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.