must give at least

seven working days’ notice prior to the commencement of work. This

allows time for arrangements to be made for supervision and/or

precautionary instructions to be issued by the relevant Eskom Manager

Note: Where and electrical outage is required, at least fourteen

workdays are required to arrange it.


2.3.2 Site fencing and demarcations

*Apx B

The Contractor shall not damage or remove any boundary fences

without the agreement of the adjoining landowner. Where property

fences are replaced these shall, at the minimum, meet specification of

the fencing it replaces, in terms of top height, sturdiness and rigidity (pole

foundations and supports and strength and wire gauge), security

(barbed or razor wire) and size of the largest openings (i.e. distances

between horizontal wires or mesh dimensions.


2.4.1 Protection of natural features

*Apx B

The Contractor shall not deface, paint, damage or mark any natural

features (e.g. rock formations) situated in or around the Site for survey or

other purposes unless agreed beforehand with the Engineer. Any

features affected by the Contractor in contravention of this clause shall

be restored/ rehabilitated to the satisfaction of the Engineer.


SDEM4.4.12 Protection of flora and fauna (Subclause 2.4.2)

A Revegetation and Rehabilitation Plan, included in Appendix G, shall

be implemented. The specialist shall recommend species to be used in

rehabilitation as well as any special measures for rehabilitation, such as

shade-netting and alien vegetation removal. Restoration shall be

undertaken as soon as possible after completion of construction

activities to reduce the amount of habitat converted at any one time

and to speed up the recovery to natural habitats. A Plant Rescue and

Protection Plan, included in Appendix F, shall be implemented. This plan

will be compiled by a vegetation specialist familiar with the site and be

implemented prior to commencement of the construction phase.

Y Noted and complied with. Revegetation not feasible because of the

relatively small disturbed areas, but ripping and top soiling occurred

to restore natural vegetation.

2.7.13 Temporary revegetation of the areas disturbed by construction

50

*Apx B

e) The prepared area shall be hydro- or hand-seeded at a rate of 40

kg/ha using a suitable indigenous grass species or Rye grass (Lolium

multiflorum). In the event of hand-seeding, the seed mixture as specified

shall be mixed with two parts per volume of clean dry plaster sand, then

divided in half and applied evenly in two successive applications, one

after the other, by means of an approved hand seeding machine

(known colloquially as a “tefsaaier”). On completion of the seeding the

surface shall be lightly raked to cover the seed with no more than 5 mm

of soil.


relatively small disturbed areas, but ripping and top soiling occurred

to restore natural vegetation.

No flora shall be removed or damaged, outside of the designated

working area, without specialist botanical input.


The collection of firewood by construction workers should be prohibited. Y Noted and complied with.

Any snakes found on site shall be removed from site and released into

an area away from the site, without harm.


The contractor shall ensure that the time a trench is left exposed is kept

to a minimum, and that open trenches are inspected on a daily basis for

animals which may have fallen or become trapped. Any animals found

trapped in any trenches shall be freed without harm.


The Alien Invasive Management Plan, included in Appendix H, shall be

implemented.

Y Noted and complied with. No aliens observed on site.

An Open Space Management Plan, included in Appendix K, shall be

implemented.


Noise shall be reduced and maintained to a minimum particularly with

regards to blasting on the ridge-top associated with excavations for

foundations. Blasting should not take place during the breeding seasons

of the resident avifaunal community and in particular for priority species.

Blasting shall be kept to a minimum and, where possible, synchronized

with neighbouring blasts.


Disturbance associated with the operation of the facility shall be

minimised, by scheduling maintenance activities to avoid and/or

reduce disturbance in sensitive areas at sensitive times – such areas will

be identified during the pre-construction and operational monitoring.


2.4. Mitigation measures during the construction phase

Avifauna

Prior to construction commencing, an inspection should be performed

by the avifaunal specialist to record any large raptor nests on the existing

transmission lines that could be impacted by the construction of the

proposed De Aar 1 Maanhaarberg 132 kV line.


All the spans, except those spans that are located adjacent to two or

more high voltage lines, should be marked with Bird Flight Diverters on

the earth wire of the line, ten metres apart, alternating black and white.

Appendix B of the Avifauna report indicates the preferred BFDs to be

used.

Y No Bird Flight Diverters were recommended by the specialist. All lines

are located adjacent to high voltage lines.

51

The new transmission line should be marked with bird flight diverters

along its entire length and that all new power line infrastructure is

adequately insulated and of a configuration that is bird friendly.

Y No Bird Flight Diverters were recommended by the specialist. All lines

are located adjacent to high voltage lines.

SDEM 4.4.13 Protection of archaeological and paleontological remains (Subclause 4.4.3)

Should substantial fossil remains be exposed during construction, these

should be safeguarded by the ECO, preferably in situ, and the South

African Heritage Resources Association (SAHRA) should be notified by

the ECO immediately so that appropriate mitigation can be

undertaken.

Y Noted and complied with. No remains were exposed.

2.4. Mitigation measures during the construction phase

Paleontological mitigation measures

A palaeontologist must monitor all construction activities in the areas

identified as being moderate to highly palaeontological sensitive in

Figure 21 of the submitted heritage report. This palaeontologist must

advise on pylon positions to limit negative impact to significant

palaeontological heritage. A monitoring report must be submitted to

SAHRA once work is completed.

