COMMENTS ON THE
DRAFT
ENVIRONMENTAL MANAGEMENT FRAMEWORK
FOR THE SALDANHA BAY AREA AND A PORTION OF THE BERG RIVER MUNICIPALITY
Feb/March 2013
No.
Commentator &
date received
Comment
Response
1.
Lucile Byrnes
Received by email
on 12.02.13
I am disappointed that although my comments on the
Discussion Document (submitted last May and attached as
Annexure A) have been noted in the appropriate Appendix of
the Draft EMF, they have not been taken cognisance of – and
an example of this is reference to page 12 item 2.3.1 and the
birds not found here. Why have these discrepancies not
been included in the second draft? It is simply confusing not
to do so.
The EMF has been revised. In addition, CapeNature has been
informed of the concerns regarding the information on birds, which
originated from the Technical Report written by CapeNature in
respect of the Fine Scale Biodiversity Plan for the area.
I question why I should be wasting my time in making
comment if note is not being taken of it.
2.
K.H.B. Harrison.
(West Coast Bird
Club –
Conservation)
Sent by Email 21st.
February 2013
Thank you for sending me the CD for the above project,
which is very comprehensive, so that I am able to comment.
There have been some recent changes taken place.
1. Maps,
For the Dwaskersbos area is the Eastern boundary the tar
road? The reason I ask is that there is an application for
prospecting for Heavy Minerals, East of the road.
There is a map showing infrastructure in the EMF and GIS
database.
2. Birds, I have read the correspondence about the
presence of certain species, I would take the opportunity not
to include the Dune lark, Barlow’s lark or Karoo Bustard
The information on birds has been revised. In addition, CapeNature
has been informed of the concerns regarding the information on
birds, which originated from the Technical Report written by
1.
(which Robert’s 7 names as Karoo Korhaan).
3. Mining,
The reference on page 60, that mining is not a key economic
activity in the area and also section 4.1.10 re-degradation of
land should be re-written due to the current list of prospecting
applications in the EMF area, involving - Heavy Minerals, 7
for Phosphates (one PEA indicates a mine with infrastructure
like the old Langebaanweg Mine), Limestone which will
require an 8km conveyor or roadway to a Cement Plant,
Silica Sand and Sea Shell for Calcium Carbonate.
4. Renewable Energy Projects,
Due to good conditions for wind and sun there have been
many opportunities for renewable energy projects. Currently
construction has commenced at the Hopefield site. The
Paternoster West Coast No.1 site has passed the Eskom Bid.
Several Solar plants have passed their EIA stage.
3.
Sue Ruether
Environmental
Consultant
SRK Consulting
By email 01.03.13
The WCBC reserves the right to further comment when
additional information becomes available.
I wonder if the “Limited Constraints Zone” is depicted
correctly (Map 26) – the white area is supposedly the
combined coverage of Zones 1 and 2 (Maps 22, 23 and 25 –
there is no Map 24 in the document), and the remaining
areas I would assume fall within an orange ‘no constraints
zone’ – although none of that is visible.
However, there are areas for example immediately NE of
Vredenburg or east of Paternoster and also in the southwestern portion of the EMF area that don’t seem to fall within
Zones 1 or 2 – yet they are still shown as white rather than
orange areas in Map 26?
CapeNature in respect of the Fine Scale Biodiversity Plan for the
area.
Mineral resources are shown on a map in the EMF. Manufacturing
/ industrial development is seen as a larger sector than mining –
although mining is identified as an economic growth opportunity.
The EMF is not concerned with tracking EIA applications or
mapping these. Rather, it is a framework to support and guide
applications made in terms of the EIA Regulations.
There is a map showing renewable energy projects.
Map 24 was erroneously omitted from the document and this will be
corrected in the final. However all the maps are included separately
on the online version at http://www.chand.co.za/saldanha.asp
In the process of revising and finalising the EMF many of the maps
have changed. Most of the study area is covered by one or more
EMZ.
Not all of the attributes listed in Table 10 (Section 6.4) seem
to also be mapped in Maps 23 or 25? I can’t find for example
dryland agriculture paleontological sites or cultural sites.
Actually – it seems like that map (could it be 24?) is missing
from the document, which explains why the three available
maps don’t add up to the white area cover in Map 26?
2.
4.
Kerry Maree
CapeNature
By email – 15.03.13
1. As custodians of biodiversity, interest lies mainly within
the recognition of spatial biodiversity informants when
assigning EMZs as well as the assigning of appropriate
activities, management objectives and desired outcomes
to the important biodiversity areas.
2. For the study area in question, the Biodiversity Sector
Plan and its associated maps represent the best
available spatial biodiversity informants to be used in
land-use spatial planning and decision-making. We would
like to commend the consultants on their interpretation
and application of these layers together with the other
vital informants such as the NFEPA and threatened
ecosystem layers.
3. With regard to the cross-walking of the CBA map
categories, our suggestions are as follows:
a. CBAs –EMZ 1: This document has correctly done
this.
b. CESAs and OESAs –EMZ 2: This document assigns
EMZ 1 status to CESA’s.
We do however feel that these areas can withstand
some degree of change on conditions that the
ecological processes supported by these areas are
maintained.
c. Other Natural Areas (ONA): We feel that these areas
should be targeted for sustainable development and
can therefore withstand a higher degree of impact.
The activities listed in Table 12 appear to be too
restrictive for these areas. We are however also
uncomfortable in deeming them as Limited
Constraint zone as these areas appear to be already
transformed and within urban edges and have a long
term objection to be exempt from the authorization
processes (which we would not support). Also the
Management Objective of ONA should not be to
minimise loss but rather encourage sustainable
development.
4. We are pleased with the desired outcomes and
management objective stipulated for EMZ 1 which
appear to be consistent with the Desired Management
Objectives of the Biodiversity Sector Plan.
The CESA have been moved to EMZ 2.
3.
5. There are however discrepancies between the EMZ1 and
the CBA layers. Two cadasters where this has happened
are where the Saldanha Steel / Arcelor Mittal and
Namakwa Sands / Tronox industrial facilities are located
respectively. Both of these sites have been mapped as
EMZ 3. Although they are both large industrial facilities,
both properties do have natural vegetation that is of high
conservation value and was mapped as CBA and should
therefore be mapped as EMZ 1. The report implies that
all CBAs were mapped as EMZs and misleadingly does
not allude to these exceptional cases. We request that all
such sites be highlighted and that a motivation be
provided as to why they have not been appropriately
classified as EMZs, CapeNature, will not support the
exclusion of these areas from undergoing environmental
authorization and the undertaking of specialist studies.
