BRAKKEFONTEIN WITHDRAWN!

It is with great pleasure that Greytonian can announce that this ill-conceived wind farm proposal has been cancelled by the developer, Terra Power Solutions. This is what the EAP, Thomas King wrote:

"Dear Interested and Affected Parties and key stakeholders

As you are aware CES recently conducted an Environmental Scoping process for the above mentioned project that was initiated by Terra Power Solutions (TPS) in the Bonnievale area. Over the course of the last few months it has become apparent that the wind resource on the site, which has been subject to an approximately year-long monitoring programme, is not sufficient to justify the project proceeding. This is compounded by the fact that the feed in tariff (the price that the relevant government agency pays to independent power producers - IPPs) for wind energy has substantially decreased from its initial pricing levels, rendering the proposed project financially unviable

Coupled with the environmental sensitivities of the site and its surroundings, as well as the numerous conservation initiatives in various stages of development or implementation in the project area that were brought to CES and TPS attention during the Scoping process, the applicant has decided to withdraw the application. 

Please be aware that the national Department of Environmental Affairs has been informed of the reasons for withdrawal by CES and acknowledgement of this is still awaited from them. Please accept this correspondence as the final round of notification for this project.

Thomas King

Environmental Consultant

Coastal & Environmental Services"

BRAKKEFONTEIN - ABBREVIATED COMMENTS ON DSR

Mr. Marc Hardy

Coastal & Environmental Services

P O Box 934

GRAHAMSTOWN, 6140

Copy: Ms. Mmatlana Rabothata, DEA; Ms. Marbé Herbst, DEADP

By email to: m.hardy@cesnet.co.za; t.king@cesnet.co.za; mrabothata@environment.gov.za;

Marbe.Herbst@pgwc.gov.za

28 September 2012

COMMENTS ON DRAFT SCOPING REPORT FOR THE PROPOSED BRAKKEFONTEIN WIND ENERGY PROJECT.

DEA Ref: 14/12/16/3/3/2/35; DEADP Ref. 16/3/1/6/6/B1/4/1056/12

Dear Mr Hardy,

There is much evidence of carelessness in the preparation of this DSR, the first example being the statement that 30 turbines will be erected and then every subsequent figure shows 26 turbines.

 Receiving environment

A significant portion of the project area is situated in the ‘Riviersonderend Mountain Catchment Area and Nature Reserve’, and the entire proposed development is adjacent to other conservation areas, as well as being in a Critical Biodiversity Area (CBA)- Figure 1.

Figure 1

Flora

It is flabbergasting that this project intends to place all the turbines and supporting infrastructure in natural vegetation, and mostly on ridges. This flies in the face of environmental good practice and is in direct contravention of the “Strategic Initiative to Introduce Commercial Land Based Wind Energy Development to the Western Cape – Towards a Regional Methodology for Wind Energy Site Selection” and the “Guideline for the Management of Development on Mountains, Hills and Ridges of the Western Cape”. 

Assessment according to the criteria in these two documents, show this development to be at the extreme level of unsuitability. This is in terms of highly undesirable visual impact and loss of sense of place with high probability and significance, as well as the extensive destruction of fynbos and renosterveld.

The following assessments from the Ecology Issues table are noted:

“The wind farm could result in a permanent physical loss of important habitat and species on the land required for the turbines and ancillary elements. There could additionally be habitat severance and fragmentation, particularly from linear elements such as the access tracks.”

It is not a matter of “could” but “will” result in permanent loss…..This has serious implications for the survival of remaining renosterveld, fynbos and biodiversity in the area and makes it mandatory for a specialist botanical study to be performed by an expert in the flora of the area, and not be demoted as a part of the terrestrial ecology study and report. Ecological Impact Assessment requires separate specialist studies.  The only motives for combining the two could be at best for financial expediency, or to obfuscate the very real issues at stake.

The extent of the disturbance and habitat loss is grossly and disgracefully misrepresented. It is stated that the internal roads amount to only “minor excavations”. Although the internal access roads are stated to be 6m wide with cable trenches alongside, the actual disturbed and lost habitat will be effectively much wider, say ± 10m. With an estimated total length of ± 20 Km this will lead to a natural vegetation loss of 20 hectares, much of this on sensitive ridges and in valleys. This is probably an underestimate.