Y Noted and complied with. A monitoring report was submitted to

SAHRA.

A Palaeontologist should be appointed as part of the Environmental

Construction Team for preferably all identified paleontological sensitive

areas but definitely for the identified highly sensitive areas.


SDEM 4.4.14 Access routes/ haul roads (Subclause 2.4.18)

Eskom’s rights and services shall be acknowledged and respected at all

times. Unobstructed access shall be granted to Eskom to access their

servitudes.


The contractor shall ensure that all regulations relating to traffic

management are observed and local traffic officials are informed of the

proposed construction activities. As far as possible, attempts shall be

made to ensure that high construction related road usage coincides

with low traffic flow periods.


Signage and safety measures during the construction of the access

roads shall comply with the guidelines as set out in the latest issue of the

SADC Road Traffic Signs Manual. Standard “construction ahead”

warning signs should be placed on all relevant roads in the area. Ensure

access roads are kept clean and storage of materials is screened.


A traffic management plan for the site access roads shall be compiled

and implemented to ensure that no hazards would results from the

increased truck traffic and that traffic flow would not be adversely

impacted. This plan shall include measures to minimize impacts on local

commuters e.g. limiting construction vehicles travelling on public

roadways during the morning and late afternoon commute time and

avoid using roads through densely populated built-up areas so as not to

disturb existing retail and commercial operations.


2.4.18 Access routes / haul roads

52

*Apx B

Unless inside the urban edge or part of an environmental authorisation

in terms of NEMA R544 Activity No. 22. (II) no new construction road shall

exceed 8m or where such road already exists be widened by more than

6m or lengthened by more than 1000m.


SDEM 4.4.15 Cement and concrete batching (Subclause 2.7.3)

No cement and / or concrete batching shall occur within the “no-go”

areas or within 32 m from the top of riverbanks/water courses/drainage

lines. Reasonable measures shall be implemented to limit contaminated

surface run-off into the surrounding vegetation.


SDEM 4.4.16 Earthworks (Subclause 2.7.4)

Any blasting is to be executed by a suitably qualified person. Y Noted and complied with.

Controlled blasting techniques shall be employed to minimise dust and

fly rock during blasting.


The use of explosives of any type within 500 m of Eskom’s services shall

only occur with Eskom’s previous written permission. If such permission is

granted the Contractor must give at least fourteen working days prior

notice of the commencement of blasting. This allows time for

arrangements to be made for supervision and/or precautionary

instructions to be issued in terms of the blasting process. It is advisable to

make application separately in this regard.

Y

Noted and complied with. Blasting notifications given.

Prior to blasting the Contractor shall notify the relevant occupants/

owners of surrounding land and address any concerns. Buildings within

the potential damaging zone of the blast shall be surveyed preferably

with the owner present, and any cracks or latent defects pointed out

and recorded either using photographs or video. All Local Authority

regulations are to be adhered to and all service infrastructures are to be

located prior to commencement of blasting activities.


Blasting or drilling shall take place during normal working hours. The

Contractor shall notify emergency services, in writing, a minimum of 24

hours prior to any blasting activities commencing on site. Adequate

warning must be issued to all personnel on site prior to blasting activities

taking place. All legally required signals are to be clearly indicated. The

Engineer shall be issued daily updates of the days intended blasting

activities.


The Contractor shall prevent damage to special features and the

general environment, which includes the removal of flyrock. Damage

caused by blasting / drilling shall be repaired to the satisfaction of the

Engineer.


Minimise areas disturbed at any one time and protect exposed soil

against wind erosion, e.g. by dampening with water or covering with

hessian.


Changes in ground level may not infringe statutory ground to conductor

clearances or statutory visibility clearances with respect to existing

powerlines onsite. Clearances between Eskom’s live electrical

equipment and the proposed construction work shall be observed as


53

stipulated in terms of Regulation 15 of the Electrical Machinery

Regulations of the Occupational Health and Safety Act, 1993 (Act 85 of

1993) at all times.

SDEM 4.4.17 Community relations (Subclause 2.6)

Maintain a register that shall contain details of the measures taken to

resolve complaints and the details of the communication of these

measures to the person who raised the complaint.


*DENC EA 16 Any complaints must be brought to the attention of the Dept within 24h

and a complaints register kept up to date.


2.4.13 Aesthetics

*Apx B

The Contractor shall take reasonable measures to ensure that

construction activities do not have an unreasonable impact on the

aesthetics of the area. Measures will be taken to obscure construction

yards and associated plant and equipment from onlookers as far as is

reasonable. Refer also to 2.4.4 regarding requirements for lighting.


2.4.14 Disruption to existing and neighbouring land use activities

*Apx B

The Contractor shall take measures to limit the disruption of any existing

land use activities occurring on the site or neighbouring sites as far as

reasonable.


2.4.15 Temporary site closure

*Apx B

If the site is closed for a period exceeding one week, the Contractor, in

consultation with the Engineer shall carry out [the specified] checklist

procedure.