6. We encourage you to consider adopting the list of
activities as outlined by the Provincial Spatial
Development Framework Rural Land Use Planning and
Management Guidelines (RLUPMG) (in Preparation)
instead of defining a new list of activities as this EMF has
done, Considerable work was done by CapeNature,
SANBI and DEADP to ensure that the activities defined in
the RLUPMG are reflected by the land use guidelines for
the CBA Maps for the province, thereby minimising the
amount of activity lists users would have to become
familiar with when decision-making. We also note that the
RLUPMG was not listed as an information source.
7. In terms of applying the EMF in land-use planning, we
encourage
you
to
include
a
cross-walking
recommendation as to how the EMF EMZs should be
translated into the Spatial Planning Categories (SPC) for
Spatial Development Frameworks (SDF) (i.e. Core 1,
Core 2, Buffer 1, Buffer 2, Intensive Agriculture and
Settlements). We hope that the EMF will form one of the
lead informants of the SDFs and including such
instructions can only assist in this regard.
8. Certain Maree and Vromans, 2010 paragraphs have
been included verbatim into the background sections of
this EMF. We request that these sections be
appropriately referenced. We also remind you that the
THE EMF maps have been reworked. Some locations will have
more than one attribute present.
The activities used are based on the EIA Regulations. Ultimately
the EMF is a tool aimed at supporting the EIA Regulations and
Integrated Environmental Management.
Revisions have been made to the EMF based on this feedback.
4.
BSP was for Saldanha and Sandveld region and that
information contained in the BSP might therefore not be
relevant to this EMF, e.g. page 32 makes reference to
Succulent Karoo and Namaqualand tent tortoise and the
Namaqualand speckled padloper.
9. We acknowledge that the EMF is intended to be a
strategic document and need not necessarily provide site
specific guidance in decision-making as stipulated in this
report and by the DEA norms and standards for drafting
EMFs. We do however feel that it would be possible to
provide more sustenance in the form of a decision –
support tool, to section 8.2, Using the EMF to inform
environmental decision-making to aid decision-makers in
conflict areas, e.g. a site which has been categorised as
EMZ 1for both biodiversity and agricultural purposes.
10. The document contains some minor grammar and editing
errors: e.g. there are two Tables 2s; last sentence under
endangered ecosystem on page 3 appears to be missing
a word; Page 44 has Map x highlighted in yellow; page
128 reference SANBI as producers of the Biodiversity
Sector Plan when it should read CapeNature, etc.
11. With regard to Table 9 on Page 107:
 Activities which could only be considered due to
overriding public interest but which are
nonetheless likely to have a significant negative
impact in this zone:
In the highly unlikely event that these activities
are permitted, they must be appropriately offset.
This is stipulated in Table 8 (a) but needs to be
made explicitin Table 9 too.
 Activities that are unlikely to have a significant
negative impact in, and could be considered.
Education and research-as long as there is no
development footprint associated with these
activities.
Suspended linear infrastructure is still likely to
have an impact on the biodiversity and
depending on the sensitivity of the biodiversity,
the impact could be medium to high even though
the footprint is limited, e.g. boardwalk through
wetlands. We suggest attaching a caveat similar
A guidance section has been included as well as a section on
decision-making and trade-offs.
The tables have been revised and the order in which they appear in
the EMF changed to allow for an easier flow of information.
5.
to that of the underground infrastructure which
mentions ‘subjects to certainty based on
scientific research or specialist assessment.
12. CapeNature agrees to the roles and responsibilities
assigned to them as outlined on page 131. We trust that
the responsibilities will be addressed as a team with
DEADP and SANBI and that we, as an individual
organisation, cannot be expected to deliver on any one of
these.
13. We would like to challenge the opening sentence of Page
133 which indicates that it is ‘generally acknowledged’
that there has been little progress on mainstreaming
environmental
considerations
into
development
decisions. Please provide references for this as we are of
the opinion that over the last decade there has been
considerable advancements in this arena and that the
success on the ground now needs to be properly
acknowledged in official documents and articles.
Momentum in these mainstreaming avenues and the
acknowledgement of this success encourage the further
mainstreaming by the wider group. The alternative
scenario, whereby claims are made that few people
make use of environmental considerations, could retard
the mainstreaming efforts even more.
Revisions to this section have been made to take account of this
comment..
Conclusion
We thank you the time to consider our comments and
suggestions. We will gladly engage further on these matters
and look forward to the ultimate completion and
implementation of this Environmental Management
Frameworks.
CapeNature reserves the right to revise initial comments and
request further information based on any additional
information that may be received.
6.
5.
Lisa van Aarde
Planning Partners
8 April 2013
Received via email
Planning Partners has been requested to prepare a comment on the draft
Environmental Management Framework for the greater Saldanha Bay
Area: February 2013 (EMF). The comment has been prepared at the
requested of Mr. Robert Groenix, who has an interest in a significant land
holding between Saldanha and Vredenburg.
1. Introduction
Firstly we would like to state that the draft EMF is a document that has
grouped a significant amount of environmental information together in
a manner that provides a comprehensive overview of the
environmental attributes of the area under consideration.
The contribution that the EMF will make to the future of the sustainable
development of the study area is important from both a private and
public sector perspective. As a high level characterisation and
evaluation of the important environmental characteristics and attributes
it will make a valuable contribution to the sustainable use of land. It will
represent the common reference document against which decision
making on proposed activities within the area will be measured, be it
from a conservation or development perspective or other and will
make a positive contribution to proactive planning.
There are however, certain important aspects that require further
consideration before the finalisation of the report.
2. Environmental Management Framework vs Spatial Development
Framework
On Page 10 of the EMF it is stated that he difference between the
“EMF and a spatial development framework (SDF) is that the EMF
focusses on environmental attributes whereas the SDF reflects
proposals or intentions in relation to land use and development”.
It is our considered opinion that the current EMF has overstepped its
own stated boundaries, since it makes spatial development proposals,
albeit stated in the negative.
The development tables/activities matrices that are included in
Chapter 3 of the EMF clearly state those land uses/activities that
should not be considered in a zone, that could only be considered if
there is an overriding of public interest, are likely to have a significant
negative impact, are unlikely to have a significant impact, could be
considered, etc. The matrices are essentially populated by proposals
The activities that are dealt with in the EMF in terms of
their appropriateness or otherwise are based on the
Listed Activities in the EIA Regulations.
It is a
requirement of the EMF Regulations to provide
information on environmental sensitivity as well as on
the types of development that may or may not be
appropriate. This is explained in the EMF.
7.
or intentions in relation to the desired or sustainable land use of the
properties involved, as opposed to provided information regarding the
environmental conservation value or environmental sensitivity of the
area. In fact, as stated on Page 6 of the EMF, the EMF should inform
the SDF and not perform the function of making spatial proposals.