Turbine foundations and associated hard-standings will amount to at least 4 hectares

The substation will cause a further loss of at least 0.5 hectares.

‘Temporary’ crane access tracks will cause additional disturbance and destruction as will the borrow pits and material lay-down areas of as yet undetermined dimensions.

Turbine footprints are being seriously misrepresented as with the mass of excavated material. If the data provided in the DSR are correct, then each turbine foundation will require the excavation of 1000 m³, not 500 m³ as stated. The use of heavy earth-moving machinery will further destroy large surrounding areas at each location.

There are real risks of invasive alien vegetation spreading destructively through all disturbed areas, including along internal roads, on this extensive site.

Avifauna

• The Brakkefontein site is situated between the Overberg Wheatbelt (SA115)and Southern Langeberg Mountains  (SA113) Important Bird Areas (IBAs), with Stormsvleipoort  being a corridor through the Riviersonderend Mountain range between the two areas. This must be investigated, using radar techniques if necessary.

• The “BLSA/EWT Best practice guidelines for avian monitoring and impact mitigation at proposed wind energy development sites in southern Africa” must be followed in the avifauna assessment, and should be specified in the Terms of Reference for the specialist study. This includes the need for the establishment and ongoing monitoring at a nearby closely matched ‘control’ or ‘reference’ site. Kindly note that these Guidelines have been accepted by the SAWEA, of which ‘Terra Power’ is a member.

• Baseline monitoring should be performed for at least one year prior to authorization and construction, with particular vigilance at the site of the existing anemometry mast, whilst post-construction monitoring should continue throughout the operational life of the facility.

• In addition to the requirements of the “Best practice guidelines for avian monitoring and impact mitigation at proposed wind energy development sites in Southern Africa”, the cumulative and barrier effects of several wind farms in the Swellendam area will have to be assessed.

• There are numerous watercourses on the development site requiring special attention, as with the many water bodies on this and neighbouring properties.

Bats

• Roosting and or maternity sites must be identified.

• It is essential to establish foraging routes in and out of the study area, including potential internal foraging corridors along the numerous water courses on site. There are many water-bodies on surrounding properties which may attract foragers.

• Migrating movements through the study area must be identified. Surveys should be undertaken in spring, summer and autumn to identify local foraging bats from neighbouring areas as well as bats which may be migrating into, and within, the Western Cape, to or from their hibernation sites. The site may represent a corridor between the Overberg cereal lands and the orchards and vineyards in the Bonnievale/Robertson areas. There is also a strong possibility of there being a migratory route between the De Hoop and Montague cave systems.

• In view of the agricultural eco-services role of bats, all species, not only ‘Red Data’ species, should be assessed.

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

• The bat studies should follow the “South African Good Practice Guidelines for Surveying Bats in Wind Farm Developments, Draft 3 2012”. Kindly note that these Guidelines have been accepted by the SAWEA, of which the developer is a member.

• Baseline monitoring should be performed for at least one year prior to authorization and construction, whilst post-construction monitoring should continue throughout the operational life of the facility.

Visual impacts

This development will be intrusively visible from the N2 and the R317, the latter being the southern access to the scenic Stormsvleipoort road winding  and the Robertson Wine Route.

The development site is situated in an area designated as restricted (Unsuitable) for wind farm development in the ‘Strategic Initiative to Introduce Commercial Land Based Wind Energy Development to the Western Cape’:

“These are landscapes in which wind energy development will be clearly inappropriate from

both a criteria based and landscape based perspective. It is assumed that no wind energy

proposal will be acceptable at all in these zones, which will have the highest incidence of

negative (exclusionary) criteria.”

Figure 11: Framework for Location of Wind Energy Projects based on Landscape Character

 

Cumulative impacts

All the potential cumulative impacts of this and other wind farms in the Swellendam area must be assessed comprehensively – detailed information on the other sites is freely available in the public domain so all must be considered. See Figure 2.

 

Figure 2

Conclusion

Full specialist reports must be provided to all registered I&APs.

