Zitholele Consulting Reg. No. 2000/000392/07 PO Box 6002 Halfway House 1685 South Africa Thandanani Park, Matuka Close Halfway Gardens, Midrand Tel + (27) 11 207 2060 Fax + (27) 86 674 6121 E-mail : mail@zitholele.co.za REPORT ON Final EMPr for the proposed New Golela Substation and two Associated 132kV TurnIn Lines from the existing Mkuze-Pongola 132kV Power Line Report No : 12722 FEMP v2 Submitted to: Department of Environmental Affairs Private Bag X447 PRETORIA 0001 DISTRIBUTION: 2 Copies Private PRETORIA 0001 Department 1 Copy Zitholele Consulting (Pty) Ltd – Library - of Environmental Bag 13 October 2014 Directors: S Pillay (Managing Director); N Rajasakran (Director); Dr RGM Heath (Director) Affairs X447 12722 October 2014 ii 12722 TABLE OF CONTENTS SECTION 1 INTRODUCTION ........................................................................................... 2 1.1 2 3 4 5 11.2 15 Planning Phase ....................................................................................19 Construction Phase ..............................................................................24 Operational Phase ................................................................................30 ENVIRONMENTAL ASPECT AND IMPACT REGISTER ........................... 31 ORGANISATIONAL STRUCTURE ............................................................. 46 ENVIRONMENTAL ROLES AND RESPONSIBILITIES ............................. 46 18.1 18.2 18.3 18.4 19 20 21 22 23 Integration of the Environmental Management Programme into the Contract ................................................................................................14 Specification structure and Application .................................................15 11.2.1 Method statements..................................................................15 11.2.2 Site documentation and record keeping ..................................16 ENVIRONMENTAL AWARENESS TRAINING ........................................... 17 PROVISIONS FOR ADDRESSING NON-CONFORMANCE ..................... 18 ENVIRONMENTAL CONSIDERATIONS IN ADJUDICATION OF TENDER ...................................................................................................... 18 ENVIRONMENTAL MANAGEMENT MEASURES FOR THE PROJECT .................................................................................................... 19 15.1 15.2 15.3 16 17 18 Power Line Servitude ............................................................................12 132 kV Towers ......................................................................................12 Access Roads.......................................................................................12 Fencing, Gates and Access Control ......................................................12 Expansion of the existing Pongola Substation and Candover Switching Station ..................................................................................12 CONSTRUCTION ACTIVITIES ................................................................... 13 OPERATIONAL ACTIVITIES ...................................................................... 13 DECOMMISSIONING ACTIVITIES ............................................................. 14 SCOPE OF THE ENVIRONMENTAL MANAGEMENT PROGRAMME ..... 14 11.1 12 13 14 Objectives of the Environmental Management Programme ................... 7 Structure of this Document .................................................................... 8 PROJECT LOCATION .................................................................................. 8 DESCRIPTION OF PROJECT COMPONENTS ......................................... 12 7.1 7.2 7.3 7.4 7.5 8 9 10 11 Background Information ......................................................................... 2 ENVIRONMENTAL FEATURES OF STUDY AREA ..................................... 3 LEGAL FRAMEWORK .................................................................................. 4 ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP) ....................... 6 CONTEXT AND OBJECTIVES OF THIS REPORT...................................... 7 5.1 5.2 6 7 PAGE Department of Environmental Affairs ....................................................46 Eskom ..................................................................................................46 Environmental Control Officer ...............................................................48 Contractors ...........................................................................................49 TRAINING .................................................................................................... 50 PROJECT COMPLIANCE REPORTING .................................................... 51 REPORTING PROCEDURES AND DOCUMENTATION........................... 51 ENVIRONMENTAL CONTACT PERSON................................................... 51 EMERGENCY CONTACT NUMBERS........................................................ 51 ZITHOLELE CONSULTING October 2014 iii 12722 LIST OF FIGURES Figure 1 : Locality Map of the Study Area.........................................................................11 LIST OF TABLES Table 1: Document Roadmap ........................................................................................... 5 Table 2: Impacts, Management/ Mitigation Measures during the Planning Phase ............20 Table 3: Construction Process for sub transmission lines ................................................24 Table 4 : Impacts, Management/ Mitigation Measures during Construction Phase ...........25 Table 5: Environmental Aspects and Impacts Register ....................................................31 ZITHOLELE CONSULTING October 2014 iv 12722 GLOSSARY OF TERMINOLOGY Contractor means the main contractor as engaged by the Eskom for the construction of the subject infrastructure, including all Subcontractors and service provides appointed by the main contractor of his own volition for the execution of parts of the Works. “Contractor” also includes any other contractor engaged by Eskom directly in connection with any part of the construction, which is not a nominated sub-contractor to the main contractor. Environment1 (i) the land, water and atmosphere of the earth; (ii) microorganisms, plant and animal life; (iii) any part or combination of (i) and (ii) and the interrelationships among and between them; and (iv) the physical, chemical, aesthetic and cultural properties and conditions of the foregoing that influence human health and wellbeing. Environmental Means a person who is responsible for the monitoring of the Control Officer implementation of the requirements of an EMPr on behalf of the applicant. Environmental Means a person who is responsible for the implementation of Officer the requirements of an EMPr on behalf of the contractor. Environmental Impact Assessment (EIA) Environmental means a study of the environmental consequences of a proposed course of action. means an environmental change caused by some human act. impact 1 As defined in terms of the National Environmental Management Act No. 107 of 1998 (NEMA). ZITHOLELE CONSULTING October 2014 Method Statement v 12722 means setting out in detail how the management actions contained in an EMPr will be implemented, in order to ensure that the environmental objectives are achieved. Public Participation means a process of involving the public in order to identify Process needs, address concerns, in order to contribute to more informed decision making relating to a proposed project, programme or development. ZITHOLELE CONSULTING 1 LIST OF ABBREVIATIONS BA ..................................................................................................... Basic Assessment CH4 .................................................................................................................. Methane DME........................................................................ Department of Minerals and Energy DWS ...................................................................... Department of Water and Sanitation EA....................................................................................... Environmental Authorisation EIA ...........................................................................Environmental Impact Assessment EMPr ............................................................. Environmental Management Programme ECO……………………........................................................ Environmental Control Officer EO .................................................................................................. Environmental Officer DEA........... ............................................................ Department of Environmental Affairs GNR................................................................................ Government Notice Regulation I&AP ................................................................................ Interested and Affected Party NEMA ............................... National Environmental Management Act (No. 107 of 1998) NEM: AQA........... National Environmental Management Air Quality Act (No 39 of 2004) NEM:WA................... National Environmental Management Waste Act (No. 59 of 2008) ZITHOLELE CONSULTING 2 1 INTRODUCTION 1.1 Background Information Eskom Distribution’s - KwaZulu-Natal Operating Unit, is currently upgrading the electricity infrastructure on the Makhathini Flats in northern KwaZulu-Natal. With the proposed construction of three new 132/22kV substations for the supply of the greater Makhathini area viz. Ndumo Substation, Skhemelele, Gezisa Substation, Manguzi, and Mbazwana substation, Mbazwana, the existing Pongola-Candover 132kV power line will be overloaded by 2013. Should the existing Pongola-Candover 132kV power line be out of service, for whatever reason, then Makhathini, Gezisa, Ndumo and Nondabuya Substation loads will be shed resulting in an inevitable loss of supply on the greater Makhathini area and an unacceptable service to customers. As a solution Eskom proposes to construct infrastructure to strengthen and upgrade the network in the Pongola, Mkuze and Golela areas. The objective of the proposed construction of a second 132kV overhead distribution line between the Pongola Substation and Candover Switching Station is to increase the reserve capacity in the existing lines, while providing additional capacity to supply anticipated load growth on the Makhatini Flats in the Jozini and Umhlabuyalingana Local Municipalities. In order to accommodate the second Pongola-Candover 132kV power line, modifications to the existing Pongola 132/22kV substation and the existing Candover switching station will have to be undertaken. In addition, a proposed 132kV power line and substation will be required to tee-off the existing Mkuze-Pongola 132kV power line to feed a proposed Golela substation to be located on the MR8 road which leads to the Golela border post with Swaziland. The proposed project activities will accommodate future electrical loads for proposed developments at the border post and localised 22kV networks. Construction and operation of the above 132kV power lines and Golela substation are subject to Basic Assessments (BA) in terms of Section 14 of the National Environmental Management Act (107 of 1998) (NEMA), as amended. In fulfilment of this requirements, Eskom has appointed Zitholele Consulting to act as the independent environmental assessment practitioner (EAP) and to undertake the BA process. The proposal, as part of the electrification of the greater Makhathini area, includes the following principal activities for which authorisation is sought. Activity 1: Construction of a second 132kV power line within a 36 m wide servitude from the existing Pongola substation to the existing Conover switching station. The estimated length of the power line will be approximately 50 to 60km long depending on the option adopted. Activity 2: Modification of the existing Pongola Substation and Candover Switching Station to accommodate the second Pongola-Candover 132kV power line; Activity 3: Location of a new 132/22kV substation on the secondary road to the Golela border post; ZITHOLELE CONSULTING 3 Activity 4: Construction of two 132kV power lines either as single or double circuit configuration to supply the proposed Golela Substation. Although the BA for all the above activities has been conducted simultaneously due to their overlapping study areas, the results of the BA have been provided in two separate Basic Assessment Reports (BAR) covering the above activities as follows: Basic Assessment Report 1: Activities 1 and 2 – Proposed new Pongola-Candover second 132kV Power line and associated modifications to the existing Pongola substation and Candover switching station is dealt with; and Basic Assessment Report 2: Activity 3 and Activity 4 - Location of two 500 m wide, 15 km long corridors for the construction of two 132kV tee-off power lines from the Mkuze-Pongola 132kV power line to provide supply to and from the proposed Golela Substation. With the construction of three proposed new 132kV substations for the supply of the greater Makhathini area viz. Ndumo, Gezisa and Mbazwana substations, the existing PongolaCandover 132kV line will be overloaded by 2013. Should the existing Pongola-Candover 132kV line be out of service for whatever reason then Makhathini, Gezisa, Ndumo and Nondabuya loads will be shed resulting in an inevitable loss of supply on the greater Makhatini area and an unacceptable service to customers. A second 132kV line from Pongola to Candover therefore needs to be constructed for electrical purposes and to enhance security of supply for the Makhatini substations of Ndumo, Gezisa and Mbazwana. In order to accommodate a second Pongola-Candover 132kV line modifications to the existing Pongola 132/22kV substation and the end point, the existing Candover switching station will have to be undertaken. A 132kV power line and substation is also required to tee-off the existing Mkuze-Pongola 132kV power line (also called MkuzePongola line 1). This substation is required close to the turn-off from the N2 to the road leading to the Golela border post with Swaziland. This is to accommodate the electrical load for developments within the vicinity of the border post. 2 ENVIRONMENTAL FEATURES OF STUDY AREA The topography of the study area is predominantly rolling hills, but relatively high escarpments traverse the study area from north to south. Game farms and cattle farms, game reserves and some sugar cane are the predominant land uses in the study area. The vegetation consists of Zululand Lowveld and Northern Zululand Bushveld and is very dense in the central and south eastern portions of the study area. The mountainous terrain and dense vegetation generally coincide and will impose access constraints and poses challenging conditions for undertaking the necessary construction activities. According to the Local Municipalities’ Integrated Development Plans for the uPhongolo Area some important conservation areas require careful management in the unfolding development pattern. These conservation areas include the Pongolapoort Dam and ZITHOLELE CONSULTING 4 nature reserve, the area surrounding the Mkuze River as well as the area between the R66 and the N2 Roads. 