This is particularly concerning since it pre-empts the decision to be
taken in terms of an EIA process, which is directed at site specific
detailed investigations, since it is prompting what may or may not be
considered to be the sustainable use of land by the decision maker.
The following comment on certain components of the EMF is directly
related to this issue.
3. Critical Biodiversity Areas: Terrestrial Designation
The incorporation of environmental attributes into what are essentially
spatially defined land use proposals.
In Section 2.2 Biodiversity, it is stated that the Biodiversity Sector Plan
provides the best available scientific information regarding the
biodiversity resources that need to be retained in the long term. Per
implication it is possible that better information may be available in the
future, and the EMF should guard against being presented as a blue
print plan that will control the use of land into the future, for instance:
Map 6 – Critical Biodiversity Areas: Terrestrial in particular informs
Map 22 – Environmental Management Zone 1 (EMZ1), which
incorporates the Critical Biodiversity Areas: Terrestrial into the
category directed at achieving the strategic objective of keeping assets
intact. When considering Map 6 however, it appears and is in fact the
case that areas that are transformed and degraded (indicated as red
areas on the map) have been included in the CBA: Terrestrial. While
accepting that the critical biodiversity area mapping has been
conducted in a manner that is presented to be the least land hungry
with respect to achieving biodiversity conservation targets, the
alternatives considered to prepare this map are not presented. The
inclusion of transformed and degraded areas into the EMZ1 has
potentially significant consequences for the future use of this land and
directly on the land owners concerned. What is concerning is that in
some cases, entire agricultural land units or significant portions thereof
have been included in this manner into this classification.
8.
What is not clear from the EMF is what the underlying criteria are
that were applied that resulted in the inclusion of these degraded
and transformed areas into the CBA. Reference to the other maps
included in Chapter 2 of the report, e.g. Map 11 – Threatened
Ecosystems: Status and Vegetation Types, indicate that some
of these areas are not included as threatened ecosystems, but
are mapped as dryland agriculture on Map 12 – Agricultural
Priority Areas. Their agricultural potential is mapped similarly to
other areas that have not been designated as part of the CBA
layer.
The biodiversity data has been drawn from
SANBI/CapeNature. The criteria used and methodology
applied is explained in the Technical Report attached to
the Fine Scale Plan. Criteria were not developed by the
EMF team in this regard.
It is therefore not clear why some areas that are indicated with
similar designations on the map have been incorporated into the
CBA layer, while others are not. It is not acceptable that certain
land owners, whose land have been included into the CBA layer,
are then subject to the very limiting decision making framework
embodied within the EMF. This of particular concern with respect
to the EMZ1 – keeping assets intact, and the prospect of
environmental offset targets that may need to be met.
Throughout the EMF, it is stated that the propose of the EMF is to
serve as a decision making tool, in particular within the context of
environmental impact assessment processes conducted in terms
of the NEMA Regulations. The EMF states that each project must
be evaluated on its merits and that specialist studies are required
for ground trothing in respect of each attribute that is presented on
the EMF maps. However, applicants are often confronted by
strategic documents, such as the EMF, which in principle are
intended to be guiding documents, but are applied in an inflexible
manner.
In order to assist the decision maker in applying his/her mind to a
particular application, it is requested that the reasons for the
inclusion of known degraded and transformed areas into the CBA
should be explained in more detail in the EMF. This would assist
both land owners and decision makers in the preparation of
applications and the evaluation thereof where departures from the
CBA designation may or may not be considered.
4. Environmental Management Zone 2 (EMZ2)
9.
The EMZ2 covers a very wide range of environmental attributes,
to the extent that, not surprisingly the entire study area is
characterised as having one or more environmental attributes.
However, Table 12 deals with the “be careful zone” in an holistic
manner, i.e. all environmental attributes covered have been dealt
with as if they are equally sensitive to all potential types of
intervention.
As with the EMZ1 and the opening issues raised, where Tables
10, 11, 12 and 13 may provide useful guidance to the land
owner/applicant and the decision maker alike, it is concerning that
Table 14 then lists activities/land uses, which amounts to spatial
planning directives.
It is clearly stated in the EMF that groundtruthing will be
required as will specialist studies. The onus is on the
Applicant to undertake the necessary investigation and
to endeavour to undertake development that is
responsive to environmental factors. The EMF is a
decision-support tool.
Each application must be
evaluated and decided upon on its own merits.
We submit this comment, and trust that careful consideration will be given
to addressing the issues raised, in particular in order to maintain the
distinction between a spatial development framework, which is a spatial
representation of the vision of a local authority with respect to its
sustainable development over time (and this includes spatial directives at
achieving sustainable conservation targets) and a document that is
intended to present an holistic view of the environmental attributes of an
area, with the view of assisting environmental decision making.
Please note that this comment is not intended to refute the important role
that an EMF can play, and we believe will, play in guiding the formulation
of an SDF, but that the Department of Environmental Affairs and
Development Planning must carefully reconsider the appropriateness of
including land use proposals in the EMF.
6.
Mrs Michelle Pretorius
Department of
Agriculture , Forestry &
Fisheries
29 April 2013
Received by email
Further, our client reserves his rights (e.g. zoning rights) with respect to
the continued lawful utilisation of his properties and the exercise of those
rights on his property. Any application which may at some future date be
submitted, would also need to be evaluated on the merits of the particular
application, notwithstanding the use listings included in the EMF.
The Department of Agriculture, forestry and Fisheries (Branch Fisheries):
Directorate: Sustainable Aquaculture Management: Sub-Directorate:
Aquatic Animal Health and Environmental Management Framework (EMF)
for the Saldanha Bay area and a portion of the Berg River municipality.
The Sub-Directorate AAHEI has reviewed the EMF and would like to
submit the following comments:
10.
1. With reference to Table 3 on page 39,-key ecological information
Saldanha Bay and S Helena: ‘of the 85 alien species known to occur
in South Africa, 62 are present in Saldanha Bay. This is the highest
number and density of alien marine species in the country. These
species have originated primarily from ballast water and cleaning of
ships and to a much lesser extend form matriculture species farmed,
there are no known naturalised populations of the farm oyster
(Crassostera gigas) within Saldanha Bay, despite the fact that this
oyster species is imported and farmed in the area. The Daff has
recently conducted a biodiversity Risk and benefit Assessment
(BRBA) for seven alien aquaculture species in South Africa, which
included the farmed oyster Crassostrea gigas and the farmed
Mediterranean mussel. Mytilus galloprovincialis. The BRBA for C
gigas concluded that despite continuous introduction of the species
since the 1950’s there has been very little spread of the species within
South Africa (Robinson et al 2005) and it does not appear to
demonstrate the same invasion potential in South Africa as it does
internationally. This is due to the fact that the oyster is unable to
reproduce and settle successfully under local environmental
conditions on the west coast which differ from its native habitat. The
Mediterranean mussel. M. galloprovincialis, was first discovered in
South Africa in 1979, in Saldanha Bay (Branch & Steffani 2004),
where it was most likely introduced as a result of shipping. Since M.
galloprovincialis has established self-sustaining populations along the
coastline from the Namibian border to East London, further culturing
of this species anywhere in this region is unlikely to significantly affect
the size or spread on the current populations. Mariculture, which we
term “marine aquaculture”, of M. galloprovincialis relies on mussel
seed, from offshore larval pools which naturally settle on the culture
ropes. Currently there is no import of mussel seed required in South
Africa. It is requested that the above facts are used to amend the
above statement in the document and wherever it may apply in the
EMF.
