Coastal & Environmental Services
P O Box 934
GRAHAMSTOWN, 6140
Copy: Ms. Mmatlana Rabothata, DEA; Ms. Marbé Herbst, DEADP
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.
