To:
Jacqueline de Goede, GIBB Langhoogte WEF Public
Participation Office
Walter Fyvie, GIBB
By email: langhoogtewef@gibb.co.za;
wfyvie@gibb.co.za
7 February 2013
COMMENTS ON DRAFT EIA REPORT FOR THE PROPOSED LANGHOOGTE WIND FARM
DEA Ref: 14/12/16/3/3/2/260; DEA&DP Ref No.: E12/2/4/7 -
E4/5-CJ2275/11
Dear Ms. De Goede andMr.
Fyvie,
Please find
below our comments on this DEIA.
AVIFAUNA
FSR
With reference to previous comments and the response in
the scoping phase regarding offsets for
Blue Crane mortality, the EAP clearly does not understand irony. To clarify, we
repeat ”It is difficult to imagine what possible offsets could be conceived to
compensate for the probable population, regional and national level mortality
on Blue Cranes.”
Power lines
- To quote, “The most important associated infrastructure from a potential bird impact assessment perspective is the planned power line which will connect the wind farm to the grid at the Houhoek Substation.”
- There has been no avifaunal assessment of the proposed power line routes and the adjacent wetland, riverine and renosterveld habitats. Habitat destruction, and consequent displacement from that, and due to disturbance, has not been assessed. Nor have collision risks during the operational phase been assessed.
- This represents a serious flaw in the Avifaunal Report, and is purportedly “due to resource constraints”.
- And this despite the admission that power line collisions might be a significant impact for Blue Crane and Denham’s Bustard, for which a 10% annual mortality for the former, and up to 30% annual mortality for the latter have been estimated in this region, and which is one of the 4 major potential avifaunal impacts of the WEF, representing “a possible unsustainable source of unnatural mortality”.
- It is a grossly inadequate to seriously propose that mitigation in the form of “Bird Flight Diverters” being placed along the entire power lines will reduce risk significance from high to medium. No evidence has been provided to support this conclusion.
- How, why and by whom were the resources not allocated to this vital area of study?
Final Avifauna report
- A copy of the full “Final” baseline study was provided late on the 4th February 2013, following a request at the Open Day on 30 January.
- No details were provided regarding the actual dates of field visits. No additional hot spots were identified. Vantage Point 1 was moved away from the area in which Denham’s Bustards had previously been seen displaying, to another location far removed from proposed turbine sites, with no reasons being provided.
- The following survey dates were outlined - Late summer: March 2012 ,Late autumn: May - early June 2012, Late winter: August – early September 2012 and Late spring: Mid November 2012 - early December 2012. Hardly a full year of baseline surveying as should have been done.
- The peak breeding period of the Blue Crane in the Overberg of mid-December through January has been evaded. Which is no doubt the reason why no additional Blue Crane nests were identified throughout the study period considering the large numbers of cranes present in the area. (CAR Project Database). In other words a 2½ month period of vitally important surveying for the prime priority species, Blue Crane, has not been performed.
- It is stated that if monitoring during the operational phase reveals high mortality of Blue Cranes, then “the landowners must be sensitised to the fact that the feeding of sheep close to a turbine may create a high risk collision potential for Blue Cranes, and should therefore be avoided if at all possible.”
- We agree entirely with that caveat but surely it would be better to do this pre-emptively rather than awaiting results of mortality counts, with all the uncertainties associated with carcase monitoring? Have the farmers confirmed the feasibility of so doing? If feeding stations cannot be changed then this should form part of the micro-siting assessment, taking into account site rotations due to crop and camp rotation.
- It is established fact that Blue Cranes roost in water bodies, and prefer nesting nearby. Dams and wetlands therefore constitute habitats of high risk potential for causing collisions with power lines, not only for Blue Cranes which often arrive at times of poor visibility, but for other species such as White Storks.
- Another serious deficiency is that the avifaunal report does not contain an analysis of the use of the many water bodies present on this site, nor has any attempt been made to delineate avifaunal buffer zones around such water bodies.
- No mention is made of a control or reference site as recommended in the Best Practice guidelines.
BATS
- Surveying reported so far was based on a visit restricted to 3 days in winter, in heavy rain during a cold front, which is hardly conducive to a baseline bat assessment survey. Only sections of the site accessible by vehicle , in pouring rain were traversed.
- Despite the authors’ admission that “Bat detection will be significantly lowered..” in those circumstances, they go on to say that it only “..slightly compromises the assessment of the extent of habitat use by bats”, and “the sensitivity map generated remains credible”. Surely this is nonsense.
- We are informed that pre-construction monitoring commenced in September 2012, whereby passive long-term bat detectors are used to continuously detect and record bat calls for a 12 month duration, but no analyses or reports have yet been completed.