We expect that all comments in this letter will be taken into account before completing the Final Scoping Report which should be amended accordingly and circulated to I&APs for comment prior to submission to the competent  authorities. This letter should be included in its entirety in the ‘Comments Report’. We reserve the right to revise these comments and to make more comments if considered necessary.

It is however abundantly clear, even at this early stage of the EIA process, that this project is fatally flawed and should not be allowed to proceed any further.

BRAKKEFONTEIN - ANOTHER OVERBERG WIND FARM

Another wind farm proposal has materialised, this time near Stormsvlei on the R317 road to Bonnievale.  It can be seen that all the turbines and infrastructure, including some 20 Km of internal roads are to be placed on ridges in threatened renosterveld at the Eastern extremity of the Riviersonderend Mountains. There will be an enormous loss of natural vegetation with associated disturbance and displacement of birds and other wildlife. Mortality of birds and bats from collision with turbines and associated barotrauma can be anticipated. This industrialisation of the landscape will detract from tourism and may well result in a net loss of local employment. The Draft Scoping Report has been published for comment before 30 September.

If anyone reading this has the slightest interest in the conservation of this environment please register as an Interested and Affected Party at  Thomas King at CESNET. The full DSR can be viewed or downloaded at Brakkefontein. Please submit your comments... Thank you.

BLSA/EWT Best practice guidelines for avian monitoring and impact mitigation at proposed wind energy development sites

These Guidelines were updated in July 2012, and significantly have now been endorsed by the South African Wind Energy Association (SAWEA) and Eskom. BLSA/EWT Avian Guidelines

OUTCOME OF THE APPEAL BY BIRDLIFE OVERBERG AGAINST THE AUTHORISATION OF THE KLIPHEUWEL/DASSIESFONTEIN WIND ENERGY FACILITY

Amendment of the Environmental Authorisation for the proposed establishment of the Klipheuwel/Dassiesfontein  Wind Energy Facility (WEF) and associated infrastructure within the jurisdiction of Theewaterskloof Local Municipality, Western Cape Province.

As a result of the Appeal by BirdLife Overberg, the DEA decision of 27 June 2011 to authorize this development was varied so as to strengthen the requirements for bird and bat monitoring, to specify that the guidelines published by BLSA and EWT should be used, and to instruct the applicant to provide monitoring data on a quarterly basis to all stakeholders, including the Appellants. Here follows a summary of the salient sections:

  

• The bird monitoring programme to be undertaken by an independent bird monitoring specialist

• A batmonitoring programme must be implemented to document the effect of the operation of the WEF on bats. This must commence prior to construction and continue during operation of the WEF

• The bat monitoring programme to be undertaken by an independent bat monitoring specialist

• The reports from the bat monitoring programme will be submitted to affected stakeholders, including the appellants and DEA, on a quarterly basis

• The birds and bat monitoring programmes must cover all listed and threatened species (TOPS), as well as other significant species identified by the respective specialists, and must include collision and mortality date during operation

• Baseline bird and monitoring must continue at least every 2^nd month for as long as possible before, and during the construction phase of the WEF

• Bird impact monitoring must produce data in the format required by the “Best practice Guidelines for Avian Monitoring and Impact Mitigationat proposed Wind Energy Development Sites in Southern Africa”, published by BLSA and EWT

• Bat impact monitoring must produce data in the format required by the “SA Guidelines for Surveying Bats in Wind Farm Developments” published by EWT

• Post constructiom monitoring must start as soon as possible, within the first few weeks of operation, and should last for at least 2 years – as opposed to the original EIA recommendation that monitoring starts 6 months after commissioning and is reviewed after 1 year of operation

• If problems are identified in the first 2 years, mitigation measures should be included in the EMP and monoitoring to continue to determeine the effectiveness of those measures

• The bat monitoring reports must be submitted quarterly to EWT, BLSA, CapeNature and DEA. The reports will assist all stakeholders in identifying potential and additional mitigation meassures and to establish protocols for bat monitoring programmes of EF development in SA

• Should monitoring results reveal serious impact on Threatened or Protected Species (TOPS), including among others, local extinction, all work must cease immediately in that area whilst all relevant authorities are notified

It was admitted by the DEA that a bat report was not considered by them as it had not been provided by the Applicant until long after the final EIA submission. After a retrospecive review the DEA states that it would nevertheless not have come to a different conclusion…

The applicant provided a copy of the Bat and Bird Reports to the Appellants only following the Appeal result. It would not appear that other registered I&APs were afforded this opportunity.