2.4.16 Public roads

*Apx B

Where road safety may be impacted on the Contractor shall notify the

relevant roads authority and arrange for the necessary road warning

signage and appoint trained points men to control traffic around any

hazards. Any damage caused to the public road system as a result of

construction or as a direct result of construction vehicles and equipment

shall be repaired to the satisfaction of the Engineer.


*Apx B

On gravel or earth roads on Site and within 500 m of the Site, the vehicles

of the Contractor and his suppliers shall not exceed a speed of 20 km/h.

Mud and sand deposited onto public roads by construction activities

shall be cleared on a daily basis.


2.4.17 Security and access control

*Apx B

The Contractor shall ensure that access to the Site and associated

infrastructure and equipment is off-limits to the public at all times during

construction. If so required, as directed by the Engineer, the Contractor

shall fence the site to ensure effective control of access to the site.


SDEM 4.4.18 Erosion and sedimentation control (Subclause 2.7.7)

Erosion control measures, as included in Appendix I, shall be

implemented to minimise erosion at excavation / clearing sites or

aggregate storage sites. Where necessary, sedimentation barriers shall

be laid between the Work Area and the “no-go” areas to limit sediment

Y Noted and complied with. Storm water berms were reinstated on

servitude roads.

54

deposition. The sedimentation barrier shall consist of a geotextile fabric

stretched across and attached to supporting posts and stabilised with

sandbags. The barrier shall be inspected daily and any damage shall be

repaired immediately. Sediment deposits shall be removed once they

reach half the height of the barrier.

Minimise duration and extent of construction activities in the river.

Construction shall also preferably take place in the low flow season.

Where access routes need to be constructed through ephemeral

streams, disturbance of the channel should be limited.


Clearing of debris, sediment and hard rubble associated with the

construction activities should be undertaken post construction to ensure

that flow within the drainage channels are not impeded or diverted.

Rehabilitate disturbed stream bed and banks and revegetation with

suitable indigenous vegetation.


SDEM 4.4.19 Site closure and rehabilitation (Subclause 2.7.12)

All construction debris found within the disturbed areas shall be removed

and disposed of at a registered landfill site.


A Vegetation Rehabilitation Plan, included in Appendix G, shall be

implemented. The construction footprint associated with the activity

shall be re-vegetated with indigenous vegetation, as directed by this

rehabilitation plan. Rehabilitation of disturbed areas shall commence as

soon construction of the specific section have been completed.


relatively small disturbed areas around monopoles, however ripping

and top soiling occurred to restore natural vegetation.

SDEM 4.4.20 Labour requirements

Equipment shall be regarded electrically live and therefore dangerous

at all times. Safety and best practice standards with regards to all safety

hazards related to electrical plant shall be employed for the

development.


Recruitment shall be based on sound labour practices and with gender

equality in mind. Obtain a list of locally available labour and skills.

Preference shall be given to local communities.


Appropriate training shall be provided to enable individuals to apply

their skills to other construction and development projects in the region

once the construction phase is completed.


Environmental Management Programme (EMPr), Section 4 Operational Phase

Mitigation measures to be implemented as proposed by the various specialist consultants

Traffic Management

Pg. 17 / Sheet. 21

of 38

After construction of the development is completed, the Smauspoort

Road must be repaired where necessary and restored to satisfactory

condition (refer to Traffic Impact Assessment Addendum in Appendix 6).


Environmental Management documentation and procedures

Pg. 36 / Pg. 40 of

387

The overall goal of the OEMP will be to ensure that the operation of the

WEF does not have unforeseen impacts on the environment and to

ensure that all impacts are monitored, and the necessary corrective

Y Daily monitoring of the WEF was observed on the WEF De Aar 1 which

was conducted by the resident EM.

55

action is taken (OEMP included in Appendix 4). Note: Fourteen (14) days

written notice must be given to the DEA and DENC that the projects

operational phase will commence.

Furthermore weekly, monthly and annual monitoring reports of

various specialist including avifaunal, botanical and bat monitoring

reports. Various processes and procedure documentation have been

compiled for the operational phase of the facility.

DEA and DENC were given 14 days’ notice that the operational

phase commenced. Also observed was the monitoring

documentation for the site which included site audits (latest up to

date audit dated May 2019).

56

Operational Phase EMP (OEMP): Operational Management Programme Framework

Environmental Management documentation and procedures

Page No. Aspect

Impact

Mitigation Measure:

(Objective and Mechanism) Performance Indicator

Y/X/NA Findings & Recommendations

Environmental Management Programme (EMPr), Section 4

Mitigation measures to be implemented as proposed by the various specialist consultants

Pg. 17 /

Sheet. 21

of 387

Traffic

Management

Impacts of the

operation and

maintenance

of the WEF on

the surrounding

community and

infrastructure.

After construction of the

development is completed, the

Smauspoort Road must be repaired

where necessary and restored to

satisfactory condition (refer to Traffic

Impact Assessment Addendum in

Appendix 6).

Traffic Assessment

Addendum


Pg. 36

/

Pg. 40

of

387

Environmental

Management

documentation

and procedures.

No framework

within which to

locate the

management

of the

operational

phase.