3 LEGAL FRAMEWORK An Environmental Management Programme (EMPr) is guided by sound environmental management practices and is based on national and international best practices, and relevant legislation, policies and guidelines. All stakeholders should note that obligations imposed by the EMPr are legally binding in terms of environmental statutory legislation and in terms of the additional conditions to the general conditions of contract that pertain to this project. In the event that any rights and obligations contained in this document contradict those specified in the standard or project specifications then the latter shall prevail. All legislation applicable to the development must be strictly enforced, and may including the following: The Constitution of the Republic of South Africa Act 108 of 1996, (Chapter 2: Bill of Rights, Section 24: Environmental right, Section 25: Rights in property); National Environmental Management Act, 107 of 1998, as amended; Environment Conservation Act, 73 of 1989; National Environmental Management: Protected Areas Act, 57 of 2003; National Environmental Management: Biodiversity Act, 10 of 2004; National Forests Act, 43 of 1983; The National Water Act, 36 of 1998; Hazardous Substances Act, 15 of 1973; National Heritage Resources Act, 25 of 1999; Conservation of Agricultural Resources Act, 43 of 1983; Occupational Health and Safety Act, 85 of 1993; National Veld and Forest Fire Act, 101 of 1998; Fertilisers, Farm Feeds, Agricultural Remedies and Stock Remedies Act, 36 of 1947; National Environmental Management: Waste Management Act, 59 of 2008; Mineral and Petroleum Resources Development Act, 28 of 2002; and Health Act, 63 of 1977. A detailed account of all environmental legislation including specific Environmental Management Acts which have a bearing on the proposed Pongola-Candover 132kV power line and associated modifications to the existing Pongola 132/22kV Substation and Candover Switching Station is provided in Part 11 of Section A: Activity Information of the Basic Assessment Report (BAR). This Environmental Management Programme (EMPr) must be read along with the BAR. Specific provisions which are included in Regulation 33 of the Environmental Impact ZITHOLELE CONSULTING 5 Assessment (EIA) Regulations 2010 (R.5432) relating to the contents of an EMPr is provided in Table 1. Although the EMPr is a living document and should be continually updated and improved, any amendments which are made to the approved document must be done in accordance with Regulation 46 of the EIA Regulations 2010 (R.543). It should be noted that obligations imposed by the EMPr are legally binding in terms of environmental statutory legislation and in terms of the additional conditions to the general conditions of contract that pertain to this project. Non-compliance to environmental law is a criminal offence and if prosecuted Eskom will be liable for any environmental damage incurred. Table 1: Document Roadmap DOCUMENT ROADMAP Regulation 33 of the EIA Regulations (2010) Description of Regulation Relevant chapter of document details of – Regulation 33(a) Regulation 33(b) Regulation 33(c) Regulation 33(d) Regulation 33(e) Regulation 33(f) (i) the person who prepared the environmental management programme; and (ii) the expertise of that person to prepare an environmental management programme; Information on any proposed management or mitigation measures that will be taken to address the environmental impacts that have been identified in a report contemplated by these Regulations, including environmental impacts or objectives in respect of— (i) planning and design; (ii) pre-construction and construction activities; (iii) operation or undertaking of the activity; (iv) rehabilitation of the environment; and (v) closure, where relevant. A detailed description of the aspects of the activity that are covered by the draft environmental management programme; An identification of the persons who will be responsible for the implementation of the measures contemplated in paragraph (b); Proposed mechanisms for monitoring compliance with and performance assessment against the environmental management programme and reporting thereon; As far as is reasonably practicable, measures to rehabilitate the environment affected by the undertaking of any listed activity or specified activity to its natural or predetermined state or to a land use which conforms to the generally accepted principle of sustainable development, including, where appropriate, concurrent or progressive rehabilitation measures; 2 Chapter 4 Chapter 15 Chapter 8-10 Chapter 16 Chapter 8-10 Chapter 16 Chapters 13, 20 and Chapter 21 Chapter 8-10 Chapter 16 South Africa. 2010. National Environmental Management Act, 1998 (Act No. 107 of 1998) Environmental Impact Assessment Regulations, 2010. (Notice 543). Government gazette 33306:3, 18 June ZITHOLELE CONSULTING 6 DOCUMENT ROADMAP Regulation 33 of the EIA Regulations (2010) Regulation 33(g) Regulation 33(h) Regulation 33(i) Regulation 33(j) Regulation 33(k) 4 Description of Regulation A description of the manner in which it intends to— (i) modify, remedy, control or stop any action, activity or process which causes pollution or environmental degradation; (ii) remedy the cause of pollution or degradation and migration of pollutants; (iii) comply with any prescribed environmental management standards or practices; (iv) comply with any applicable provisions of the Act regarding closure, where applicable; (v) comply with any provisions of the Act regarding financial provisions for rehabilitation, where applicable; Time periods within which the measures contemplated in the environmental management programme must be implemented; The process for managing any environmental damage, pollution, pumping and treatment of extraneous water or ecological degradation as a result of undertaking a listed activity; An Environmental Awareness Plan describing the manner in which — (i) the applicant intends to inform his or her employees of any environmental risk which may result from their work; and (ii) risks must be dealt with in order to avoid pollution or the degradation of the environment; Where appropriate, closure plans, including closure objectives. Relevant chapter of document Chapter 8-10 Chapter 16 Chapter 8-10 Chapter 16 Chapter 8-10 Chapter 16 Chapter 12 Not Applicable ENVIRONMENTAL ASSESSMENT PRACTITIONER (EAP) In terms of the NEMA (1998) and Environmental Impact Assessment (EIA) Regulations (Government Notice Regulation [GNR] 543 to 546, June 2010) the proponent must appoint an Environmental Assessment Practitioner (EAP) to undertake an EIA and / or PPP for listed activities regulated in terms of the aforementioned Act. In this regard, Eskom appointed Zitholele Consulting (Pty) Ltd. (Zitholele) to undertake the PPP and complete the Amendment Application for the proposed project, in accordance with the aforementioned regulations. Zitholele is an empowerment company formed to provide specialist consulting services primarily to the public sector in the fields of Water Engineering, Integrated Water Resource Management, Environmental and Waste Services, Communication (public participation and awareness creation) and Livelihoods and Economic Development. ZITHOLELE CONSULTING 7 Zitholele Consulting has no vested interest in the proposed project and hereby declares its independence as required by the EIA Regulations. The details of the EAP representatives are listed below. The details of the key individuals representing Zitholele, and acting as the EAP on these projects are given below. Sharon Meyer Douglas, as Project Director Name: Sharon Meyer Douglas Company Represented: Zitholele Consulting (Pty) Ltd. Address: P O Box 6002, Halfway House, 1685 Telephone: 011 207 2060 Fax: 086 674 6121 E-mail: sharonm@zitholele.co.za 5 CONTEXT AND OBJECTIVES OF THIS REPORT This Final EMPr has been drafted according to the findings of the impact assessment, and is included as an appendix to the BA Report (BAR) and submitted to the authorities for approval along with EA evaluation process. The Final EMPr is published as a standalone document for ease of use. 5.1 Objectives of the Environmental Management Programme Environmental management does not end with obtaining the required EA. Rather there is a need to ensure that the remedial requirements identified during the environmental process are effectively realised during project implementation, and this is where EMPrs have a key role to play. An EMPr, in the context of the EIA Regulations (2010), is a tool that takes a project from a high level consideration of issues down to detailed workable action plan that can be implemented in a cohesive and controlled manner. An EMPr is defined as “an environmental management tool used to ensure that undue or reasonably avoidable adverse impacts of the construction phase of a project are prevented and that the positive benefits of the projects are enhanced”. Impacts range from those incurred during start up (site clearing, erection of the construction camp), and to those incurred during operation. Specifically, the objectives of this EMPr can be articulated as follows: To give effect to the construction related requirements; To give effect to the environmental commitments to the various role players; To ensure that these requirements / commitments are expressed in a manner that is accessible to all parties and is binding upon those responsible for project implementation; ZITHOLELE CONSULTING 8 To ensure that sufficient resources are allocated to the project budget in order to give effect to the environmental requirements / commitments, and to ensure that the scale of EMPrrelated interventions is consistent with the significance of identified impacts; To provide a coherent and pragmatic framework for the implementation of the requirements, ranging from the roles and responsibilities of the key project participants to the auditing and reporting of compliance; To facilitate appropriate and proactive response to unforeseen events or changes in project implementation that were not considered in the BA process; and To ensure that the construction phase of the project does not result in undue or reasonably avoidable adverse environmental impacts, and that any potential environmental benefits are enhanced. 5.2 Structure of this Document This document has been divided into four parts, each addressing a different aspect of the Environmental Management Programme (EMPr). 