2. With reference to statements made on page 82 regarding Marine
Pollution and Pollution risks: Organic nutrient loading. It is not
disputed that studies, such as the State of the Bay, have alluded to
eutrophication, algal growth and anoxia problems associated with fish
processing and mariculture. It should, however, be clarified that the
organic loading from fish processing far outweighs those produced by
mariculture. Please amend in order to provide perspective in this
regard.
Information on marine biodiversity in Saldanha Bay and
St Helena Bay has been drawn from the respective
State of the Bay reports. The EMF provides a Situation
Assessment, based on existing published information
and data sources.
11.
3. With reference to page 84 regarding the unsustainable use of
fisheries. “Mariculture has a negative impact on biodiversity in the
sense that diseases harboured in these facilities returns to the ocean,
which in turn impacts on the natural populations.” In order to manage
this risk all aquaculture facilities are required by the Daff, as part of
their permit conditions, to apply best management practises including
having farmed animals certified disease free by qualified veterinarian
prior to importation. Marine Aquaculture Permit holders as required to
comply with an approved Disease Surveillance / Management Plan or
any specific disease management directions issue by the Department
and the relevant Veterinary Authority. Permit holders are to implement
a bio-security programme to prevent the risk of disease spread, to cooperate with stock health inspections implemented by the Daff and to
notify the Department of mortalities and disease. The industry is
heavily regulated and this point should be emphasised in the report. In
assessing the significance of impacts, a clear distinctions should be
made between the risk of a potential impact and unavoidable impacts.
A disease outbreak is not a definite impact, but in most cases remains
a risk to be managed and mitigated. Certain impacts are definite, such
as the clearing of vegetation, while many impacts are potential risks
that are mitigated through careful management. Please amend the
sentence on page 84 to” …mariculture may or could have a negative
impact…...” and revise the significance of this impact accordingly.
4. With regards to the Strategic Environmental Management Plan
(SEMP) and the Environmental Management Zones (EMZ) identified,
we would like to raise the following concerns:
a. Zone 1, which indicates that aquaculture / mariculture activities
should be avoided, includes the 100m from the high water mark
(HWM). While it is acceptable for the main footprint of land-based
aquaculture development to be behind the 100m HWM, the
infrastructure associated with intake and discharge of either sea
water or freshwater has to be within this zone in order to access
the sea and fresh water.
b. Zone 1 identifies irrigation land as land where activities, such as
aquaculture, should not be undertake or avoided. However,
existing water abstracted for irrigation can be used for freshwater
aquaculture, without compromising the irrigation. This is
beneficial, as the same amount of water is used for both irrigation
and aquaculture production. In addition, aquaculture improves the
irrigation water by increasing the nutrient concentrations. Please
consider revising the activities in Zone 1 accordingly.
It has been noted that mariculture is a contributor but not
as significant as other sources.
12.
c. Zone 1 includes avoiding any discharge within the surf zone. This
is not applicable to aquaculture, specifically abalone culture, as
the sea water effluent is largely innocuous. The effluent water
contains low level increases in ammonia and suspended solids.
Preliminary results indicate that the industry is generally meeting
international standards in this regard (DAFF, 2012).
d. Zone 2 caution the use of aquaculture activities in this zone. This
includes listing aquaculture as having significant impacts in Big
Bay and recommends avoiding aquaculture entirely from Small
Bay. Both bays have been zoned for aquaculture and are
currently being used very successfully for the culture of oysters
and mussels. The current production in Saldanha Bay is well
below the carrying capacity study done for shellfish culture within
for the allocated zones in the bay (Grant et al 1998), which can be
addressed through management strategies such as the rotation of
rafts. In reality, the further development and discharge of other
industries into the bay will have a negative impact on the food
safety of produts originating from the existing aquaculture farms
in the Bay. Marine aquaculture was identified as a beneficial use
in the Operational Policy for the Disposal of Land-Derived Water
Containing Waste to the Marine Environmental of South Africa
(DWA 2004), which is currently being amended by Department of
Environmental Affairs (Oceans and Coast). In additions, the
recent Strategic Environmental Assessment, undertaken by an
independent marine specialist, to identify suitable marine
aquaculture development zones for marine cage culture identified
suitable areas for aquaculture within small and big bay (Hutchings
et al.2011). there are numerous different types of aquatic species
that are farmed and numerous different types of systems used for
farming (land based, rafts, closed recirculation systems, etc).
Broad and generalised statements about aquaculture, with
regards to the zoning and activities excluded from the zones, may
have serious implications on the development of the current and
future aquaculture industry within the bay. Please differentiate
between different types of aquaculture and revise the activities
allowed in Zone 2 to incorporate mussel and oyster farming in Big
and Small Bay.
e. Zone 3 appears to the superfluous as Zone 1 and Zone 2 make
up the entire Saldanha EMF area (Map 26). This negates the
purpose of using the EMF as a tool to assist applicants or
developers in identifying appropriate locations for developments,
The guidance given in respect of the EMZs is not fixed.
It is indicative of key issues that need to be resolved and
significant impacts that could occur. It is thus an ‘early
warning system’. Each application must be evaluated
on its own merits, taking account of how adverse
impacts have been addressed and mitigated.
13.
as Zone 3 has not identified any areas, specifically for
aquaculture. A SEMP or EMP can be used as powerful tool in
environmental management but the usefulness is negated if the
environmental factors are not weighted against socio-economic
factors. Please restructure the Zones in order to improve the
applicant of the SEMP.
5 While the SEMP indicates which categories govern the significance of
an impact of an activity, it does not indicates what methodology was
used to score each sector or how activities were evaluated according
to these criteria. Please clarify how the significance of impacts was
evaluated and consider re-evaluating the significance of aquaculture
activities according to the statements made above.
7.
Mr Michelle Pretorius / Mr
Asanda Njobeni
Department
of
Agriculture, Forestry &
Fisheries
29 April 2013
Received via email
The Sub-Directorate looks forward to your response to comments
above. Please note that Sub-Directorate: AAHEI: sub-unit Aquaculture
Environmental Assessments still reserves the right to review / provide
additional comments in future.