No procedures

against which to

assess

environmental

performance

during the

operational

phase and thus

no measure of

compliance

The overall goal of the OEMP will be

to ensure that the operation of the

WEF does not have unforeseen

impacts on the environment and to

ensure that all impacts are

monitored, and the necessary

corrective action is taken (OEMP

included in Appendix 4).

Note: Fourteen (14) days written

notice must be given to the DEA and

DENC that the projects operational

phase will commence.

Proof of Notification of

Commencement

Y

Daily monitoring of the WEF De Aar 1

which conducted by the resident EM.

Furthermore weekly, monthly and annual

monitoring reports of various specialist

including avifaunal, botanical and bat

monitoring reports. Various processes and

procedure documentation have been

compiled for the operational phase of the

facility.

DEA and DENC were given 14 days’

notice that the operational phase

commenced. Also observed was the

monitoring documentation for the site

which included site audits (latest up to

date audit dated 10th of August 2018).

4. Operational Phase EMP (OEMP)

Operational Management Programme Framework

57

Page No. Aspect

Impact

Mitigation Measure:



Pg. 1 /

Sheet.

127

of 387

Environmental

Management

documentation

and procedures.

No framework

within which to

locate the

management

of the

operational

phase.

No procedures

against which to

assess

environmental

performance

during the

operational

phase and thus

no measure of

compliance

Prior to the commissioning of the WEF,

a suitably qualified Environmental

Manager (EM) should be appointed

by Longyuan Mulilo De Aar Wind

Power.

The role of the EM during this phase

would be to address the on-going

operation of the WEF and to ensure

that the issues that have been

identified in the OEMP are properly

addressed on a continued basis and

in a manner that limits any

environmental impact.

The primary roles and responsibilities

of the EM will be:

The appointment of a

suitably qualified

Environmental Manager

(EM)

Y

Mr Doughty is the appointed EM on site.

1.) To represent Longyuan Mulilo

De Aar Wind Power (Pty) Ltd in the

implementation of the OEMP on site;

Y

Mr Doughty was observed to represent

Longyuan in terms of the

implementation of the OEMP on site.

The management of the area plus

observation of documentation on site

was observed to be proof of

implementation of the OEMP.

2.) To inspect the site on a

monthly basis and advise on

areas of environmental

management, or compliance

with the OEMP, requiring

attention;

Y

Monthly inspections and audits

are conducted by the onsite SHE

Manger.

No framework

within which to

locate the

3.) To inspect the site more

regularly during the first 3 months of

operations, during which more

frequent monitoring may be required

for the establishment of certain

programmes or aspects of

environmental management.

Y

It is noted that the EM on site conducts

site inspections on a daily basis;

furthermore, formal internal monthly

Inspections and audits are

undertaken.

58

Page No. Aspect

Impact

Mitigation Measure:



Pg. 1 /

Sheet.

127

of 387

Environmental

Management

documentation

and procedures.

management

of the

operational

phase.

No procedures

against which to

assess

environmental

performance

during the

operational

phase and thus

no measure of

compliance

4.) Maintain a photographic

record of site inspections undertaken

as well as any incidents that occur

and subsequent corrective action.

Y

It was observed that photographic

evidence is kept on file, in particular for

any incidents which occur on site.

5.) Be responsible for ensuring that

the Avifaunal Post-Construction

Monitoring Programme (Appendix 7)

and the Operational Phase Bay

Monitoring Programme (Appendix 8)

required in terms of this EMPr is

carried (with the requisite specialist

input as required);

Y

Specialists have been appointed and

implement quarterly and annual

monitoring programmes.

All information recorded on site is

submitted to the EM and on site SHE

manager.

Pg. 1 /

Sheet.

127

of 387

Pg. 1 /

Sheet.

127

of 387

Environmental

Management

documentation

and procedures.

Environmental

Management

documentation

and procedures.

No framework

within which to

locate the

management

of the

operational

phase.

No procedures

against which to

assess

environmental

performance

during the

operational

phase and thus

no measure of

compliance

No framework

within which to

locate the

management

of the

operational

phase.

6.) To liaise with various specialists

and the local authorities as and

when required, regarding issues

relating to environmental

management;


7.) To report on compliance with

the OEMP specifications to

Longyuan Mulilo De Aar Wind

Power (Pty) Ltd

Y External audit being conducted.

Monthly O&M Reports are compiled

which include both Health &Safety and

Environmental issues.

The last audit was conducted on the

May 2019.

8.) To facilitate environmental

audits and ensure that they are

undertaken, as required;

Y The Environmental Management

Department ensures all audits are

conducted.

This audit falls part of the requirement.

9.) To keep a comprehensive

record of environmental

management, and any issues of

non-compliance for audit purposes.

Such monitoring records shall be

kept in an Environmental

Management File on

site.

Y

It was observed that an Incident

register is kept on site along with a

NCR register.

59

Page No. Aspect

Impact

Mitigation Measure:



No procedures

against which to

assess

environmental

performance

during the

operational

phase and thus

no measure of

compliance

10.) To undertake any other tasks

outlined in this document, on behalf of

Longyuan Mulilo De Aar Wind Power

(Pty)

Ltd

Y

The EM's undertake to implement any

recommendations and mitigations

measures as highlighted in Specialist

Reports.