6 Part A provides a brief introduction, details of the person who prepared the EMPr and his / her expertise; and overview of the purpose and structure of this document; Part B sets the context for the EMPr by providing an overview of the project, summarising the objectives of the EMPr, highlighting the scope of the EMPr and briefly emphasising Eskom’s environmental commitments; Part C provides an overview of the structure and application of the environmental management plan and highlights the environmental considerations that should inform the construction and operation phases; Part D provides guidance in terms of the on-site implementation of the EMPr, highlighting the organisation structure and various roles and responsibilities, emphasising the importance of awareness training, summarising the requisite approach to monitoring and auditing and addressing the requirement for review and amendment of the environmental specifications; and Part B Setting the Context. PROJECT LOCATION This proposed new 132/22kV substation will be located about 1 km north-east of the intersection of the N2 and the secondary road to the Golela border post. Corridors of about 500 metre wide will be investigated in which to locate the 36m wide servitudes for the two approximately 15 km long loop-in and loop-out lines to run from the existing Mkuze-Pongola 132kV line (Mkuze-Pongola Line 1) at two points to the proposed Golela Substation. The co-ordinates for the approximate start-middle-end points of the development corridor are given below. Northern Corridor ZITHOLELE CONSULTING 9 Location along the corridor Starting point of the activity Middle/Additional point of the activity End point of the activity South 27° 26' 53.437" S East 31° 38' 20.980" E 27° 24' 44.040" S 31° 50' 30.528" E 27° 32' 57.097" S 31° 59' 14.825" E South East Central Corridor Location along the corridor Starting point of the activity 27° 26' 53.437" S 31° 38' 20.980" E Middle/Additional point of the 27° 31' 12.640" S 31° 49' 33.486" E 27° 32' 57.097" S 31° 59' 14.825" E activity End point of the activity Southern Corridor Location along the corridor Starting point of the activity Middle/Additional point of the activity End point of the activity South East 27° 26' 53.437" S 31° 38' 20.980" E 27° 32' 1.670" S 31° 50' 1.610" E 27° 32' 57.097" S 31° 59' 14.825" E The development corridor is located on the farms: Farm Name Portion Number Farm Name Portion Number Bedrog En Ontrecht 801, 326 Mooiplaats 606 Bethel 247 N2 Road Reserve 772 Bloemhof 649 Nooitgedacht 614 Bosveld 745, 860 Ongeluk 622 Burgersrust 672 Paardenfontein 674 Clerkness 13459 Sandduinen 652 Dubula 91 Soetveld 775 Erfenis 621, 17634 Steenboklaagte 202 Goedgeloop/F 17323 Sunland 72 Gollel 16936 Tamboti Ridge 81 Helena 759 Uitgevallen 599 Klipfontein Helena 17542, 17543 Uitsig 861 Koedoesberg 747 Uitzicht 624 Konkoni 0, 772 Ulrica 17330 Langgewacht 646 Vergelegen 17058 Leeuwkop 580, 859 Verwijderd 618 Lelieshoek 730, 746 Warrick 13436 Magut 817, 818, 819 Welverdiend 104 Meijershoek 602 ZITHOLELE CONSULTING 10 A layout map showing the site boundaries, the development corridor, and other project components is shown in Figure 1 ZITHOLELE CONSULTING 11 Figure 1 : Locality Map of the Study Area ZITHOLELE CONSULTING 12 7 DESCRIPTION OF PROJECT COMPONENTS 7.1 Power Line Servitude Each 132 kV Power Line requires a servitude of 36 m wide. The proposed power lines for this project will be built in parallel alignment. The total servitude width for the seven power lines will thus be 252 m. 7.2 132 kV Towers The proposed power lines will consist of twin turn cables capable of distributing up to 200 MVA at 132 kV, connected by a series of towers (pylons) located approximately 200 m apart, depending on the terrain and soil conditions. The exact tower type to be used will be determined (based on load calculations) during the final design stages of the power line. At this stage, it is proposed that either the Guyed Lattice or Steel Monopole tower type will be used for the proposed power lines. Such a tower is typically 18 m in height and each tower will have a footprint of between 1.21 m² and 16.81 m². 7.3 Access Roads Existing farm roads will be used to access the servitude for construction purposes. A maintenance road of 5 m wide within the servitude will be retained post construction for maintenance of the power line during the operational phase. 7.4 Fencing, Gates and Access Control The power line servitude will be fenced with a diamond mesh fence approximately 1, 8 m height to prevent unauthorised access for reasons of safety and security. 7.5 Expansion of the existing Pongola Substation and Candover Switching Station The expansion of the existing Pongola Substation and Candover Switching Station will involve expanding the foundation of the substation and the erection of additional bays to take in the new line: Expansion of fence line; Construction of terrace and foundations; Assembly and erection of new bays; Rehabilitation of disturbed areas; and Testing and commissioning. ZITHOLELE CONSULTING 13 8 CONSTRUCTION ACTIVITIES The Construction Phase for the proposed project will take 60 months to complete (from the time Environmental Authorisation has been received). The Construction Phase for the proposed project will include the following activities: Construction camps will be sited in areas where the least disturbance to potentially sensitive environments will be caused; If Ready-mix concrete is not available, small mobile batching plants will have to be established in the area close to the power line; Access will have to be created in places to allow for large construction vehicles to gain access to the proposed servitude; A 36 metres wide servitude is required for the proposed 132kV power line. Trees and shrubs will be cleared where required along the entire length of the servitude for access, erection of the pylons and stringing of the conductor (the vegetation will also be maintained by Eskom during the Operational Phase); During construction the route will be surveyed, pegged and the soil nominations excavated for each and every pylon foundation; Foundations will be laid for the footings of the pylons. The first step is the excavation of the pylon foundations, the reinforcing thereof and finally the concreting of the foundations. The equipment required to excavate the foundations can be manual labour, a Tipper Loader Backhoe (i.e. TLB). In the case of hard rock a drilling rig or blasting may be required to excavate the foundations. The concrete will be transported via concrete trucks to the required locations; The towers will be erected in piece-meal; that is to say in segments. After the foundations and footings have been installed the construction team will transport the various steel parts of the towers to the site and either assemble the pylons lying down on the ground or from the base upwards. This process again requires a lot of manual labour and mobile cranes are used to assembly towers which have been assembled lying down; Once the towers have been assembled, the conductors and shield wire/s will be strung between the towers. Once stringing and tensioning is complete the line is considered constructed, where after it will be tested prior to being commissioned; Rehabilitation of disturbed areas and protection of erosion sensitive areas; and Testing and commissioning. 9 OPERATIONAL ACTIVITIES During the Operational Phase and Maintenance Phase of the project, Eskom SOC Limited requires access to the servitude for maintenance activities which may include repairs and replacement of various hardware on the towers and the conductor and, in very rare cases, repairs to the foundations. ZITHOLELE CONSULTING 14 10 DECOMMISSIONING ACTIVITIES During the Decommissioning Phase the following activities will be carried out: The physical removal of the power line infrastructure would entail the reversal of the construction process; A rehabilitation programme would need to be agreed upon with the landowners (if applicable) before being implemented; and Materials generated by the decommissioning process will be disposed of according to the Waste Hierarchy i.e. wherever feasible, materials will be reused, then recycled and lastly disposed of. Materials will be disposed of in a suitable manner, in a suitably licensed facility. All of the aforementioned decommissioning activities would be subject to a separate Environmental Authorisation Process at the appropriate time. 11 SCOPE OF THE ENVIRONMENTAL MANAGEMENT PROGRAMME This EMPr is applicable to the construction phase of the project only. The EMPr must be read in conjunction with the BAR and EA issued for the project. 11.1 Integration of the Environmental Management Programme into the Contract As mentioned in Section 2, this EMPr has been written in a form and language that is consistent with the tender / contract documentation used for engineering contracts i.e. the EMPr takes the form of a set of environmental specifications that can integrate with the civil, mechanical and electrical tender / contract documentation. There are various advantages to this approach: The Contractor is made aware of the EMPr at the tender stage; The Contractor is able to cost for compliance with the EMPr; The EMPr is presented to the Contractor in the language and terminology with which he/she is familiar, and unnecessary duplication and contradiction is eliminated; Inclusion of the EMPr within the contract ensures that the EMPr becomes a legally binding document within a well-developed legal framework; and The standardised form and structure of the environmental specifications ensures that with time and each new contract, the Contractor becomes increasingly familiar with, and thus more accepting of, the EMPr and implements it with the same diligence as any other set of specifications contained within the contract. Ultimately, by measuring compliance against an explicit set of environmental controls that are well located within a robust legal framework, the approach has been proven to enhance success in the implementation and enforcement of the EMPr significantly. ZITHOLELE CONSULTING 15 11.2 Specification structure and Application These specifications are not exclusive and could, within reason, be expanded on or amended at any time during the contract by the Environmental Control Officer (ECO). 11.2.1 Method statements Environmental practitioners are not specialists with regard to construction techniques. Therefore, so as not to hinder construction activities by stipulating elaborate, costly and/ or ineffective mitigation measures, the environmental specification is underpinned by a series of Method Statements, within which the Contractor is required to outline how they propose to mitigate any identified environmental risks. For example, if the specification states that “cement contaminated water shall not be allowed to contaminate the soil or adjacent watercourse”, the Method Statement compiled by the Contractor would be required to outline how he or she intends to achieve this requirement. In terms of the environmental specifications for the proposed 132 kV power lines, the Contractors must submit various written Method Statements to the Engineer and ECO as requested in the Specification. For the purposes of the environmental specifications, a Method Statement is defined as “a written submission by the Contractor to the Engineer in response to the Specification or a request by the Engineer, setting out the materials, labour and method the Contractor proposes using to carry out an activity, identified by the relevant specification or the Engineer when requesting the Method Statement, in such detail that the Engineer is enabled to assess whether the Contractor's proposal is in accordance with the Specifications and/or will produce results in accordance with the Specifications”. The Method Statement must cover applicable details with regard to: Retrofit (Construction) procedures, Materials and equipment to be used, Getting the equipment to and from site, How the equipment/ material will be moved while on site (including crane operation), How and where material will be stored, Removal of construction related waste, The containment (or action to be taken if containment is not possible) of leaks or spills of any liquid or material that may occur, Timing and location of activities, Removal of fauna and flora; Removal of bees on site; Removal of snakes on site; Compliance/ non-compliance with the Specifications, and Any other information deemed necessary by the Engineer. ZITHOLELE CONSULTING 16 The environmental specifications set very stringent requirements in terms of the provision of Method Statements and the commencement of the activities they cover: Any Method Statement required by the Engineer/ECO or the specification must be produced within the timeframes specified by the Engineer or the specification (typically two weeks); The Contractor may not commence the activity covered by the Method Statement until it has been approved, except in the case of emergency activities and then only with the consent of the Engineer; The Engineer may require changes to a Method Statement if the proposal does not comply with the specification or if the proposed methodology carries an unreasonable risk of excessive damage to the environment; Approved Method Statements must be readily available on the site and must be communicated to all relevant personnel; The Contractor is required to carry out the activities covered by the Method Statement in accordance with the proposed approach; and Approval of the Method Statement does not absolve the Contractor from their obligations or responsibilities in terms of the Contract. 