Latest environmental setback for Greyton

It would appear that the proposed Scholz River storm water management scheme will result in the destruction of one of our very few local wetlands - click on the attached Google Earth image for a mock up.

Ecosense, the environmental practitioners will soon be holding a stakeholders meeting - go and have your say!

COMMENTS ON FINAL SCOPING REPORT FOR CALEDON WIND FARM

Mr Jan-Willem de Jager,

Arcus Gibb (Pty) Ltd

By email to: jdejager@gibb.co.za

21 September 2010

COMMENTS ON FINAL SCOPING REPORT AND EIA FOR PROPOSED CALEDON WIND FARM

DEA Ref: 12/12/20/1701.

Dear Mr de Jager,

1. We were dismayed to note that in addition to the changes outlined in your letter dated 17 September 2010, the following significant changes were made to the FSR, thereby downgrading the previously stated commitment:

DSR “Avoiding, at all costs, the placement of wind turbines within Renosterveld vegetation occurring within the study area, regardless of the wind data in those regions”

FSR “Avoiding the placement of wind turbines within Renosterveld vegetation occurring within the study area”

Quite apart from the above, all turbines and infrastructure should avoid Renosterveld.

2. EIA Plan of Study

This chapter is lacking in detail and methodologies.

Fauna

• Frog and bat studies are highly specialized areas of zoology, and should be performed by different experts, not only by your Faunal Specialist (who is in fact a botanist).

• The report 'lumps' bats with frogs seemingly with little understanding that the two taxa are very different in every aspect of their natural history. Designing surveys for frogs has no relevance for a taxon that has an aerial and migratory lifestyle, with a likely territory of many kilometers and if their migrational range is considered, this may be more than a thousand kms. There should be a separate section for the consideration of the impacts on bats.

• There is no mention of such studies. Will they be undertaken, and if so by whom? If not, why not?

• Our previous question regarding the Cape Dwarf Chameleons which are native to renosterveld remains unanswered. Will these Chameleons be subject of a specialist study? If not, why not?

Bats

Dr Sandie Sowler PhD MIEEM, an international authority on bats has contributed the following comments:

“Bats may be affected in different ways – collision or death by barotrauma, and loss of foraging have been mentioned in the Fauna Report. Additional effects are interruption of commuting routes, which may be a major threat, and the emission of ultrasound by turbines. The migratory routes to and from the De Hoop Reserve are unknown at present, but wind farms may pose significant threats.

Surveys should not only be undertaken in the summer to identify local foraging bats, but also in the spring and autumn when bats may be migrating into and out of the Western Cape, to or from their hibernation sites. In view of the agricultural role of bats, all species, not only ‘Red Data species should be considered.

In the UK, the duration of surveys demanded would cover several years in order to gain a full picture of how the proposed site is being used. To inform survey design, thorough data trawls should be undertaken including information regarding the bats of De Hoop and their known movements. Survey techniques may include automated bat detector surveys as well as perhaps some radio tracking.

I would suggest that whoever wrote this scoping report has only read a fraction of the considerable weight of literature that is out there regarding bats and wind turbines. It would be interesting to speculate if this wind farm (and others) was to adversely affect migrating bats travelling to De Hoop, whether the local farmers who use the ecosystem services of bats for insect control, could legitimately sue the wind farms for the increased cost of pesticides!!”

Because of the lack of knowledge about bats in South Africa, the precautionary approach to impact assessment should be adopted.

Avifauna

The scoping reports have relied on desktop data from programmes which were not intended or designed for use in EIAs. Extensive field work will have to be undertaken over an extended period covering all seasons for a proper assessment to be made. The Terms of Reference for the bat and avifaunal studies must include ongoing monitoring programmes for injuries and mortalities during the operational phase.