Comments on Langhoogte Final Scoping Report

Please follow the link to read Greytonian's comments on the Langhoogte Final Scoping Report - COMMENTS ON LANGHOOGTE FSR

WHY DOGS ARE NOT ALLOWED IN THE GREYTON NATURE RESERVE 

Cape Grassbird

Nature reserves are havens created to support, protect and conserve the flora and fauna in these wilderness areas.  They are home to numerous species of plants, mammals, and birds under threat from disturbance and dislocation elsewhere. 

A balance must be found between allowing access to enjoy nature reserves whilst continuing to protect them. 

Dog walking is one issue where this balance is difficult, with various people wishing to walk their dogs in these areas. The fact is that dogs in reserves can cause a significant amount of damage, mostly unnoticed by visitors. International research has repeatedly shown that dogs in natural areas, on or off a lead, result in displacement of many species of wildlife, particularly birds. Not only does this negatively affect the biodiversity of the area, but in turn impacts on ecotourism, including bird watching, which is an increasingly popular pastime throughout the world.

Orange-breasted Sunbird

Dogs by their very nature are hunters, whilst birds and small animals, by their nature, are prey. 

 

Dogs have been domesticated and bred for thousands of years and are not a natural part of our wildlife. They may be man’s best friends but they are seen as major predators by wildlife. When a dog quarters an area, it is in reality looking for prey to hunt or retrieve. Even though you may not see your dog chasing a bird or animal, wild animals sense your dog’s presence, thus causing unnecessary stress. We are talking not only of dogs that are allowed to roam, but that the very presence of dogs can disturb wildlife, for example by driving birds away from their nests to seek refuge. Many bird species are ground-nesters, such as Spotted Eagle-owls, Francolin and the Cape Rock Thrush. A mere bark is enough to disturb and affect young birds. Worse still, they can kill and maim animals.

 

Remains of a Klipspringer

The presence of dog faeces and its scent can cause animals to stay away from surrounding areas. All this has the potential to create significant disturbance to wildlife throughout the nature reserve and may also result visitors to the reserve being less likely to see and hear wildlife.

Nerine pudica

 Dog faeces are rich in nutrients – wildflowers need low nutrient soils in which to flourish. Soils over-enriched with dog faeces encourage the growth of coarser plants which compete and outgrow our unique flora.

 

If hands or food are contaminated by dog faeces serious diseases in humans can ensue, such as canine roundworm and hydatid disease, especially in young children. The water in the streams and in the Noupoort leiwater dam can also be contaminated. Other diseases such as canine distemper can also be transmitted to wildlife including various members of the cat family

One of the principle reasons people want to walk in the Greyton Nature Reserve is because it is a quiet sanctuary in which to enjoy the peace and quiet of this near-pristine environment and its wildlife.

Spotted Eagle-Owl

Rock Agama

 

We have a combined responsibility to ensure that it stays that way.

Leopard tortoise

 We hope that by spreading the message about the unique quality and value of the Reserve and the negative impact that dogs can have on wildlife and other people’s enjoyment, that dog owners will be more considerate and walk their dogs in the other extensive areas of the Commonage where dog walking is allowed. Just as importantly they must ensure that their dogs remain on their properties and are not allowed to roam.

Scrub hare

The Society takes responsibility for the day to day management with volunteer workers and part-time employees working tirelessly to maintain the habitat and facilities through track maintenance, rebuilding bridges after fires and floods, and removing invasive alien vegetation, with practically no external financial support. 

Last but not least, there are the Municipal By-Laws, the Provincial Nature and Environmental Conservation Regulations of 1975, and the NEMA: Protected Areas Act 2003 Regulations. The Greyton Nature Reserve Advisory Board is responsible for the protection and management of the Reserve and is represented by the Theewaterskloof Municipality, CapeNature and members drawn from the Conservation Society.

Please help us to conserve this special area for the protection of our wildlife and for the enjoyment of future generations of residents and visitors.

 Greyton Nature Reserve Advisory Board and the Greyton Conservation Society