11.2.2 Site documentation and record keeping The following documents must be kept on site: Access negotiations and physical access plans; Site instructions; Pre-construction audit report; Complaints register; Records of all remediation / rehabilitation activities; Copy of this EMPr; Copy of the Environmental Authorisation; Monthly compliance report; Environmental training records; Emergency response procedures. The monthly compliance report should include: Complaints received from affected parties and details of the actions taken; Environmental incidents, spills of hazardous substances, etc. Environmental damage which requires rehabilitation; Damages of private property such as buildings or crops. ZITHOLELE CONSULTING 17 12 ENVIRONMENTAL AWARENESS TRAINING Training is required for all personnel involved in the proposed project. This includes all employees working on the site including temporary labourers, contractors and subcontractors. The Environmental Awareness Training should cover the following: The importance of the EMPr; Specific details of the EMPr; Employees role in compliance with the EMPr; Environmental effects associated with the activities; Training targeted at specific personnel for example operators of heavy machinery; The environmental impacts, actual or potential, of their work activities; The environmental benefits of improved personal performance; Their roles and responsibilities in achieving conformance with the environmental policy and procedures; Emergency preparedness and response requirements; The potential consequences of departure from specified operating procedures; The mitigation measures required to be implemented when carrying out their work activities; Environmental legal requirements and obligations; Details regarding floral/faunal species of special concern and protected species, and the procedures to be followed should these be encountered; The impacts and consequences of poaching of animals or removal of indigenous vegetation; The importance of not littering; The importance of using supplied toilet facilities; The need to use water sparingly; Details of and encouragement to minimise the production of waste and re-use, recover and recycle waste where possible; and Details regarding archaeological and/or historical sites which may be unearthed during construction and the procedures to be followed should such be encountered. Training should be conducted by a suitably qualified person and if necessary in more than one language to ensure it is understood by all workers. Copies of the environmental training must be available on site in languages appropriate to the work force. Records of training session including attendance, nature of training and date of training should be kept to ensure all staff members have received the necessary training. In addition to training, general environmental awareness must be fostered among the project’s workforce to encourage the implementation of environmentally sound practices throughout its duration. Environmental awareness and training is an important aspect of the implementation of the EMPr. Environmental awareness could be fostered in the following manner: Induction course for all workers on site, before commencing work on site. ZITHOLELE CONSULTING 18 Refresher courses as and when required. Daily toolbox talks at the start of each day with all workers coming on site, where workers might be alerted to particular environmental concerns associated with their tasks for that day or the area/habitat in which they are working. Courses must be given by suitably qualified personnel and in a language and medium understood by workers/employees. 13 PROVISIONS FOR ADDRESSING NON-CONFORMANCE Ultimately, the key to construction phase is ensuring that the requirements of the EMPr are adequately and appropriately implemented on site. Accordingly, monitoring performance and addressing non-compliance are key attributes of any environmental interventions. Part D addresses the actual process for identifying and addressing non-compliance, whilst this section provides an overview of the provision made for this in the environmental specification. Broadly, the mechanisms for addressing non-compliance that are provided for in the environmental specifications and associated contract documentation can be divided into the following categories: Controlling performance via the certification of payments; Requiring the Contractor to “make good”, at their own cost, any unjustifiable environmental degradation; and Implementing a system of penalties to dissuade environmentally risky behaviours; and Removing environmentally non-compliant staff/ plant from site, or suspending part or all of the activities on site. 14 ENVIRONMENTAL CONSIDERATIONS IN ADJUDICATION OF TENDER In terms of this EMPr, Eskom has an obligation to ensure compliance by various parties with a suite of environmental requirements related to the construction phase. To ensure that these obligations continue to be fulfilling during the actual construction processes, it requires the Eskom team to ensure that the appointed Contractors possess the requisite environmental management experience and expertise. Accordingly, it would be prudent for the Eskom team to ensure that environmental considerations form part of the contractual process undertaken during the appointment of contractors and consultants. Key considerations in this regard would be as follows: To request on appointment that the Contractor provide his environmental policy and indicate how this will influence the way the construction process is approached and managed on site. At the tender stage the Contractor would merely be asked to provide the overarching environmental policy for the Company or Joint Venture; To request as part of the tender process a list of the Contractor’s previous experience in terms of the onsite implementation and management of environmental requirements; ZITHOLELE CONSULTING 19 To request as part of the tender process an indication of the proposed organisational structure for the Contract, and specifically for the Contractor to indicate which staff would be acting in the capacity of Environmental Officer (EO) and which senior staff member would have overall responsibility for ensuring compliance by the Contractor with the specified environmental requirements; and To confirm, upon receipt of the Tender, that the Contractor has made sufficient allowance in his Tender Price for meeting the various environmental requirements. During the tender adjudication process for each Contract, each Contractor should be scored in terms of the aforementioned considerations and allocated an environmental competency score. This score should form a key consideration in the final decision-making regarding the award of the various contracts. 15 ENVIRONMENTAL MANAGEMENT MEASURES FOR THE PROJECT The management measures documented in each of the sub-sections below have been compiled using the following information: Impact Assessment and mitigation measures documented in the BAR for the proposed 132 kV power lines; and Mitigation and management recommendations provided by the specialist studies. In addition to the abovementioned information sources, the EMPr will be updated to include the conditions documented in the Environmental Authorisation (EA) to be received upon approval of the Basic Assessment (BA). 15.1 Planning Phase To mitigate the negative environmental impacts, a number of measures would have to be addressed in the design of the salvage during the planning phase. An inspection must be carried out on the design before commencement of the upgrade in order to ensure that the mitigation measures have been incorporated in the design. ZITHOLELE CONSULTING 20 Table 2: Impacts, Management / Mitigation Measures during the Planning Phase Planning Phase Environmental Consideration Training and Health and Safety Mitigation Measures Eskom is to appoint an ECO Introduce the ECO to the Project Team. Training of the Contractor’s employees on the EMPr Elucidation of environmental monitoring protocol to the Project Team by the ECO. Project Manager Project Manager ECO All correspondence from ECO must be filed and kept on site. Staff responsible for construction should be issued with the appropriate PPE and trained in safe working procedures concerning the various processing action. In consultation with the ECO, demarcate the suitable site identified for the laydown area. The site office as well as parking areas for construction vehicles should be confined to disturbed areas, away from drainage lines. Chemical toilets must be provided at a ratio of at least one per 15 employees in terms of ablution facilities. Chemical toilets must be serviced and emptied on a regular basis to avoid leaks and spillage. Camp sites must be negotiated with the land owner. No fires or dumping of waste to take place at the camp sites. Landowners must be notified and negotiated with where construction camps may be established on their property. Access procedures to privately owned land must be negotiated with the land owners. No chemical toilet may be within 100 m of a natural water body. Identify suitable hazardous/general Waste Disposal Sites which will accept waste material to be generated. Provide a plan for the collection, storage and transport of waste a recognized landfill site. All metal off-cuts and metal waste must be recycled. Local suppliers must be used, as far as possible; and Local labour should be employed. Communicate in a cultural sensitive way the next phase of project. Communicate process in language of choice. Ensure that the retrofit is designed to fit inside the existing casing. Ensure that all machinery on site is in a good working order. Project Manager and ECO Project Manager Construction Camp/laydown area Waste Social Designs Vehicles Responsible Party(ies) ZITHOLELE CONSULTING Contractor and the ECO Project Manager, Contractor Project Manager, Contractor Eskom and Contractor Eskom Contractor 21 Planning Phase Environmental Consideration Mitigation Measures Responsible Party(ies) Identify areas where known nesting grounds are located and avoid taking access roads near these areas. Sensitise employees to issue. Ensure all construction remains in minimal footprint area. Ensure access roads clearly marked and adhered to at all times. The exact locations of the towers along the power line route alignment within the corridor should be determined in consultation with an appointed Avifauna Specialist; An Avifauna Specialist should be advised regarding the proximity of the power line route alignment to habituated feeding sites (i.e. Vulture Restaurants); Factors taken into account when selecting the tower design must include the risk of electrocution of birds posed by each tower design; It is recommended that reflectors with LED lights should also be used particularly near nest sites and on the western and eastern routes that lie in relatively close proximity to water; Avifauna Appoint an avifauna specialist to provide recommendations regarding the placement of Bird diverters; Pylons should preferably be positioned so as to alternate with those of the existing power line (i.e. out-of-step) and not be placed opposite one another (in-step). This mitigation will increase the visibility of both sets of power lines to flying large raptors and the birds may then be in a better position to take timely collision avoidance action. Where the possibility or risk of a 'flash-over' might occur it is then essential that additional mitigation measures that would increase the visibility of the power line be instituted should towers be positioned 'in-step'; and The Delta pylon design preferably should not be used. A re-design of the Delta type tower that avoids any risk of electrocution to birds could be considered and may be acceptable. The principle would be to place the live conductors further away from the lower arm that is, at a distance greater than the wing span of a vulture (i.e. > 2.5 m). ZITHOLELE CONSULTING Contractor and Eskom 22 Planning Phase Environmental Consideration Mitigation Measures Responsible Party(ies) Select route within corridor least likely to impact on heritage sites. Appoint heritage specialist at design phase to assist with identification of sites and placement of towers. Avoid location of towers on or near heritage sites; Prior to the commencement of the Construction Phase the holder of the Environmental Authorisation must appoint an accredited Heritage Specialist to conduct a phase I Paleontological Assessment as the area is known to be rich in fossil finds; An Amafa accredited Archaeologist must to do a walk down of the final route alignment and tower placements before construction activities commence; The final route should be confined to the most feasible alignment within the western and northern route alignments. The Archaeologist in conjunction with the Palaeontologist should compile a Cultural Heritage Management Plan (CHMP) to ensure that heritage resources are not inadvertently damaged. The CHMP and Palaeontology Assessment should also include cover access roads and site camps. The Paleontological Report and CHMP should be furnished with Amafa and Amafa will Heritage issue further comment thereafter. The Construction Activities should only proceed once Amafa has reviewed the CHMP and issued a written approval; Amafa should be contacted if any heritage objects are identified during earthmoving activities and all development should cease until further notice; and No structures older than sixty years or parts thereof are allowed to be demolished altered or extended without a permit from Amafa. Ensure access plan detailing exact access routes is developed prior construction. Appoint heritage specialist to review proposed access plan and routes to verify that they do not pass through or close to heritage sites; and The final route should be confined to the most feasible alignment within the western and northern route alignments. The Archaeologist in conjunction with the Palaeontologist should compile a Cultural Heritage Management Plan (CHMP) to ensure that heritage resources are not inadvertently damaged. The CHMP and Palaeontology Assessment should also include cover access roads and ZITHOLELE CONSULTING Eskom 23 Planning Phase Environmental Consideration Mitigation Measures site camps. The Paleontological Report and CHMP should be furnished with Amafa and Amafa will issue further comment thereafter. The Construction Activities should only proceed once Amafa has reviewed the CHMP and issued a written approval. ZITHOLELE CONSULTING Responsible Party(ies) 24 15.2 Construction Phase Sub-transmission lines