The Department of Agriculture, Forestry and Fisheries (Branch
Fishereies): Directorate: Sustainable Aquaculture Management: SubDirectorate:Aquatic Animal Health and Environmental Interactions
(AAHEI):Aquaculture Environmental Assessments have reviewed the
Environmental Management Framework (EMF) for the Saldnah bay area
and a portion of the Berg River municipality. The Sub-directorate AAHEI
has reviewed the eMF and would like to submit the following comments:
1. With reference to Table 3 on page 39 – key ecological information
Saldanha Bay and S. Helena: “Of the 85 alien species known to occur
in South Africa, 62 are present in Saldahna Bay. This is the highest
number and density of alien marine species in the country. These
species have originated primarily from ballast water and cleaning of
ships and to a much lesser extent from mariculutre operations.” This
comment is unfounded and generalised. With regard to mariculutre
species farmed, there are no known naturalised populations of the
farmed oyster (Crassostera gigas) within Saldanha Bay, despite the
fact that this oyster species is imported and farmed in the area. The
DAFF has recently conducted a Biodiversity Risk and Benefit
Assessment (BRBA) for seven alien aquaculture species in South
Africa, which included the farmed oyster Crassostera gigas and the
farmed Mediterranean mussel, Mytilus galloprovincialis. The BRBA for
C gigas concluded that despite continuous introduction of the species
since the 1950’s, there has been very little spread of the species within
South Africa ) Robinson et al 2005) and it does not appear to
Refer to responses to Mrs Michelle Pretorius given
above.
14.
demonstrate the same invasion potential in South Africa as it does
internationally. This is due to the fact that the oyster is unable to
reproduce and settle successfully under local environmental conditions
on the west coast which differ from its native habitat. The
Mediterranean mussel, M galloprovincialis was first discovered in
South Africa in 1979, in Saldanha Bay (Branch & Steffani 2004), where
it was most likely introduced as a result of shipping. Since M
galloprovincialis has established self-sustaining populations along the
coastline from the Namibian border to East London, further culturing of
this species anywhere in this region is unlikely to significantly affect the
size or spread of the current populations. Mariculture, which we term
“marine aquaculture”, of M galloprovincialis relies on mussel seed,
from offshore larval pools which naturally settle on the culture ropes.
Currently there is no import of mussel seed required in South Africa. It
is requested that the above facts are used to amend the above
statement in the document and wherever it may apply in the EMF.
2. With reference to statements made on page 82 regarding Marine
pollution and pollution risks: Organic nutrient loading. It is not disputed
that studies, such as the State of the Bay, have alluded to
eutrophication, algal growth and anoxia problems associated with fish
processing far outweighs those produced by mariculture. Please
amend in order to provide perspective in this regard.
3. With reference to page 84 regarding the unsustainable use of
fisheries. “Mariculture has a negative impact on biodiversity on the
sense that diseases harboured in these facilities returns to the ocean,
which in turn impacts on the natural populations.” In order to manage
this risk all aquaculture facilities are required by the DAFF, as part of
their permit conditions, to apply best management practises including
having farmed animals certified diseases free by a qualified
veterinarian prior to importation. Marine Aquaculture Permit holders
are
required
to
comply
with
an
approved
Disease
Surveillance/Management Plan or any specific disease management
directions issued by the Department and the relevant Veterinary
Authority. Permit holders are to implement a bio-security programme
to prevent the risk of disease spread, to co-operate with stock health
inspections implemented by the DAFF and to notify the Department of
mortalities and disease. The industry is heavily regulated and this point
should be emphasised in the report. In assessing the significant of
impacts, a clear distinction should be made between the risk of a
potential impact and unavoidable impacts. A disease outbreak is not a
definite impact, but in not cases remains a risk to be managed and
15.
mitigated. Certain impacts are definite, such as the clearing of
vegetation, while many impacts are potential risks that are mitigated
through careful management. Please amend the sentence on page 84
to “…. mariculture may or could have a negative impact…” and revise
the significance of this impact accordingly.
4. With regards to the Strategic Environmental Management Plan
(SEMP) AND THE Environmental Management Zone (EMZ) identified,
we would like to raise the following concerns.
a Zone 1, which indicates that aquaculture/mariculture activities
should be avoided, includes the 100m from, high water mark
(HWM). While it is acceptable for the main footprint of land-based
aquaculture development to be behind the 100m HWM, the
infrastructure associated within this zone in order to access the
sea and fresh water.
b Zone 1 identifies irrigation land as land where activities, such as
aquaculture, should not be undertaken or avoided. However,
existing water abstracted for irrigation can be used for freshwater
aquaculture, without compromising the irrigation. This is
beneficial, as the same amount of water is used for both irrigation
and aquaculture production In addition; aquaculture improves the
irrigation water by increasing the nutrient concentrations. Please
consider revising the activities in Zone 1 accordingly.
c
Zone 1 includes avoiding any discharge within the surf zone. This
is not applicable to aquaculture, specifically abalone culture, as
the sea water effluent is largely innocuous. The effluent water
contains low level increases in ammonia and suspended solids.
Preliminary results indicate that the industry is generally meeting
international standards in this regard (DAFF.2012).
d Zone 2 cautions the use of aquaculture activities in this zone. This
includes listing aquaculture as having significant impact in Big Bay
and recommends avoiding aquaculture entirely from Small Bay.
Both bays have been zoned for aquaculture and are currently
being used very successfully for the culture of oysters and
mussels. The current production in Saldanha Bay is very well
below carrying capacity study done for shellfish culture within for
the allocated zones in the bay (Grant et al 1998). Previous studies
16.
e
f
have also indicated that the localised impact on the benthos
below the rafts are restricted to the short to medium term (StenonDozey et al 1999), which can be addressed through management
strategies such as the rotation of rafts. In reality, the further
development and discharge of other industries into the bay will
have a negative impact on the food safety of products originating
from the existing farms in the Bay Marine aquaculture was
identified as a beneficial use in the Operational Policy for the
Disposal of Land–Devired Water Containing Waste to the Marine
Environment of South Africa (DWA 2004), which is currently being
amended by Department of Environmental Affairs (Oceans and
Coasts ). In addition, the recent Strategic Environmental
Assessment undertake by an independent marine specialist, to
identify suitable marine aquaculture zones for marine cage culture
identified suitable areas for aquaculture within small and big bay
(Hutchings et at 2011). There are numerous different types of
aquatic species that are farmed and numerous different types of
systems used for farming (land based, rafts, closed recirculation
systems, etc.) Broad and generalised statements about
aquaculture, with regards to the zoning and activities excluded
from the zones, may have serious implications on the
development of the current and future aquaculture industry within
the bay. Please differentiate between different types of
aquaculture and revise the activities allowed in Zone 2 to
incorporate mussel and oyster farming in Big and Small Bay.