Pg. 13/

129 of

387

Environmental

Management

documentation

and procedures.

No framework

within which to

locate the

management

of the

operational

phase.

No procedures

against which to

assess

environmental

performance

during the

operational

phase and thus

no measure of

compliance

Objective:

To ensure that the operation of the WEF does not result in avoidable impacts on the environment and that any impacts

that do occur are anticipated and managed.

Mechanism:

1. Appoint a suitably qualified

Environmental Manager (EM) to

monitor compliance (either

independent on in- house).

Environmental impacts

effectively monitored and

managed during the

operational phase.

Comprehensive record of

compliance and

remedial actions

available to the

authorities

Y

Andrew Doughty has been appointed as

the designated EM on site, De Aar.

2. Audit the compliance with the

requirements of the environmental

specification contained within the

OEMP

Y

BI Annual Audits are conducted by an

external party as is conducted in terms of

this checklist and report for August 2018.

The previous audit conducted was during

May 2019.

Objective:

60

Page No. Aspect

Impact

Mitigation Measure:



Pg. 3 - 4/

Sheet.

129

- 130 of

387

Protection of the

surrounding

environment

(aquatic and

terrestrial)

Impacts of the

operation and

maintenance of

the WEF on the

surrounding

environment

(including local

flora, fauna, bats,

avifauna and

watercourses

around the

proposed

development)

To maintain minimised footprints of disturbance of vegetation/habitats on-site.

To ensure and encourage plant regrowth in areas of post-construction rehabilitation.

Mechanism:

1. Vehicle movements will be

restricted to designated roadways

No further disturbance to

vegetation.

Continued improvement

in rehabilitation

efforts.

Y Vehicles strictly stayed inbounds of the

roads network within the WEF.

2. Existing roads will be maintained

to ensure limited erosion and

impact on areas adjacent to

roadways.

Y The roads within the project area were

observed to be in good condition

throughout the full geographic scope of

the project.

Road repairs underway

3. Implementation of the

Revegetation and Rehabilitation Plan

(Appendix 10).

Y It was observed that the area in which

rehab and revegetation was conducted

in the areas required. An annual

botanical inspection has been

conducted on the 25th of May 2018.

61

Page No. Aspect

Impact

Mitigation Measure:



Previous batch plant and site camp

rehabilitated.

Former stockpile area with some vegetation

recovery

Laydown area with some vegetation recovery

62

Page No. Aspect

Impact

Mitigation Measure:



4. Implementation of the Alien

Vegetation Removal Programme

Y A local contractor (de Aar Electric) has

been appointed (co-signed appointment

on the 8th of March 2018 to conduct

alien clearing on the WEF site.

This is on an as and when required basis as

there is a low concentration of invasive

plants present on site.

Areas are monitored by Longyuan EM

and De Aar Electric and removal of

vegetation is conducted on as- and

when- required basis.

5. Ongoing implementation of the

Storm Water Management Plan

(Appendix 14) to ensure compliance

with applicable regulations and

prevent off-site migration of

contaminated storm water or

increased soil erosion.

Y A storm water management system was

observed in the vicinity of the substation.

Various potentially hazardous areas are

either bunded off or separate from the

storm water system. It was also observed

that cut off V- drains existed in the area.

Stormwater drain maintenance

6. Ensure ongoing implementation of

Open Space Management Plan

(Appendix 15).

Y

Various recommended measures have

been implemented on site such as no-

go areas, designated roads, etc.

63

Page No. Aspect

Impact

Mitigation Measure:



Pg.4 -

8/ 130

- 134

of 387

Protection of

avifauna

Disturbance to

or loss of birds

as a result

collision with

the turbine

blades.

Disturbance to or

loss of birds as a

result of collision

with the

overhead power

line.

Electrocution as a

result of the

power line.

Objective:

To reduce the impact of the operating WEF on priority bird species

Mechanisms:

1. Implementation of the Avifaunal

Post- Construction Monitoring

Programme (Appendix 7).

No additional disturbance

to avifaunal populations

on the WEF site.


to avifaunal populations

along the length of the

power line route.


of avifaunal protection

efforts

Y Monitoring is undertaken monthly by

the Lady Birds (Pty) LTD, a dedicated

service provider whose role it is to

monitor for bird and bat fatalities.

Bird and bat carcasses are labelled and

stored in a freezer

2. Bird flappers to be fitted to

overhead power lines, where

required (as identified by a suitably

qualified ornithologist)

Y

Bird flappers were observed during the

site visit

64

Page No. Aspect

Impact

Mitigation Measure:



Pg.4 -

8/ 130

- 134

of 387

Protection of

avifauna

3. Further specific requirements as follows:

Lesser Kestrel and Amur Falcon

Adaptive management must be

implemented for the influx of Lesser

Kestrel linked to locust invasions

during the summer season at the

WEF area.

Temporary shut-down of turbines at

certain times in a day (i.e. two hours

after dawn or two hours prior to

sunset) may be required during

periods of high bird traffic.

NA

No shut down has been necessary to date

Counts must be conducted during

the summer season at the De Aar

roosting sites and any additional

roosting sites in the vicinity of the WEF.