are constructed in the following simplified sequence: Table 3: Construction Process for sub transmission lines Step Sequence Step 1: Determination of technically feasible alternatives Step 2: Basic Assessment input into route selection and obtaining of relevant environmental permits and Authorisations Step 3: Negotiation of final route with affected landowners Step 4: Apply for necessary permits and licenses for vegetation clearance Step 5: Survey of the route Step 6: Selection of best-suited structures and foundations Step 7: Final design of sub-transmission line and placement of towers Step 8: Issuing of tenders and award of contract to construction companies Step 9: Vegetation clearance and construction of access roads (where required) Step 10: Pegging of structures Step 11: Construction of foundations Step 12: Assembly and erection of structures Step 13: Stringing of conductors Step 14: Rehabilitation of disturbed area and protection of erosion sensitive areas Step 15: Testing and commissioning Step 16: Continued maintenance ZITHOLELE CONSULTING 25 Table 4 : Impacts, Management/ Mitigation Measures during Construction Phase Construction Phase Environmental Consideration Mitigation Measures Soil Air Quality Fauna and Flora Salvage and stockpile topsoil (top 30 cm of the soil profile). This soil can be returned to the construction area to encourage vegetation growth; Topsoil shall not be stored higher than 1.5 m. Avoid unnecessary removal of vegetation cover; Use existing access roads as far as possible; If a new road is constructed, ensure that the Eskom erosion prevention guideline is followed and adhere to the Eskom tower construction specification TRMSCAAC1 Rev 3; Take land use into consideration when choosing pylon types, it is recommended that smaller footprint pylons be used in cultivated areas; Avoid placement of pylon footings in clay soils as well as on dunes, towers to be sited in between dunes in the so-called dune-streets; Avoid the construction of access roads through dunes; Spread absorbent sand on areas where oil spills are likely to occur, such as the refueling area in the hard park; Oil-contaminated soils are to be removed to a contained storage area and bio-remediated or disposed of at a licensed facility; Use berms to minimise erosion where vegetation is disturbed, including hard parks, plant sites, borrow pit and office areas; If soils are excavated for the footing placement, ensure that the soil is utilised elsewhere for rehabilitation/road building purposes; and Ensure that soil is stockpiled in such a way as to prevent erosion from wind/storm water. Vehicles to be properly maintained to avoid unnecessary emissions. The proposed construction operator should control on-site dust emissions by effective management and mitigation according to the existing procedures for the power lines. Construction vehicles must travel at low speeds to reduce the effect of dust. Where necessary spraying of haul roads with water or dust suppressant must be carried out to reduce dust generation. A walk through of the selected alignment as well as tower positions should be conducted by a suitable qualified botanist as well as zoologist in order to ascertain for the presence of any threatened, protected, endemic or plant or animal species of special concern within or in close proximity to the construction areas (tower supports) for the presence of any animal burrows (including spiders and scorpions), rocky outcrops, logs, stumps and other debris and relocate any affected animals to appropriate habitat away from the servitude or tower. ZITHOLELE CONSULTING Responsible Party(ies) Contractor and ECO. Contractor Contractor/ECO 26 Construction Phase Environmental Consideration Mitigation Measures Social Protected trees within the servitude will necessitate that appropriate permits are applied for before these trees are damaged or removed. General mitigation measures would include the avoidance of any physical damage to natural vegetation on the periphery of the proposed servitude and is of particular importance in all riparian areas and areas of steep slopes. No construction activity or disturbance to vegetation or habitat is to take place within 50m of a delineated wetland or riparian zone. No hunting permitted by Eskom employees or contractors. All construction areas should be demarcated prior to construction to ensure that the footprint of impacts are limited. All alien invasive species on site should be removed and follow up monitoring and removal programmes should be initiated once construction is completed. Adhere to the Eskom vegetation management guideline. The ECO should identify any sensitive species or habitats along the servitude, particularly in relation to large terrestrial species and notify the faunal specialist of these so that he can advise on how best to handle these. The construction of new access roads should be limited. All vehicle and pedestrian movement should be restricted to the actual construction site and servitude. Removal of plants should be restricted to only those trees that pose a risk to the power line. Sensitive alluvial vegetation should be avoided and construction restricted within 50m from the edge of an endangered habitat. Roads should be maintained or improved on. Have a trained first aid person on site. No squitter camps should be erected near construction camps. HIV/AIDS awareness training must form part of the induction of staff. Condoms must be freely available. Access to construction camps should be security controlled. ZITHOLELE CONSULTING Responsible Party(ies) Eskom, Contractor 27 Construction Phase Environmental Consideration Aesthetics Mitigation Measures Noise Heritage Resources Construction Materials Sound housekeeping and waste management measures to be employed. Location of construction camp to be determined by ECO to minimise visual intrusion. Construction material to be stored in a neat and safe manner, in designated areas. Waste should be restricted to storage in specifically designated areas, and removed daily. Any complaints regarding the appearance of the construction site must be recorded and addressed promptly. Ensure that all litter and pollution is cleared from the site (including remaining building rubble). All machinery to be maintained and fitted with equipment to reduce noise levels. Laborers to be provided with hearing protection (PPE). No loud music allowed from the construction camp or anywhere else within the work footprint. Construction working hours should be limited to 06:00 to 17:00 from Monday to Saturday with no construction taking place on Sundays. Placement of infrastructure should avoid potential sites of high archaeological sensitivity such as pans, rocky ridges and river beds. Where bedrock is disturbed there should be paleontological monitoring in order to identify any potential sensitive areas that may be exposed. Any cultural, archaeological or paleontological sites that are identified during construction should be reported to SAHRA / Amafa and investigated by a Heritage Resources expert. On uncovering a possible grave or burial site, it is imperative that construction cease The grave must be fenced off and SAHRA / Amafa must be notified immediately. Construction material must be stored under a roof or inside a suitable container. The construction material must be mixed in designated areas, on impermeable surfaces. The batching plant must be bonded to prevent storm water entry, and to contain dirty water. Material must be stored in a safe and neat manner. Site offices, parking areas for construction vehicles should be confined to disturbed areas. Mixing of concrete/cement must take place on impermeable surface, or where it is happening on site on a plastic liner. All concrete spills must immediately be cleaned up. Oil spill kits must be available on site. ZITHOLELE CONSULTING Responsible Party(ies) Contractor; Contractor and Eskom Contractor, Eskom and ECO. Contractor and ECO 28 Construction Phase Environmental Consideration Mitigation Measures Responsible Party(ies) Occupational Health and Safety Waste All projects must be conducted in accordance with the Occupational Health and Safety Act (Act 85 of 1993). The contact details of the Safety Officer/Representative should be provided to the ECO. Safety induction must be expanded to include environmental risks and mitigation measures. Fire prevention: At least two staff of the site contractor should be trained or be proficient in firefighting and prevention, and at least one staff should be on site at all times. Adequate firefighting equipment should be available on site at all times. The Contractor must take all the necessary precautions to protect the materials on site and to avoid fires. No waste material may be burnt. Designated areas must be provided, where smoking can occur in a controlled environment. A firebreak must be put around the construction camp. Provide area with relevant warning signage (e.g. no smoking and open fires, fire extinguisher). Littering on site and the surrounding areas is prohibited. Clearly marked litterbins must be provided on site. All bins must be cleaned of litter regularly. All general waste will be removed and disposed of at a registered Waste Disposal Site. The contractor must install and maintain mobile chemical toilets at work sites if existing facilities are not available. Drip trays must be used under all machinery, including generators and vehicles. Sanitation Infrastructure, Vehicles and Plant Equipment Under no conditions may the surrounding areas be used for ablution purposes. Sufficient chemical toilets to be provided (if no existing facilities are available). Chemical toilets to be placed at strategic points (with minimal visual impact). Chemical toilets must be professionally serviced and emptied on a regular basis. Chemical toilets must be provided at a ratio of at least 1 toilet per 15 employees on site. The equipment and plant to be used at for the power line construction must be suitable for the application and prevailing site conditions, of adequate rated capacity, in good working condition, and shall be so designed and constructed as to cause minimum environmental pollution. The plant, vehicles and equipment necessary for the operation shall be properly maintained and the vehicles serviced at the required service intervals to ensure road worthiness. All vehicles are inspected on a daily basis for roadworthiness. ZITHOLELE CONSULTING Contractor Contractor Contractor Contractor 29 Construction Phase Environmental Consideration Mitigation Measures Responsible Party(ies) Stakeholder Liaison Vegetation Access to the servitude and construction site must be negotiated with the landowners. Construction camp establishment on privately owned land must be negotiated with the land owner. All gates to privately owned land must be closed and/or locked at all times to minimize the disturbance to the land owner. Land owners should be notified when Eskom staff will be active on their property and when that activity will cease. Any changes to these schedules should be communicated to the land owner. An agreement will be drawn up between the Reserve and an Eskom SOC Limited negotiator. The agreement will provide details regarding consensus that is reached between the Reserve and Eskom regarding the scheduling of Construction Activities and the implication thereof on the hunting season. Vegetation clearing should be: o Limited to 8m within the working area; and o Vegetation should only be removed from the minimum required construction and / or working area, within the servitude. The removal of vegetation from the required working area within the servitude, should be done in accordance with Eskom’s Vegetation Management and Maintenance within Eskom Land, Servitudes and Rights of Way Standard (240- 70 0172585). ZITHOLELE CONSULTING Eskom Eskom & Contractor 30 15.3 Operational Phase Once construction of the power lines have been completed, the proposed operation is to be undertaken according to the existing operating procedure and associated procedures for transmission lines by Eskom. The Responsible Party from Eskom will monitor the activities of the operational team on site to ensure all mitigatory measures are implemented and to prevent any additional impacts from occurring. Alien vegetation, as well as indigenous invasive species such as Dicrostachys cinerea must be controlled and eliminated on a regular ongoing basis along the cleared working area within the servitude during the operational life of the power line. An annual Project Compliance Audit should be undertaken, which should focus on the adherence to the procedures. ZITHOLELE CONSULTING 31 16 ENVIRONMENTAL ASPECT AND IMPACT REGISTER All environmental aspects as well as environmental impacts that are associated with the Proposed New Golela Substation and two Associated 132kV Turn-In Lines from the existing Mkuze-Pongola 132kV Power Line Project is tabulated below. An environmental aspect is defined as an “element of an organization’s activities or products or services that can interact with the environment” while an environmental impact is defined as “any change to the environment, whether adverse or beneficial, wholly or partially resulting form an organization’s environmental aspects” (ISO314001:2004). The table below considers all Environmental Aspects and Environmental Impacts throughout the Project Lifecycle of the proposed project. Table 5: Environmental Aspects and Impacts Register No. 1. 