Zone 3 appears to be superfluous as Zone 1 and Zone 2 make up
the entire Saldanha EMF area (Map 26). The negates the purpose
of using the EMF as a tool to assist applications or developers in
identifying appropriate locations foe developments, as Zone 3 has
not identified any areas, specifically for aquaculture. A SEMP or
EMF can be used as powerful tool in environmental management
but the usefulness is negated if the environmental factors are not
weighted against socio-economic factors. Please restructure the
Zone in order to improve the application of the SEMP.
While the SEMP indicates which categories govern the
17.
significance of an impact of an activity, it does not indicate what
methodology was used to score each sector or how activities
were evaluated according to these criteria. Please clarify how the
significance of impacts was evaluated and consider re-evaluating
the significance of aquaculture activities according to the
statements made above.
References
Branch, G M & Steffani, N C 2004. Can we predict the effects of alien
species? A case –history of the invasion of South Africa by Mytilus
galloprovincialis (Lamarck) J. Exp Mar. Biol.
Copp. G.H Britton , J.R Cowx, I. G Jeney., G. Joly, J.P Gherardi, F.
Gollasch, S.Gozlan, R.E Jones,Macleod,Midtlyng, L Nunn, AD Occhipinti
Ambrogi, AOidtmann, B Olenin, S. Peeler, E Russell I.C Savini, D
Tricarico, E & thrush, M 2008. Risk assessment protocols and decision
making tools for use of alien species in Aquaculture and stock
enhancement. EU Co-ordination Action Project: IMPASSE Environmental
impacts of alien species in aquaculture. Deliverable report 3.2.
Department of Agriculture Forestry and Fisheries. 2012 South Africa
Aquaculture Yearbook 2012.
Department of Water Affairs 2004 Operational Policy for the disposal of
Land-derived water containing waste to the marine environment of South
Africa
Hutchings: K Porter, S. Clark B & Sink K 2011. Strategic environmental
assessment Identification of potential marine aquaculture development
zones for fin fish cage culture Anchor Environmental Consultants. Pp 106
Grant, J Stenton-Dozey, J Monteiro, P Pitcher, G & Heasman, K 1998.
Shellfish culture in the Benquella system a carbon budget of Saldanha
Bay. South Africa for raft culture of Mytilus Galloprovincialis. Journal of
Shellfish Research, vol 17 No 1 41-49
Stention-Dozey J.M.E. Jackson, L.F & busby, A. J 1999. Impact of Mussel
Culture on Macrobenthic Community Structure in Saldanha Bay. South
Africa. Marine Pollution Bulletin vol.39 No. 1-12 357-366
18.
Robinson: T.B Griffiths, C.L Tonin A Bloomer P & Hare, M. P 2005.
Naturalized population of oysters. Crassostrea gigas along the South
African coast. Distribution abundance and opulation structure. Journal of
Shellfish Research 24 (2) 443-450.
8.
Eddie Hanekom
DEADP- Waste
Management Licensing
08 April 2013
The Sub-directorate looks forward to your response to comments above.
Please note tha5t Sub-directorate: AAHEI sub-unit Aquaculture
Environmnetal Assessment still reserves the right to review/provide
additional comments in future.
Review of environmental attributes should be done especially where
development have been approved to provide a status quo to the EMF
whenever it is updated (every 5 years).
Timeframes should be added to when the EMFs get updated for example
on Page 144-10.1 Updating the EMF.
1. The revision cycle would be initiated by the DEA&DP in
consultation with the relevant municipality/ies, within the same
year when the municipalities new financial year starts.
2. The DEA&DP should inform the national Department of
Environmental Affairs of the EMF revision process, which 60 days
of the final EMF has been signed off and accepted.
1. Section 2.7 of the EMF (Infrastructure and Services) is silent on
any infrastructure for waste management within the Municipality.
This needs to be addressed and all the facilities should be
indicated.
2. Section 4.1 (key trends) is also silent on aspects of waste
management. Section 4.1.13 merely indicates that infrastructure
for waste management is inadequate.
The updating process would need to comply with any
legislative requirements.
This has been included on a map.
Comments: Section 2.1 water resources:
Since the area has water shortage it is crucial that industry plays a role in
water resource management by coming up with ways to minimise use of
water in their processes or to re-use or recycle if possible. New applicants
for development need to show how they will minimise water use in their
processes particularly within the IDZ.
Section 1.14: What is the relationship between the EMP, IDP and SDF?
This report should include the relationship within the municipal IWMP as
well, in order to address the issue of development of new landfill facilities.
This has been addressed.
19.
9.
J. Africa/S. Gatyeni
D:EA&DP:
Environmental
and
Spatial
Planning:
Region 2
02 May 2013
Received via email
Page 76, 4.1 KEY TRENDS
Waste management must also be addressed /discussed under key trends
because there were many important issues with including hazardous
waste.
1. Introduction
1.1 Your request for comment on the draft Environmental Framework for
the Greater Saldanha Bay Area has reference. It should be noted
that extensive comments were provided on previous drafts of the
Discussion Document (February 2012) as well as on the draft
Strategic Environmental Management Plan (October i2012).
The EMF is not intended to fulfil the role of a waste
management plan. Waste and pollution have been
noted as trends, pressures or concerns.
1.2 It is acknowledged that the EMF is a broad, overarching document
that does not equate an SDF; however, this provides a spatial
environmental context which informs decision making processes and
should provide guidance in terms of indicating significant
environmental areas and promote the protection thereof as well as
encouraging sustainable environmental practise.
1.3 As stated in previous comments, the link between the SDM. EMF,
and IDP, should be clear, and these documents should also be
aligned as much as possible so as not to create points of conflict in
order to enable predictability in decision making.
1.4 It should be noted that previous comments provided by this
Directorate remain valid as it would appear that these comments
have not been adequately addressed in the current version of the
EMF.
2. General comments
2.1 Although the E3MF goes into detail with regards to NEMA
requirements, etc., the document does not clarify the remaining
processes that still need to be followed prior to completion and what
the statutory status of the document would be after approval. In
addition, it would be useful to clarify the relationship between this
product and subsequent EIA’S within the study area. It is
acknowledged that the public participation information has been
included for the draft Discussion Document and not the comments on
the draft Strategic Environmental Plan, dated July 2012.
2.2 A stated in previous comments, on the discussion document as well as
the strategic environmental plan, the identification of areas of
20.
environmental significance, in terms of ecological connectivity and is
not adequately reflected on the plans provided.