Y

Counts were conducted in January 2019

and data collected by an ornithologist as

part of independent monitoring. Weekly to

monthly undertaken.

Verreaux's Eagle

Continue with the Argos / GPS satellite

tracking.

Y GPS Satellite tracking continued during

operations until March 2019 (when the

tracker fell of the eagle). The bird specialist

has confirmed that tracking do not have to

continue indefinitely and a new eagle do

not have to be tagged.

If need be, implement adaptive

management for the Verreaux’s

Eagle based on the satellite tracking

monitoring results.

Y

Noted. Mitigation measures for turbine

collisions is being developed.

65

Page No. Aspect

Impact

Mitigation Measure:



Pg.4 -

8/ 130

- 134

of 387

Protection of

avifauna

If results of the initial monitoring at

nest VE3 indicate any potential risky

turbines, further monitoring should be

implemented at these turbines.

Based on the results of this

monitoring, adaptive management

should be implemented (if need be)

to effectively reduce any risk to the

fledgling eagle.

Y/X

There have been several bird incidents

involving Verreaux’s eagles. Half of these

mortalities were caused by collisions and the

remainder were from electrocutions on the

powerlines connecting the turbines. As a

result of this bird perches has been

extensively installed on the powerlines to

reduce the risk of electrocutions and

monitoring of the effectiveness of this

mitigation continues. The project owner has

been consulting with BLSA and the avifaunal

specialist and mitigation measures for

turbine collisions are being developed for

testing and implementation.

Monitor the breeding activity of

eagles in the area by assessing the

number of pairs and breeding

success (productivity and fledgling

rates), including (if feasible) the

identification of individual adult birds.

Y

A monitoring program was conducted.

The monitoring program is noted to

include radio tracking, as a breeding pair

having been fitted with a radio tracking

device which has subsequently fallen off.

The number of breeding pairs have also

been identified in the specialist report

observed and are monitored on a weekly

basis.

Visual observations continue.

Blue Crane

Results indicate that the species does

not occur regularly on the plateaus

where the turbines are located but

rather on the surrounding plains

below the plateaus.

No specific mitigation is required at

this stage, but ongoing monitoring

should be performed to record any

potential changes in this pattern of

occurrence.

NA

To be reassessed if the species has been

verified as occurring regularly on site.

To be determined by the Appointed

Avifaunal Specialist.

Water birds and Large Terrestrial Species

66

Page No. Aspect

Impact

Mitigation Measure:



Pg.4 -

8/ 130

- 134

of 387

Protection of

avifauna

Waterbodies on the plateau are less

frequented by water birds than

those in the surrounding plains. This

could be due to a variety of factors

such as size, availability of water,

shelter and access. No specific

mitigation measures are required at

this stage as far as the turbines are

concerned.

NA

To be reassessed if the species has

been verified as occurring regularly on

site. To be determined by the

Appointed Avifaunal Specialist.

General Recommendations

Prior to electrification of the wind

farm an on-site "walk through' should

be conducted by the ornithological

consultant to identify the sections of

power line between the turbines

which require marking with Bird

Diverters as an

anti-collision measure


During the operational phase, regular

surveys of the intra-turbine power lines

will be conducted as part of the post-

construction monitoring programme

to assess if there are collision

mortalities, and any additional spans

identified as high risk should be

marked with Bird Flight Diverters.

Y

Weekly inspections are undertaken by

The Lady Birds (Pty) Ltd. at the turbines.

The internal reticulation lines are

inspected on a quarterly basis.

Pg.4 -

8/ 130

Protection of

In addition to that, the 132kV grid

connection should also be inspected

at least once a quarter to establish if

there is any significant collision

mortality.

NA

132Kv line is managed by ESKOM.

67

Page No. Aspect

Impact

Mitigation Measure:



- 134

of 387

avifauna

The fitting of Bird Flight Diverters on

the 33-kV power line which crosses

the narrow kloof between

Smouspoort and Swartkoppies is

recommended.


Pg.4 -

8/ 130

- 134

of 387

Protection of

avifauna

Exterior lighting at night should

be reduced to a minimum.

Where possible, the following

measures must be implemented:

Use long-wavelength (red or

orange) or energy-saving lights.

Use minimum lumen or wattage in

fixtures.

Use directional fittings, down-

lights and shielded fixtures.

Install sealed light fittings so that

insects cannot reach the light

source. Control lighting with

timers so that non-essential lights

do not stay on all night.

Screen interior lighting with blinds,

curtains, etc. to prevent exterior

light pollution.

Limit mounting heights of lighting

fixtures or use foot-lights or

bollard- level lights.

Warning lights should be flashing,

not constant, to avoid attraction

of animals.

Use motion-detectors on

security lighting.

Y

Y

It was observed that LED lighting is only

used at on the substation.

External substation lights are kept off

except for strategic structural lights

which are low impact.

Lights on turbines flash intermittently but

can also be observed as low range and

low impact.

Objective:

68

Page No. Aspect

Impact

Mitigation Measure:



Pg. 8 - 10

/

Sheet

134

- 136 of

387

Protection of

bats and fauna

Disturbance to

or loss of fauna

including bats,

and/or habitat.

Direct mortalities

To minimise impacts on fauna, including bats.