3 Project Lifecycle Phase Planning and Design Phase Environmental Aspect Environmental Impact Mitigation Measures Determining the location of each tower along the power line route alignment and substation. The towers may be placed on or extend through areas in which heritage and / or archaeological resources may be found. As the study area and surrounds have a rich historical and archaeological history, the construction of the towers and access roads may in result in damage to burried and / or unexposed heritage and / or archaeological resources. Select route within corridor least likely to impact on heritage sites; Appoint heritage specialist at design phase to assist with identification of sites and placement of towers; and Avoid location of towers on or near heritage sites. ISO: International Standards Organisation ZITHOLELE CONSULTING 32 No. 2. 3. Project Lifecycle Phase Planning and Design Phase Planning and Design Phase Environmental Aspect Environmental Impact Mitigation Measures Determining the alignment and location of access roads. The access roads may be extend through areas in which heritage and / or archaeological resources may be found. As the study area and surrounds have a rich historical and archaeological history, the construction of the towers and access roads may in result in damage to burried and / or unexposed heritage and / or archaeological resources. Ensure access plan detailing exact access routes is developed prior construction; and Appoint heritage specialist to review proposed access plan and routes to verify that they do not pass through or close to heritage sites. The natural habitat along the entire length of the access road will be transformed largely by the removal of vegetation. Select the route within corridor that requires least amount of invasive road construction works; Access plan to be developed prior to the commencement of construction as a means of ensuring that only access routes which will require minimal cutting; and Repair existing access routes before establishing / constructing new access routes. Determining the alignment and location of access roads and substation. ZITHOLELE CONSULTING 33 No. 4. Project Lifecycle Phase Planning and Design Phase Environmental Aspect Determining feasible alternative power line route corridors and substation. Environmental Impact Mitigation Measures The positioning of the towers and power lines in areas where high bird activity has been recorded will amplify the risk of bird electrocution and collisions with the conductors. The exact locations of the towers along the power line route alignment within the corridor should be determined in consultation with an appointed Avifauna Specialist; An Avifauna Specialist should be advised regarding the proximity of the power line route alignment to habituated feeding sites (i.e. Vulture Restaurants); Factors taken into account when selecting the tower design must include the risk of electrocution of birds posed by each tower design; It is recommended that reflectors with LED lights should also be used particularly near nest sites and on the western and eastern routes that lie in relatively close proximity to water; Appoint an avifauna specialist to provide recommendations regarding the placement of Bird diverters; and For the northern route, pylons should preferably be positioned so as to alternate with those of the existing power line (i.e. out-of-step) and not be placed opposite one another (in-step). This mitigation will increase the visibility of both sets of power lines to flying large raptors and the birds may then be in a better position to take timely collision avoidance action; and Where the possibility or risk of a 'flash-over' might occur it is essential that additional mitigation measures that would increase the visibility of the power line be instituted should towers be placed. ZITHOLELE CONSULTING 34 No. Project Lifecycle Phase Environmental Aspect Environmental Impact Planning and Design Phase Determining feasible alternative power line route corridors and substation. The routing of the power line through areas which are known as suceptable to electrocution or collision, will increase the possibility of death and / or injury of birds by electrocution and / or collisions with the power line. 6. Planning and Design Phase Determining the location of each tower along the power line route alignment and substation. As the working area and footprint of the tower cannot be utilised for any other use whilst the tower structure remains, the possibility of utilising the land for agricultural purposes will be lost. 7. Planning and Design Phase Determining feasible alternative power line route corridors and substation. The visibility of the power line may give rise to a visual disturbance on tourism route / operations and residential homes. 5. ZITHOLELE CONSULTING Mitigation Measures Ensure tower design and type is best for preventing the electrocution of birds and discourages the roosting of birds on the structures; It must be ensured that suitable bird repelling structures, such as bird guards are considered in the design; and Ensure that the cross arms of the tower structures in areas of heavy bird activity (such as wetlands and vulture nesting grounds and vulture restaurants) are all fitted with antiroosting spikes. Where possible the placement of towers within crop lands must be avoided; and The construction footprint must be confined to the smallest require area, not exceeding a width of 16 meters. Where possible avoid placing towers in the view of sight from front of homesteads, lodges; Keep towers below escarpments or hills to ensure visual obscuring. In the case of the northern corridor tower spacing should match existing line; The placement of towers in static view areas, where the relationship between the proposed power line and the landscape remains unchanged should be avoided. Examples of static views includes views from a farmhouse, lodge and homestead; and Provided that Environmental Authorisation is granted for the Northern Corridor, the new towers should be placed adjacent to the existing towers to reduce and confine the visual impact to the disturbed area. 35 No. 8. 9. Project Lifecycle Phase Planning and Design Phase Planning and Design Phase Environmental Aspect Environmental Impact Determining feasible alternative power line route corridors and substation. All indigenous vegetation as well as endangered / protected species within the selected corridor and construction footprint will be cleared thereby resulting in: Loss of species of conservation importance; Habitat loss and degradation; and Habitat fragmentation and transformation. Determining feasible alternative power line route corridors and substation. The power line extending through a conservation, ecological sensitivity and / or protected area will negatively impact on the pristineness of the area and introduce adverse environmental impacts such as the loss of vegetation within the working area. ZITHOLELE CONSULTING Mitigation Measures Select corridor and route least likely to impact on indigenous vegetation; Where possible locate towers and alignment in areas of least dense indigenous bush and tree cover to minimise the amount of bush clearing required; Also attempt to select a route where minimal bush clearing is required for the purposes of access; Where possible locate towers and alignment in areas identified as consisting of species typical and numerous in the area. Make use of specialist during alignment and identification of access routes to achieve this; Select corridor and route least likely to require habitat transformation though excessive bush clearing or platform cutting (soil disturbance); Where possible towers along the power line route alignment should be placed in areas where the habitat has been transformed and / or disturbed; and Use specialist to identify rare and endangered species and to assist in aligning power line and placement of towers within corridor to reduce potential for impact on rare endangered species. Select corridor and route least likely to introduce new impact in previously nonimpacted conservation areas; If possible, the selected power line corridor route should bypass / avoid any a conservation, ecological sensitivity and / or protected areas; and Where the selected power line corridor route cannot bypass / avoid any a conservation, 36 No. Project Lifecycle Phase Environmental Aspect Determining feasible alternative power line route corridors and substation. Conducting the Basic Assessment Process for the proposed project as part of the Environmental Authorisation Process. Environmental Impact Introduction of a non-compatible land use into an area due to inappropriate alignment of the power line. 10. Construction Phase 11. Construction Phase 12. Construction Phase Excavation foundations. 13. Construction Phase The movement of construction vehicles and construction activities may disrupt breeding activities and alter the specific conditions for breeding within the area. Disturbance of breeding activities of local birds. 14. Construction Phase Construction of towers within croplands. Vegetation clearing surrounding towers will result in the loss of crops within the construction footprint. of the pylon Strengthening of the grid will ensure uninterrupted electricity supply in Northern Zululand. Damage to or destruction of archaeological and heritage sites as a result of construction activities. ZITHOLELE CONSULTING Mitigation Measures ecological sensitivity and / or protected areas the working area and extent of the power line must be confined to the absolute minimum area. Select corridor and route within corridor least likely to introduce new incompatible land use into new areas. The new 132kV power line must be constructed to strengthen the grid of the region and to ensure the success and efficiency of all the other grid strengthening activities that are being planned in the region. Ensure all identified sites are clearly demarcated prior to construction and that all persons on site are sensitised to the issue and the significance; Stop work if new archaeological or heritage site exposed during construction; and Notify the provincial heritage authority of the discovery of any exposed archaeological or heritage site. Identify areas where known nesting grounds are located and avoid taking access roads near these areas; Ensure that the Environmental Awareness Training provided to the employees address the required measures to prevent disturbance of the breeding activities of birds; Ensure all construction remains in minimal working area; and Ensure access roads clearly marked and adhered to at all times. Negotiate access to agricultural lands with landowner; 37 No. Project Lifecycle Phase Environmental Aspect Environmental Impact Mitigation Measures 15. Construction Phase Construction of power line and substation. The visibility of the construction of the power line may give rise to a visual disturbance on tourism route / operations and residential homes. 16. Construction Phase Construction activities undertaken during the hunting season and in close proximity to hunting concession game farms. Disturbance to hunting activities on hunting concession game farms. 17. Construction Phase Employment of local labour for the duration of Construction Phase. Creation of construction. 18. Construction Phase Clearing all vegetation within the construction footprint. temporary jobs during Loss of rare and endangered species due to bush clearing and access activities. ZITHOLELE CONSULTING Ensure that all construction activities remains within the minimum required working area; and Ensure access roads clearly marked and all vehicle movement is restricted to the demarcated access roads. Design and time construction activities in association with landowners to minimise the interference effects; and Landowners can arrange tourism activities to avoid construction area for duration of contract. Design and time construction activities in association with landowners to minimise the interference effects; and Landowners can arrange hunting activities to avoid construction area for duration of contract or can arrange with contractor to work elsewhere while hunters are on the property i.e. an operation plan to minimise impacts on the hunting season between May and October can be developed to suit landowner and contractor. Contractor to employ as many local labourers as is feasibly possible. Prior to the commencement of the Construction Phase an ECO should carry out a survey of the final route alignment to determine / identify specific sites along the route alignment where vegetation species of conservation importance (Red List and protected) are found; Prior to commencement of the Construction Phase, permits to remove all protected species within the route alignment must be applied for and obtained from the relevant national and/or provincial authority; and 38 No. Project Lifecycle Phase Environmental Aspect Environmental Impact 19. Construction Phase Clearing of all vegetation within the construction footprint. Loss of indigenous vegetation due to bush clearing and access activities 20. Construction Phase Selected alternative power line route corridors may extend through or within close proximity to the extent of the riparian area. Placing the towers within the riparian area will alter the characteristics of the associated watercourses and require the removal of riparian vegetation. 