- However, following a request at the Open Day for an indication of the methodology being used for bat monitoring a résumé was made available. A Time Expansion system was referred to but the equipment model stated as being used, the “SM2bat+”, does not have Time Expansion capability. This would appear to indicate that the specialist is uncertain of which technology he is using, which may not, in reality, be suitable for best practice. No information was provided regarding the analytical software being used.
- The author’s attention is brought to the Coega study – see references.
VEGETATION
- Errors and omissions from the Scoping Reports have not been corrected despite being pointed out by CapeNature and an undertaking by the EAP to do so in the EIA.
o Kogelberg Sandstone Fynbos was incorrectly classified
as “Least Threatened” whereas it is in
fact listed as “Critically Endangered”.
o The Overberg CBA map shows the Critically Endangered
Ecosystem of Western Rûens Shale Renosterveld as occurring on site – but the
Ecology Report claims that none remains. Where is the evidence for this
assessment? (Theewaterskloof Municipality's Spatial Development Framework is
quoted but not referenced)
- Although much of the land has been transformed, there is still sufficient remaining renosterveld to warrant close investigation during all seasons of the year, and its subsequent protection. Natural vegetation must include that which has been partly invaded by alien vegetation, as in many instances it is capable of recovery. All turbines and elements of infrastructure should be placed so as to avoid Renosterveld, whether partly transformed or pristine, and additionally so as to avoid interrupting ecological corridors. At least 2 turbines and extensive stretches of internal roads (in the current layout plan) are close to renosterveld and could be expected to impact on the natural vegetation.
- Two of the southern power line routes are to pass through areas of Critically Endangered Rûens Silcrete Renosterveld, whilst a third route is marked as additionally encroaching on Cape Lowlands Freshwater Wetlands, also Critically Endangered .
- It is essential that specialist botanical studies should be performed by an expert in the flora of the area wherever there is a possibility of affecting natural vegetation by the wind farm and its infrastructure.
- We are however pleased to note that issues around existing and potential spread of Invasive Alien Vegetation have received considerable attention in the Draft EMP.
CUMULATIVE IMPACTS
- All the potential local and regional cumulative impacts of this and the three proposed neighbouring wind farms must be addressed comprehensively – detailed information on the other sites is freely available in the public domain, with the larger development also being assessed by Gibb, so they must all be considered. This is particularly so for impacts with low certainty, but with potential for serious impacts.
- It is imperative that the DEA and DEA&DP consider cumulative impacts of this and other WEFs in the vicinity.
In conclusion, it should be imperative that results of
both the avifauna and bat monitoring programmes should be made available to all
registered I&APs and sufficient time allowed for further comments before
completion of the Final EIA Report. The final plans, layouts and micro-siting
of all components of the wind farm should be informed by the necessary data. It
is inconceivable that Authorisation can be even contemplated by the Competent
Authority before all data are available.
We fully support
the statement by CapeNature that “A
final layout must be provided and it must be reviewed and approved by all of
the specialists before it is included in the Final EIR which is submitted for
authorisation.”
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.
Cc.
By email to:
BirdLife South Africa; Endangered
Wildlife Trust; CapeNature; BirdLife Overberg; Overberg Lowlands Conservation
Trust; Overberg Crane Group; CAR Project, Animal Demography Unit
Copy Ms Nyiko Nkosi, DEA, nnkosi@environment.gov.za
Copy Marbe Herbst, DEADP, marbe.herbst@pgwc.gov.za
REFERENCES
- Modelling power-line collision risk for the Blue Crane Anthropoides paradiseus in South Africa
Jessica M. Shaw,
Andrew R. Jenkins, Jon J. Smallie, Peter G. Ryan: Ibis (2010), 152, 590–599
- Best practice guidelines for avian monitoring and impact mitigation at proposed wind energy development sites in southern Africa, 2012.
- South African Good Practice Guidelines for Surveying Bats in Wind Farm Developments, Draft 3, 2012.
- Avian Wind Farm Bird Sensitivity Map.
- DEADP Guideline on Biodiversity Offsets. October 2011
- Coordinated Avifaunal Roadcounts (CAR) Project; Animal Demography Unit , Dept. of Biological Sciences, UCT
- Strategic Initiative to Introduce Commercial Land Based Wind Energy Development to the Western Cape. Towards a regional methodology for wind energy site selection. Report 6: Proposed Project Level Methodology. DEADP
- Breeding habitat selection and reproductive success of Blue Cranes Anthropoides paradiseus in an agricultural landscape of the Western Cape, South Africa. Mark T Bidwell. Unpublished MSc thesis (Conservation Biology), Department of Zoology, UCT. March 2004.
- AC Doty & AP Martin (2012): Assessment of bat and avian mortality at a pilot wind turbine at Coega, Port Elizabeth, Eastern Cape, South Africa, New Zealand Journal of Zoology,
DOI:10.1080/03014223.2012.741068
http://dx.doi.org/10.1080/03014223.2012.741068
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