Mechanisms:

1. Vehicle movements to be

restricted to designated roadways.


to fauna populations on

the WEF site.


of fauna protection

efforts


2. Adherence to reduced vehicle

speeds by all vehicles moving on

site.

Y Site induction is conducted with all

visitors to site in which vehicle

restrictions are conveyed.

3. Implement the Bat Operational

Phase Management Plan

(Appendix 8).

Y

Animalia Zoological & Ecological

Consultation have been appointed as

the onsite specialist who implements the

Bat Operational Phase Management

Plan.

Additional Requirements in respect of Bats:

(i) Operational phase monitoring is

essential to determine the actual

impacts on bats and therefore the

required mitigation measures and

thresholds. However, such an

approach requires an exceptionally

flexible Adaptive Management Plan

to be implemented during operation.

Such an Adaptive Management Plan

must allow for changes to be

implemented within a maximum

timeframe of 3 weeks.

Y

Animalia Zoological & Ecological

Consultation have been appointed

as the onsite specialist who

implements the Bat Operational

Phase Management Plan.

69

Page No. Aspect

Impact

Mitigation Measure:



(ii) The Wind Farm must agree to

follow the mitigation measures that

may result from the operational

monitoring and Adaptive

Management Plan.

NA

Currently no adaptive management is

required, therefore no agreement is

having been warranted.

(iii) In accordance with the Adaptive

Management Plan, appropriate

mitigation measures, such as

curtailment at specific environmental

conditions and/or the use of acoustic

bat deterrents, will have to be

implemented in the case of high bat

mortality. The operational monitoring

study design must allow for

determining the exact environmental

conditions as well as the turbines that

require appropriate mitigation

measures.

NA

Currently no adaptive management is

required, therefore no agreement is having

been warranted.

(iv) Emerging technologies such as

acoustic bat deterrents can be

experimented with during operation

and can replace curtailment if

proven to be equally or more

effective than curtailment.

NA

No acoustic deterrents are yet needed.

(v) Operational Monitoring will have

to be designed and carried out

according to the Best Practise

Guidelines on Operational Monitoring

that is available at the start of the

facilities operation. That includes all

relevant factors such as which

turbines are surveyed, amount of site

visits, etc.

Y

A bat monitoring report is provided to

Mulilo at weekly and quarterly intervals.

The weekly report indicated the bat

mortalities on site. The quarterly report

indicated acoustic monitoring data as

well mortalities and scavenger effect and

influence on mortalities.

70

Page No. Aspect

Impact

Mitigation Measure:



(vi) Operational monitoring must

commence once the first turbine is

turning, regardless of grid

connections being completed or not.

However, mitigation measures that

alters turbine operations can only be

implemented once all testing phases

on a turbine is completed.

Y

It was observed that the Bat

Monitoring report was done during

August 2018 and indicates that the

bat mortalities are not significant to

warrant any management

intervention at this stage.

(vii) Lighting at the turbines must be

fitted with passive motion sensors and

static lighting prohibited, as this will

create feeding zones that will

increase bat presence around

turbines and subsequently increase

the probability of mortalities. Such

passive motion sensors must be

maintained and any faulty sensors

resulting in a light to remain

illuminated, must be shut down until it

is repaired/replaced.

Y

The following finding is referred to:

External turbines lights adhere to those

required by the Civil Aviation Authority.

Internal lights are kept off at all times and

are only used in the event of emergency

repairs.

(viii) The storm water drainage plan

must avoid creations of artificial

ponds or wetlands in turbine zones,

as these will increase insect activity

and therefore bat activity in the

area. This can result in turbines that

were previously assessed as having a

low risk to be treated as financially

and biologically costly high-risk

turbines.

Y

There has been some recent damage to

storm water drains. At the time of the site

inspection, repairs were almost complete.

Objective:

To minimise the production of waste.

To ensure appropriate waste disposal. To avoid environmental harm from waste disposal.

71

Page No. Aspect

Impact

Mitigation Measure:



Pg. 10 -

11

Sheets

. 136 -

137

of 387

Appropriate

handling and

management of

hazardous

substances and

waste.

Litter of

contamination

of the site or

water through

poor waste

management

practices

Mechanisms:

1.) Hazardous substances must be

stored in sealed containers within a

clearly demarcated bunded area.

Such containment bunds shall be

impermeable and shall have a

minimum volume of 110% of the

volume of substances being stored.

The floor of the bund shall be sloped

towards an oil trap or sump to enable

any spilled substances to be removed.

Bunded area shall have overheat

cover to prevent rain from entering the

bunded area.

No complaints received

regarding waste on site or

indiscriminate dumping.

Internal site audits

identifying that waste

segregation recycling

and re-use is taking

place.

No contamination of soil

or water.

NA

.

No hazardous substance storage units

were on site.

2.) All structures and/or components

replaced during maintenance

activities must be appropriately

disposed of at an appropriately

licenced waste disposal site or sold to

a recycling merchant for recycling.

NA

No large-scale component replacement

has as yet been conducted terms of

interviews held with the site EM.

3.) Care must be taken to ensure that

spillage of oils and other hazardous

substances are limited during

maintenance. Handling of these

materials should take place within an

appropriately sealed and bunded

area. Should any accidental spillage

take place, it will be cleared up

according to specified standards for

bioremediation.