21. Construction Phase Movement of construction vehicles outside of the demarcated access roads. Uncontrolled vehicle access can result in unnecessary loss of indigenous and riparian vegetation. ZITHOLELE CONSULTING Mitigation Measures The relevant national / provincial authority must be consulted to determine any specific requirements which the authority may have and authorisations / permits required for the management of all species along the power line route which have been categorised by the IUCN Red List of Threatened Species as Near Threatened, Vulnerable, Endangered or Critically Endangered species. Ensure competent bush clearer appointed to clear alignments; Ensure only required clearing is undertaken; and Ensure area to be cleared is properly and clearly demarcated. Bush clearing through riparian areas must be kept to a minimum and must permit access on foot only i.e. clearance of a narrow strip only and selective trimming for the purposes of maintaining electrical clearances; Ensure all wetlands and streams along the power line route are identified; Access routes, laydown area, drum stations etc. will not be permitted within the buffer zones of any wetland; and The stockpiling of soil, topsoil or any other material will not be permitted within the watercourse, riparian area or within the 1:100 year flood line, so as to prevent the impediment of surface water flow. Ensure access routes are planned, clearly demarcated and suitable for the vehicles that will be using them; Ensure drivers are sensitised and disciplined to the issue; and 39 No. Project Lifecycle Phase Environmental Aspect 22. Construction Phase Clearing of natural vegetation may create conditions conducive to the establishment and colonisation of exotic and/or declared CARA Category 1, 2 and Category 3 invader plants. 23. Construction Phase Clearing of all vegetation within the construction footprint. Environmental Impact Establishment of exotic and / or declared Category 1, 2 and Category 3 invader species. The bare ground will be prone to erosion as a result of the vegetation clearing. Increased velocity of runoff across bare soil surface may result in soil erosion. ZITHOLELE CONSULTING Mitigation Measures Vehicle access through riparian or wetland system should as far as possible be limited to pre-existing formal access routes. Alien vegetation, as well as indigenous invasive species such as Dicrostachys cinerea must be controlled and eliminated on a regular ongoing basis along the cleared working area within the servitude during the operational life of the power line. Bush clearing may only occur through cutting or trimming; Breaking the soil through scalping or ploughing, except where the de-stumping of trees are necessary, should be avoided; Suitable erosion measures must be implemented in areas prone to erosion and should include: o Vegetation clearance within the working area should be undertaken within and restricted to an 8m vegetation clearance path; o Remove vegetation only as it becomes necessary for work to proceed; Prevent the unnecessary removal of vegetation; De-stumping of trees on stream and river banks will not be permitted; The site should be graded to ensure the free flow of run-off and to preventing the ponding of water; and Drainage must be controlled to ensure that runoff from the site will not culminate in off-site pollution or cause water damage to surrounding properties. 40 No. Project Lifecycle Phase Environmental Aspect within during Environmental Impact Mitigation Measures 24. Construction Phase Removal of topsoil construction footprint excavations. 25. Construction Phase Movement of construction vehicles across cleared areas. Hardening and compaction of soil can prevent the revegetation of an area and promote erosion. 26. Construction Phase Clearing of all vegetation within the construction footprint. Construction fragmentation construction. 27. Construction Phase The operation of equipment and implementation of construction activities which generate noise. Increased ambient noise levels. Vegetation removal can result in the loss of topsoil. activities will of habitats ZITHOLELE CONSULTING cause during Bush clearing may only occur through cutting or trimming; No scalping or ploughing will be permitted; and Topsoil removed from foundation sites or drum stations must be removed and stored for rehabilitation and protected from erosion during storage. All hardened surfaces will be ripped during the rehabilitation phase to assist with rapid vegetation re-establishment. Vegetation clearing must be limited by minimising clearance wherever possible; and The movement of all construction vehicles must be confined to demarcated access roads. All machinery to be maintained and fitted with equipment to reduce noise levels; Operations should occur during acceptable working hours; All noise complaints shall be recorded, investigated and rectified immediately; Unless agreed to by the particular landowner, construction camps and batching plants must be sited outside of conservation / game farms / nature reserve areas; During hunting season, negotiations to keep hunting concessions away from work areas will be required; and Contractor employees to be sensitised to requirement to keep all noise to a minimum. 41 No. Project Lifecycle Phase Environmental Aspect Environmental Impact Mitigation Measures 28. Construction Phase Vehicle and construction equipment activity. Exhaust emissions from construction vehicles and equipment as well as the dust generated by the movement of vehicles across bare soil surfaces thereby adversely impacting on the ambient air quality. 29. Construction Phase Movement of vehicles through dry grassland and workers starting open uncontrolled fires. Damage to receiving environment (e.g. loss of vegetation, injury to fauna) caused by fires. 30. Construction Phase Movement of construction vehicles to and from the Site Camp and construction area. Construction will result in increased traffic flow in specific routes in the region which may impact on other users. 31. Construction Phase Movement of construction vehicles to and from the Site Camp and construction area. Deterioration of public and private roads due to passage of construction vehicles. 32. Construction Phase Storage and use of hazardous substances. Spillage of hazardous substances into the natural environment ZITHOLELE CONSULTING Where sensitive environments are identified or complaints received, dust suppression must be implemented; Vehicle speeds must be limited to slow speeds (less than 30 km/h) on gravel roads and track; and Dust complaints must be recorded, investigated and addressed immediately. No open fires will be permitted on site; Smoking may only occur during controlled breaks at a designated smoking area with appropriate fire protection facilities; Long grass to be trimmed or flattened along access routes; and Contractor to join the local fire protection association. Construction vehicle drivers must be considerate to all other road users at all times. The frequency and number of trips taken by construction vehicles on public roads to and from the Site Camp and construction area should be kept as low as possible. All vehicles and equipment must be in good working order; Equipment/ vehicles with permanent leaks must be removed from site; Drip trays must be available with all vehicles and all areas where hazardous substances are being used; Hydro-carbons should be stored in a bunded storage area; All hazardous materials inter alia paints, turpentine and thinners must be stored 42 No. Project Lifecycle Phase Environmental Aspect Environmental Impact Mitigation Measures ZITHOLELE CONSULTING appropriately to prevent these contaminants from entering the environment; Spill-sorb or similar type product must be used to absorb hydrocarbon spills in the event that such spills should occur; Precautionary measures specific to the storage, handling and transport of hazardous materials must be formulated and implemented; and In the event of an event resulting in the pollution of surface / groundwater resources the Department of Water and Sanitation must be contacted. 43 No. Project Lifecycle Phase Environmental Aspect Environmental Impact Mitigation Measures 33. Construction Phase 34. Construction Phase 35. Operational Phase Poor waste management. Conducting the Basic Assessment Process for the proposed project as part of the Environmental Authorisation Process. Conductor failure or flash overs caused by bird streamers and / or lightning strikes. Pollution of receiving environment. Strengthening of the grid will ensure uninterrupted electricity supply in Northern Zululand. Ignition of veld due to conductor failure or flash overs ZITHOLELE CONSULTING An integrated waste management plan must be compiled during site establishment and must be implemented continuously throughout the construction phase; Demarcated areas where waste can be safely contained and stored on a temporary basis during the construction phase should be provided at the hard park; When adequate volumes (not more than 1 month) have accumulated all waste is to be removed from site and disposed of at a licensed facility; Waste may not to be buried on site; Hydro-carbons should be stored in a bunded storage area; All hazardous materials inter alia paints, turpentine and thinners must be stored appropriately to prevent these contaminants from entering the environment; Spill-sorb or similar type product must be used to absorb hydrocarbon spills in the event that such spills should occur; and Chemical toilets and / or any effluent treatment facilities may not be placed within the 1:100 year flood line and should be regularly emptied by a professional service provider. The new 132kV power line must be constructed to strengthen the grid of the region and to ensure the success and efficiency of all the other grid strengthening activities that are being planned in the region. Regular line inspections to ensure the integrity of the line. 44 No. Project Lifecycle Phase Environmental Aspect Environmental Impact Mitigation Measures 36. Operational Phase Avifauna collisions with power lines. Electrocution of avifauna and collisions with the conductor 37. Operational Phase Overgrown servitude. Overgrown servitude and electrical clearance problems associated 38. Operational Phase Poor maintenance of access tracks. Poor maintenance of access tracks results in erosion of these tracks. ZITHOLELE CONSULTING Ensure that all bird diversion structures recommended by the specialist remain in working order at all times; Bird diverter and bird guard placement may improve the electrocution and collision percentage; Use an alternative tower configuration with proven reduced risk of bird electrocution, or Amend the design of the delta configuration to allow for a greater distance between conductors and therefore reduced risk of electrocution; and/or Will include bird diversion mitigation to the selected tower configuration to discourage roosting on the towers. Eskom to ensure that the vegetation clearance and line maintenance occurs as per Eskom Policies; The width of the power-line corridor where vegetation is actively maintained during the operational phase must be kept at an absolute minimum that permits safe operation of the power line, as per Eskom’s Vegetation Management and Maintenance within Eskom Land, Servitudes and Rights of Way Standard (240-70172585); and Ensure that as much natural vegetation as possible is retained within the corridor once the servitude is cleared to ensure visual screening. Movement of vehicles must be confined to established access tracks; and Suitable erosion management measures as per Eskom’s maintenance programme should be implemented. 45 No. Project Lifecycle Phase Environmental Aspect 39. Operational Phase Poor management on Eskom servitude gates. 40. Operational Phase Electrical faulting. Environmental Impact Poor lock management on Eskom servitude gates exposes landowners to illegal trespassers and provides access to criminals and creates a poaching risk. Faulting causing loss of stable electricity supply i.e. outages which impacts negatively on businesses hospitals, schools etc. ZITHOLELE CONSULTING Mitigation Measures Eskom to ensure that the access maintenance occurs as per Eskom Policies. The implementation of the proposed project will contribute to ensuring a stable supply of electricity. 46 17 ORGANISATIONAL STRUCTURE The organisational structure identifies and defines the responsibilities and authority of the various role-players (individuals and organisations) involved in the project. All instructions and official communications regarding environmental matters shall follow the organisational structure. The organisational structure reflected has been developed to ensure that; There are clear channels of communication; There is an explicit organisational hierarchy for the integration project; and Potential conflicting or contradictory instructions are avoided. In terms of the defined organisational structure reflected in the figure, all instructions that relate to environmental matters will be communicated to the Contractor via the Site supervisor. The only exception to this rule would be in an emergency (defined as a situation requiring immediate action and where failure to intervene timeously would, in the reasonable opinion of the ECO, result in unacceptable environmental degradation), where instructions may be given directly to the Contractor .The detailed roles and responsibilities of the various role-players identified in the organisational structure are outlined in Section 11. 