2.3 It is noted that the issue of alignment between SDF, EMF and the
other sector plan is mentioned in the EMF. However, the alignment is
not demonstrated and would appear that the documents are still very
much separate entities. The alignment with the SDF, in particular, is
not carried over to the plans and is lacking in the text.
The EMF serves as a support tool for environmental
purposes.
It should be taken into account when
developing a SDF as noted in the EMF. The EMF is
based on environmental attributes and not proposed
land use planning as is the case with the SDF.
2.4 It would appear that coastal setback lines have not been taken into
consideration. As mentioned in previous comments on the strategic
environmental framework, DEA&DP are currently in the process of
preparing a coastal setback line document in tem of Section 25 of the
National Environmental Management: Integrated Coastal Management
Act, 2008, in which coastal setback lines will be demarcated which will
have an effect on development. The sensitivity regarding this matter
needs to be clarified in the narrative4 if no line is available at the time
of going to print.
Coastal setback lines are provided, based on existing
available information.
2.5 It is acknowledged that the EMF cannot prescribe areas that are
suitable for alternative energy, however, at the very least,
recommendations should be made in order to clarify the need for
further studies which will demarcate appropriate areas.
This is the subject of a specialist study initiated by the
national Department. Relevant information has been
drawn into the EMF.
2.6 The section dealing with agricultural production on page 44 does not
correctly reference the associated plans on agricultural production.
This should be rectified, as reference is made to Maps X and Y.
3. Spatial Planning comments
3.1 As mentioned in previous comments, the scale of the plans provided is
problematic. It is very difficult to determine, at an erf level or in terms
or land uses, what the environmental proposals of the EMF are.
3.2 Linked to paragraph 3.1 above, the EMF plans must also reflect the
urban areas. It is noted that the EMF does not deal with urban areas,
however, at the very least, urban edges must be included on the plans,
it is difficlt to indicate any urban edges. It is suggested that as a
minimum requirement, the EMF describess the PSDF Interim Urban
Edges as areas which will therfore result in a precautionary scenario
for all planning and environmental applications using this document as
a reference. Annexure 1 depicts the Interim Urban Edges for towns in
These are shown.
21.
Saldnaha Bay Municipality.
3.3 In terms of the PSDF, it is encouraging to see that the PSDF and it
objectives are discussed as well as the EMF’s alignment with these
objectives, partiuclary with regards to sustainability and resource
conservation.
3.4 The issue of using the Spatial Planning Categories prescribed by the
PSDF as well as the Rural Management Guidelines (2009), which is a
draft explanatory manual in term of the PSDF, has not been addressed
as requested in previous comments. The SPC’s have not been
incorporated into the plans and thus the EMF deviates from both the
PSDF as well as the municipal SDF, which use the same SPC’s.
3.5 It was requested in previous comments that the Freshwater
Ecosystem Priority Areas (FEPA) information be mapped separately.
The FEPa information is mapped at a different scale to the rest of the
plans presented in the document. It would make more sense for the
FEPA information to be presented on a separate plan at the
appropriate scale.
3.6 The “Zones” which have been proposed (i.e. Keep Assests Intact, Be
Careful, and Limited Xonstraints” Zones) have not been addressed as
requested in previous comments. The plans are not at a detailed
enough level in order to make any informed decisions. They are
viewed to be too broad in nature to be of use in any decision making.
The table associated with each plan is not adequate enough to make
informed decisions. The tables presented are vague and do not make
clear recommendations in terms of which activities are allowed and
which activities should be avoided completely. The headings of each
table should also be looked at, so as to make the tables easier to read.
In previous comments, examples from the City of Cape Town’s
Blaauwberg District plan (Which includes a detailed EMF) were
included, in order to give the consultant an idea of what is required in
terms of the plans (with the associated SPC’s) as wll as what is
required in terms of the tabular notation for each plan. The Saldanha
Bay EMF has not taken this recommendation into consideration, as
requested.
The EMF is not a detailed plan- it is a high-level,
strategic plan. The scale of information is limited by that
which is available from various organisations that house
this information.
22.
4. Conclusion
4.1 It would be beneficial for urban areas to be included in the EMF and a
clear differentiation should be made between urban and non-urban
areas. It would also be useful to indicated urban edges. Although the
EMF does not focus on urban areas, including these in the EMF would
provide more clarity in terms of decision making.
4.2 It would appear that not all of the previous comments have been
addressed, and these comments on the Draft EMF should be read in
conjunction with the comments provided in October 2012 with regards
to the draft Strategic Environmental Management Plan.
4.3 I trust that the above is in order. Should you have any further
enquiries, please do not hesitate to contact this Directorate
10.
Joy Leaner
Director: Pollution
Management
10 May 2013
Refer to Annexure B for the corresponding figures.
The Directorate: Pollution Management has reviewed the above
mentioned document in term of water quality and waste management
status quo of the area and the way forward to reach the desired state of
these pollution parameters. The D: PM have the following related
comments:
1. Water Quality
A study should be undertaken which will form part of the
Environmental Management Framework (EMF) development process.
Salient issues to be addressed should include the following:
1.1 All available rainfall, evapotranspiration, river flow, temperature
(seasonal and diurnal), predominant wind characteristics, data
should be collated and form part of an environmental and climatic
characterization.
1.2 Prepare water quality profile of available sources (surface and
groundwater) and determine the current conjunctive usage of all
water sources. The current status should include human and
commercial consumption values and projected human and
commercial requirements.
1.3 Evaluate the current status of all Waste Water Treatment Works
(WWTW) within the area of study and determine t5he current
capacity and conduct a needs analysis for future expansion in
terms of waste water treatment, waste generation (from sewage
sludge) in alignment with projected growth.
1.4 Evaluate the current status of bulk water treatment works and
project future needs in terms of both environmental and human
The primary purpose of the EMF is to provide support to
Integrated Environmental Management and the EIA
Regulations. It is largely concerned with guiding land
use and development.
The management of
environmental quality issues, such as air quality and
water quality fall outside of the EMF. There are tools
such as Air Quality management Plans to address such
issues.
23.
needs as described in the National Water Act of 1998 (Act 36 of
1998).
1.5 Evaluate the use of the recycled sewage water as a source of
potable water and the erection of desalination plants to augment
bulk fresh water supplies.
1.6 Evaluate the current impact of waste water disposal into the bay
and the future potential impacts based on proposed expansions
which increase the volume of effluent.
2. Waste Management
2.1 Compile data to reflect current solid waste landfill sites, the
lifespan of such landfill and the projected needs for landfill in
terms of spatial and volume waste generation.
2.2 Evaluate the waste minimization potential in terms of current
recovery and recycling rates, and the potential to increase this.
2.3 Identify the feasibility of alternate hazardous waste management
site(s), and use of sewage sludge in situ as an augmentive
source of energy to drive waste water treatment works and
desalination of treated WWTW water via Reversed Osmosis.