Y

Spill kits are available on site for small

spill.

72

Page No. Aspect

Impact

Mitigation Measure:



Spill kits on site

The project has an agreement in place

with a specialist service provider to handle

larger spills.

4.) Used oil and chemicals will

be appropriately disposed at a

licenced facility.

NA

No hazardous substances have been

disposed of to date.

5.) General waste will be recycled

where possible or disposed of at a

licenced facility.

Y Due to the small volumes of waste

recycling is deemed not to be viable, at

present waste is disposed of at the local

municipal landfill facility, if the amount of

waste increases over time the Licence

Holder will explore the option of

recycling.

6.) Hazardous waste (including

hydrocarbons) and general waste

will be stored and disposed of

separately.

Y

General and Hazardous Waste Stored

separately.

7.) Disposal of waste will be in

accordance with relevant legislative

requirements, including the use of

licenced contractors.

Y General waste is disposed of at the

municipality with records being kept

on site

Pg. 11 -

12

Sheets

. 137 -

138

of 387

Visual Aesthetics

Impact of the

proposed

development

on the

surrounding

visual aesthetics

of the area

Objectives:

To ensure that impacts on the visual aesthetics are minimised during the operational phase.

Mechanisms:

1.) During operation, the

maintenance of the turbines, the

internal roads, the power line

servitude and other ancillary

structures and infrastructure will

ensure that the facility does not

degrade, thus aggravating visual

impact.

Condition of the project

infrastructure and roads.

Y

Ongoing maintenance occurs daily.

Onsite inspections file made available

73

Page No. Aspect

Impact

Mitigation Measure:



2.) Turbines should not display

brand names.

Y

No branding visible.

Pg. 12

Sheet

138

of 387

Environmental

management of

the operational

phase

Positive impacts

on socio-

economic

environment

during operation

Objectives:

To ensure that the operation of the wind energy facility maximises positive impacts on the socio-economic environment.

Mechanisms:

1) Train local people for operation

and maintenance of facility.

Consult annual skills and

training records,

employment records and

proof of staff residency in

the area prior to

employment.

Y The Lady Birds (Pty) Ltd is a local

company which is involved in bird

collision monitoring who received

training from the Project Specialist. De

Aar Electric (Pty) Ltd has received

training for to various skills and activities

relevant to site.

2) Employ local labour for the

operational phase, where

possible, and particularly for

day to day operations and

maintenance.

Y

The Lady Birds (Pty) Ltd is a local company

which is involved in bird collision

monitoring.

Adenco is a local electrical contractor

employed on site. De Aar Electric is a

company that has been locally sourced

and is responsible for general site

maintenance and alien vegetation

clearing.

Pg. 12 -

13

Protection of

Eskom

infrastructure

Impact of the

proposed

development

on the Eskom

powerlines

Objectives:

To ensure that the operation of the WEF does not result in avoidable impacts on the Eskom powerlines.

Mechanisms:

1.) Liaise with Eskom to come to an

agreement regarding suitable risk

mitigation measures to be put into

place for operational management.

Compliance with Eskom’s

guidelines.

Y

Bird Diverters have been placed on the

132kV line as a mitigation measure prior

to being handed over to ESKOM.

74

Page No. Aspect

Impact

Mitigation Measure:



Sheets.

138 -

139

of 387

2.) No mechanical equipment,

including mechanical excavators or

high lifting machinery, shall be used

in the vicinity of Eskom’s apparatus

and/or services, without prior written

permission having been granted by

Eskom.

If such permission is granted the

Contractor must give at least seven

working days’ notice prior to the

commencement of work. This allows

time for arrangements to be made

for supervision and/or precautionary

instructions to be issued by the

relevant Eskom Manager.

Note: Where and electrical outage

is required, at least fourteen

workdays are required to arrange it.

NA

Work permit required when working on

site, when working in vicinity of

ESKOM powerlines the Project notifies

accordingly.

No communication regarding this

condition to date.

3.) Unobstructed access shall be

granted to Eskom to access their

servitudes.

Y Dedicated ESKOM lock and key system on

all access gates allow ESKOM free

access.

4.) Equipment shall be regarded

electrically live and therefore

dangerous at all times. Safety and

best practice standards with regards

to all safety hazards related to

electrical plant shall be employed for

the projects.

NA

Duly noted by the Licence Holder

APPENDIX 2: DECLARATION OF INDEPENDENCE

APPENDIX 1: DECLARATION

THE INDEPENDENT ENVIRONMENTAL CONTROL OFFICER (ECO)

I, B Wiesner, as the appointed independent environmental practitioner (“ECO”) hereby declare that I:

• act/ed as the independent ECO in this audit report;

• regard the information contained in this report to be true and correct;

• do not have and will not have any financial interest in the undertaking of the activity, other than remuneration for work performed in terms of the NEMA, the Environmental Impact Assessment Regulations, 2017 and any specific environmental management Act; and

• have and will not have no vested interest in the activity;

Signature of the environmental assessment practitioner:

Amathemba Environmental management Consulting CC

Name of company:

Date: 727 February 2020