18 ENVIRONMENTAL ROLES AND RESPONSIBILITIES As is evident from Figure 5, the key-role-players for the integration project are the DEA, Eskom (including the Environmental Control Officer) and the Contractor. The detailed roles and responsibilities of each of these organisations are outlined below. 18.1 Department of Environmental Affairs As the competent environmental authority, the DEA has the responsibility to ensure that the proponent, viz. the Eskom, complies with the conditions of the Environmental Authorisation for the FFP project (once received) as well as the requirements of the broader environmental legislation, specifically the NEMA - National Environmental Management Act (No. 107 of 1998). Compliance would be confirmed via the following mechanisms: Receipt and review of the environmental reporting required in terms of the EA; and Ad hoc and planned site inspection by the DEA Compliance and Enforcement 18.2 Eskom As the Proponent, Eskom must ensure that the implementation of all components of the Solar Park project comply with the requirements of the DEA Environmental Authorisation (once received), this EMPr, as well as any obligations emanating from other relevant environmental legislation. Although part of this obligation is being met by the development of the EMPr, and ZITHOLELE CONSULTING 47 its integration into the contract documentation, and the appointment of the ECO, the Eskom cannot delegate out of this responsibility. Accordingly, Eskom retains various key roles and responsibilities during the decommissioning of the components of the Solar Park project and associated infrastructure. These are outlined below. Eskom, as an organisation must ensure that adequate funding is made available for the implementation and monitoring of the environmental controls emanating out of the Basic Assessment, Environmental Authorisation (once received), EMPr and applicable environmental legislation. This would include the appointment of the ECO as this is an explicit requirement of the EMPr. It should be noted that the ECO can be an existing environmental employee, for example the Environmental Manager. The Eskom Project Manager must: Be fully conversant with the BA reporting for the project, the conditions of the Environmental Authorisation (once received), the EMPr and all relevant environmental legislation. Ensure that all the specifications and, legal constraints pertaining to the project, specifically with regards to environment management, are highlighted to the Eskom and its Contractor(s) so that they are aware of these; and Ensure that the environmental specifications are correctly implemented throughout the project by means of site inspections and meetings. This will be documented as part of the site meeting minutes. Eskom’s Representative (≈ Eskom’s Construction Manager) must: Be fully knowledgeable with the contents of the BA Reporting; Be fully knowledgeable with the contents and conditions of the Environmental Authorisation; Be fully knowledgeable with the contents of the EMPr, specifically as articulated into the environmental specifications attached to each Contract; Be fully knowledgeable with the contents of all relevant environmental legislation and ensure compliance with these; Have overall responsibility of the environmental specifications and their proper implementation; Ensure that regular audits are conducted to confirm compliance with the environmental specifications; Ensure there is communication with the Eskom Project Manager or his delegate, the ECO and the relevant Site Engineers on matters concerning the environment; and Ensure that no actions are taken which will harm or may indirectly cause harm to the environment, and take steps to prevent pollution on the site. ZITHOLELE CONSULTING 48 18.3 Environmental Control Officer The Eskom must appoint a suitable qualified ECO to monitor compliance with this EMPr, environmental legislation and the Environmental Authorisation (once received). To fulfil these requirements, the ECO would need to have relevant on site experience. It should be noted, unless otherwise stated in the Environmental Authorisation, the ECO could be a Eskom employee, as long as they have the requisite environmental training and experience. The ECO will be responsible for monitoring, reviewing and verifying compliance by the Contractor with the environmental specification. Accordingly, the ECO would be required to: Be fully knowledgeable with the contents of the BA Reporting; Be fully knowledgeable with the contents and conditions of the Environmental Authorisation; Be fully knowledgeable with the contents of the EMPr, specifically as articulated into the environmental specifications attached to each Contract; Be fully knowledgeable with the contents of all relevant environmental legislation and ensure compliance with these; Ensure that compliance with the conditions of the Environmental Authorisation and environmental specification are monitored and verified through regular and comprehensive inspections of the site and surrounding areas, and that the results of these inspections are reduced to writing; Ensure that if the environmental specifications are not followed then appropriate measures are undertaken to address this; and Report to the DEA every three months regarding compliance with the requirements of the EMPr, environmental legislation and the Environmental Authorisation (once received); In meeting the aforementioned obligations, the ECO's specific duties would include the following: Assisting the Eskom Project Manager in ensuring necessary environmental authorizations and permits have been obtained; Confirming that activities on site comply with legislation; Monitoring and verifying that the conditions of the Environmental Authorisation and environmental specifications are adhered to at all times and requiring the Contractor to take action if these are not followed; Monitoring and verifying that environmental impacts are kept to a minimum; ZITHOLELE CONSULTING 49 Giving a report back on the environmental issues at the monthly site meetings and other meetings that may be called regarding environmental matters; Inspecting the site and surrounding areas regularly with regard to compliance with the environmental specifications; Ensuring that a register of complaints is kept by the Contractor and that all complaints are appropriately recorded and addressed; Assisting the Engineer in certifying payment for items related to the environmental specification; Approving any method statement required by the contractor; Recommending the issuing of penalties for contraventions of the environmental specifications; Advising on the removal of person(s) and/or equipment, not complying with the specifications, from site; Completing the requisite environmental reporting, which should include a daily site diary entry, weekly audit checklists, a bi-monthly (viz. every second month) environmental compliance report; Keeping a photographic record of progress on Site from an environmental perspective; and Undertaking project and contractors audits. As outlined previously, all instruction issued by the ECO would go through the Engineer’s Representative, who will then convey these to the Contractor. 18.4 Contractors By virtue of the environmental obligations delegate to the Contractor through the Contract Document, all contractors (including subcontractors and staff) and service providers appointed for this component of the Solar Park project would be responsible for: Ensuring adherence to the environmental specifications; Ensuring that any instructions issued by the Engineer, on the advice of the ECO, are adhered to; Ensuring that there must be communication tabled in the form of a report at each site meeting, which will document all incidents that have occurred during the period before the site meeting; Ensuring that a register is kept in the site office, which lists all the transgressions issued by the ECO; and Undertaking subcontractor’s audits. Ensure that all employees, including those of sub-contractors receive training before the commencement of construction in order that they can constructively contribute towards the successful implementation of the environmental requirements of the Contract. The most important actions by the Contractor to ensure compliance with the environmental requirements, relates to the establishment of an adequate and appropriate organisational ZITHOLELE CONSULTING 50 structure for ensuring the implementation and monitoring of the requisite environmental controls. The EO's specific duties relate to the implementation of the environmental controls contained within the EMPr, and which are audited by the ECO. Accordingly, the EO’s duties include: Ensuring that activities on site comply with legislation; Monitoring and verifying that the environmental specifications are adhered to at all times and taking action if the specifications are not followed; In consultation with the engineers, develop any method statements required in this EMPr; Monitoring and verifying that environmental impacts are kept to a minimum and taking action to address any environmental degradation; Proactively developing environmentally responsible solutions to problems, in consultation with the EO where necessary; Giving a report back on the environmental issues at the monthly site meetings and other meetings that may be called regarding environmental matters; Keeping records of all activities / incidents concerning the environment on site; Inspecting the Site and surrounding areas regularly with regard to compliance with the environmental specifications; Maintaining a register of complaints, ensuring that all complaints are appropriately recorded and addressed and notifying the ECO of each complaint and how it was resolved; Completing the requisite environmental reporting, namely a daily compliance checklist, a record of staff induction and incidence reports, for submission to the ECO; Keeping a photographic record of progress on Site from an environmental perspective; and Undertaking subcontractor audits. 19 TRAINING The ECO shall be appropriately trained in environmental management and shall possess the skills necessary to impart environmental management skills to all personnel involved in the construction, of the proposed construction of the 132kV power lines; Eskom, together with the Environmental and Safety Manager and the ECO, shall ensure that the employees (including construction workers, engineers, and long-term employees) are adequately trained on the EMPr; and All employees shall have an induction presentation on environmental awareness. The cost, venue and logistics shall be for Eskom’s account. Where possible, training must be conducted in the language of the employees. The induction and training shall, as a minimum, include the following: The importance of conformance with the EMPr, other environmental policies and procedures; The significant environmental impacts, actual or potential, related to their work activities; The environmental benefits of improved personal performance; ZITHOLELE CONSULTING 51 Their roles and responsibilities in achieving conformance with the EMPr and other environmental policies and procedures; The potential consequences of departure from specified operating procedures; and The mitigation measures required to be implemented when carrying out their work activities. 20 PROJECT COMPLIANCE REPORTING Regular monitoring of all the environmental management measures and components shall be carried out by the Eskom and ECO to ensure that the provisions of this plan are adhered to. Ongoing and regular reporting of the progress of implementation of this Programme should be done. Various points of compliance will be identified with regard to the various impacts that the construction will have on the environment. Inspections and monitoring shall be carried out the implementation of the plan. Visual inspections on erosion and physical pollution shall be carried out on a regular basis. 21 REPORTING PROCEDURES AND DOCUMENTATION Record keeping and monitoring of documentation is a vital part of compliance with the environmental management system, record-keeping procedures for the 132 kV power line construction has to be in order. Accurate records must be kept of all waste exiting the construction site. Waste must be categorised by the number of loads, defined by mass, type and origin. Records must be kept on both a daily and a cumulative basis. One or a combination of the following systems could be used for record keeping: An electronic, totally computerised, mass measuring device providing detailed records of daily, weekly and monthly transactions. This system should be used with the proposed weighbridge and computer system; and A mass measuring unit with hand capturing of data for manual or computerised collation. This would also be used as backup when the computer is out of action. Details of waste category, quantities and origin will be obtained and recorded for all wastes accepted by the Contractor’s access controller. A daily summary of the wastes accepted must be recorded by the Contractor in the Daily Diary in the Contractor’s site office. 22 ENVIRONMENTAL CONTACT PERSON Information to be provided subsequent to the granting of Environmental Authorisation. 23 EMERGENCY CONTACT NUMBERS Police: 10111 ZITHOLELE CONSULTING 52 Ambulance Netcare 911 ER24 Emergency Crimestop 10177 082 911 084 124 107 08600 10 111 ZITHOLELE CONSULTING (PTY) LTD Sharon Meyer Douglas ZITHOLELE CONSULTING ZITHOLELE CONSULTING