Below are some selected quotations from the “Briefing Document on best practice for pre-construction assessment of the impacts of onshore wind farms on birds”, written by Mike Jordan and Jon Smallie for The Endangered Wildlife Trust’s Wildlife and Energy Programme. It is compiled from international information, guidelines and experience. Much of it also applies to bats. Until the definitive best practice document has been published this current document should inform the EIA process and the avifaunal and bat studies.

a)      “Onshore wind farm developments have the potential to adversely affect bird populations in three main ways; displacement & disturbance, habitat loss & fragmentation, and direct mortality through collision. This briefing document discusses best practice from Australia, Canada, the EU, the UK and the USA with regard to pre-construction assessment of the potential impacts. It does not discuss offshore developments or post-construction assessment of affects.”

b)      “There is a general consensus that in virtually all cases baseline information has to be collected by actual observations at the proposed wind farm development site and that quantitative data on actual bird usage of the site is required to adequately assess the potential impacts.”

c)       “There is a complete consensus that the duration of bird studies at a potential wind farm site must as a MINIMUM cover all of the normal variation in bird usage at the site; including breeding, wintering/non-breeding and passage/migratory movements through the site; normally at least a minimum of one year of field observations, and generally if species of particular concern are present studies should span longer periods than a year.”

d)      “There is a general consensus that baseline information has to be collected from across the entire proposed wind farm site and including a buffer area dependent upon the species of concern for which data is being collected. Point observations specifically for the calculation of collision risk should cover the entire site and a small buffer to allow for observer error.”

e)      The UK minimum guidance for observations to assess collision risks are:

“The recommended minimum is that 36 hours of watches should be conducted at each VP (Vantage Point) for each season (breeding, non-breeding, migratory) when the species is present. Each season should be regarded as a discrete observation period. Within each season, each part of the wind farm should be watched for at least 36 hours. If half of the proposed wind farm area has been watched for 36 hours, for example, and the other half has been watched for 36 hours (with no overlap in visibility areas), then the proposed wind farm area has been watched over for 36 hours (the time spent observing each part of the proposed wind farm), and NOT 72 hours (the total time spent in observation).”

f)        “There are well established protocols for the collection of normal ornithological survey data, however there is a general consensus that special emphasis should be placed on the observations necessary to provide the data required to calculate predictions of collision risk. These observations are unique to the assessments of wind farm impacts and may involve special protocols and additional skills.”

g)      “There are common features to the criteria used in most regions to identify target/key species for EIA. These criteria typically comprise a combination of species deemed to be at risk from wind farms, globally/nationally red listed species, species listed under protection in national legislation; international migratory species and species occurring at low/very low density. Such criteria could easily be applied in a South African context.”

h)      “Collision mortality may be an ongoing impact for the entire operational life of the wind farm and if affecting wide ranging species then may have the potential to adversely affect whole regional, national or international populations of a species.”

i)        “There is general consensus that merely predicting whether or not an impact will occur is insufficient. Assessing the actual significance of predicted impacts is critical to the planning approval/refusal process. This presents particular challenges for wind farms and birds where the impacts may be ongoing for the entire operational life of the wind farm and also affecting large wide ranging populations. Increasingly Population Viability Analysis is used to put these impacts into perspective.”

j)        “There is a general consensus that assessing the impacts for each wind farm in isolation does not adequately assess the true significance of the impacts for bird populations. Greater attention needs to be placed on assessing the cumulative impacts of all operational, consented or planned wind farms (and other relevant developments) on target/key bird species. In some cases insignificant impacts at individual wind farms will accumulate across all wind farm developments to have a significant adverse impact upon birds.”

Visual

Notwithstanding the proposed Specialist Visual Report, TWK Municipality’s Mr. Jan Visagie has given assurance to the DEADP that no wind energy facilities be allowed in the 2 km buffer zone along the N2 (which has been classified as a scenic route within this area), especially in the area where the road descends the Houw Hoek Pass towards Caledon. In addition, it is the stated intention of the municipality that wind energy facilities should not be visible along the N2. How are these undertakings to be satisfied?

As a general comment, the blithe statements that “Data Gaps” should be highlighted and discussed are just not good enough – best practice would dictate that every effort should be made to fill those gaps.

We expect that all comments in this letter will be taken into account during the EIA phase, and will be circulated to other I&APs. We reserve the right to revise these comments and to make more comments if considered necessary.

Yours sincerely,

Stuart Shearer

Birdlife Overberg