3. Air Quality
3.1 The undertaking of an air quality study must form part of the
Environmental Management Framework (EMF) development
process. Aspects to be addressed, amongst other, in the air
quality study are as follows:
3.1.1 Research, assimilate and consolidate all existing air quality
data, information and reports within the given study area.
3.1.2 Prepare on air quality assessment/baseline study report that
defines and spatially represent the status quo of the emission
sources in the study area;
3.1.3 Compile an emission inventory of present industries,
agricultural activities, transport, domestic fuel burning
practices, biomass burning, parts e.g. Port of Saldanha, waste
disposal facilities and other sources in the study area.
3.1.4 Levels of pollutants generated under the current prevailing
conditions must be mode3lled to provide a spatial distribution
of pollutants across the study area. The pollution levels must
be evaluated against the ambient air quality standards of
South Africa.
3.2 Levels of pollutants generated under various industrial
development and high density transport scenarios must be
modelled to provide a spatial distribution of pollutants across the
24.
study area. It must be noted that the various industrial
development scenarios will be generated in an iterative manner
(i.e. the initial findings of a simplistic model may be used to
develop more sophisticated layout options and types of industrial
clusters during the IDZ project planning process, which in turn will
be used to generate different development scenarios for the
study). The project proposal for the study must therefore
acknowledge this phase approach (or iterative planning process).
3.3 List all uncertainties, technical and/or knowledge gaps and the
anticipated consequences thereof.
3.4 The model must indicate the maximum levels of pollution sources
that can be accommodated in the future development to ensure
that the ambient air quality standards are not exceeded.
3.5 It should be noted that the Department of Environmental Affairs
has released the Draft National Dust Control Regulations, Notice
309 of 2011 for comment. The draft regulations prohibit a person
from conducting any activity in such a way as to give rise to dust
in such quantities and concentrations that:
(1) The dust, or dust fall, has a detrimental effect on the
environmental including health, social conditions economic
conditions, ecological conditions heritage, or has contributed to
the degradation of ambient air quality beyond the premises
where it originates; or
(2) The dust remains visible to the ambient air beyond the premises
where it originates, or the dust fall at the boundary or beyond
the boundary of the premises where it originates exceeds:
(a) 600mg/m2/day averaged over 30 days in residential and light
commercial areas measured using reference method ASTM
01739; or
(b) 1200mg/m2/day averaged over 30 days in areas other than
residential and light commercial areas measured using
reference method ASTM 01739. The Draft National Dust
Control Regulations also refers to the requirement for dust
fall monitoring and ambient dust monitoring and must be
considered when assessing dust formation during the
construction and decommissioning phases of the
development.
(3) The Draft National Dust Control Regulations also refers to
requirements for dust fall monitoring and ambient dust
monitoring and must be considered when assessing dust
formation during the operation and decommissioning phases of
25.
the development.
3.6 It should be noted that in terms of Section 35 (2) of the National
Environmental Management: Air Quality Act (Nem: AQA) (Act No.
39 of 2004) (the act), the occupier of the premises must take all
reasonable steps to prevent the emission of any offensive odour
caused by any activity on such premises.
11.
Mark Duckitt
Eco Impact Legal
Consulting (Pty) Ltd
31 May 2013
Received via email
4. Recommendations
4.1 Recommend interventions to improve the current water quality in
the bay due to marine waste water discharges
4.2 Ensure that the regulations and enforcements are in place which
obliges industries and others to adhere to waste minimization and
water saving measures.
4.3 Active monitoring of users to ensure waste generation (water and
solid wastes) adheres to specific guidelines and that any
transgression is underpinned by the ‘polluter pays’ principal.
4.4 Encourage waste sorting at source and a recycling ethos
4.5 Identify the location of industries and the types of emission that
could be allowed to ensure that the ambient air quality standards
are not exceeded within the different land use zones. The latter
must take fugitive dust and gaseous emission from all sources
into account.
4.6 Indicate what kind of activities or land uses would be undesirable /
desirable for air and water quality in the area or in specific parts of
the area.
Please
contact
Mr
Jeff
Jefferson
on
021 483
2895
(jeff.jefferson@westerncape.gov.za), or Mr Zayed Brown on 021 483 8367
(zayed.brown@westerncape.gov.za), should you have any further queries
in this regard.
We mail you following the award by DEA:DP of an Environmental
Authorisation
for
the
development
on
Rem
of
Farm
123 Witteklip Vredenburg.
Please note that the Biodiversity study as conducted by our EAP/Pri Sci
Nat. (Ecology) and fully included in this application pertinently indicated
that this site does not comprise/contain any CBA (critical biodiversity area)
elements.
This specialist report was submitted in the first instance for scrutiny to
Cape Nature and after acceptance of such further assessed by DEADP.
The EMF is based on available information from various
scientific and government organisations. These are
databases that are applied uniformly. It is not the
purpose of the EMF to update these databases based
on individual studies. The updating will be controlled by
the organisations that are the custodians of this
information. Applicants should you the EMF as a
screening and scoping tool. The EMF does not remove
the need for site work, groundtruthing / verification of
information (on the ground) and specialist studies.
26.
See attached map and extract from our process specialist report for your
information to confirm the above
More info can be forwarded should such be required
 It is earnestly requested by client that SBM update your EMF at the
hand of this site specific and credible input to reflect a verified situation
on the ground
Herewith
Extract from CLES specialist Bio diversity report as submitted to CN &
DEADP during EIA process
Page 9 of this report specifically refers
“7.1. Habitats & Ecosystem Process
Observation:
The study area lies within the Saldanha Granite Strandveld region of the
Cape Floristic Region (“CFR”). The CFR is one of the world’s six Floral
Regions.
Some of the flora species identified on site during the survey include:
o
o
o
o
o
o
o
Amaryllis belladonna
Brunsvigia orientalis
Haemanthus pubescens
Carpobrotus quadrifidus
Solanum linnaeanum
Lycium ferocissimum
Asparagus capensis
No red data flora species were identified during the survey.
Findings:
A section of the proposed development site falls within the Critical
Biodiversity Areas as identified by Cape Nature see Appendix 1. The most
northern section of the CBA is described as mostly degraded /
transformed, while the section clasified as a CBA next to the road been
described as mostly natural to near natural. This is hover not correct. The
site assessment revealed that the northern section of the site is mostly
natural although degraded at some places, while the section next to the
27.
road is totally transformed.
This survey did identify the following sections of the study site as
regionally important from a biodiversity point of view (also see photo 1
Indicating granite outcrops, streamline, dam and wetlands areas):
o
o
The granite outcrops in the north-east.
The streamline, dam and fountain with wetland in the east.
28.
Figure 1: Ecological Features on Site
29.