COMMENTS ON FINAL EIA REPORT FOR THE PROPOSED LANGHOOGTE WIND FARM, BOTRIVIER

Department of Environmental Affairs,

Ms Thulisile Nyalunga (Langhoogte Case Officer)

By email: tnyalunga@environment.gov.za

5 April 2013

COMMENTS ON THE FINAL 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. Nyalunga ,

Please find below our comments on this FEIA. Please note that no responses were received to our comments on the Draft EIA from either Sagit or Gibb, nor were any responses recorded in Appendix D9.B as they should have been.

AVIFAUNA

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?

Revised Final Avifauna report

• A revised “Final” baseline study has now been provided, with a few amendments to the previous version received on the 4^th February 2013, after the Open Day.

•  Survey dates have now been provided following our comments on the previous “Final” DEIA report but still do not represent 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. Observations from the CAR project suggest that the peak breeding season is in late December (personal communication).

•  This 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).  Quite simply, a 2½ month period of vitally important surveying for the prime priority species, Blue Crane, has  not been performed.

·         It is essential, and should be made a condition of approval, that feeding and water troughs are only placed well away from all turbines, with suitable buffer zones defined.

• Water bodies – only a “large dam” is mentioned, ignoring the other 55 smaller water bodies on site very likely to be used by Blue Cranes and other species.

• There is no analysis of the use of these many water bodies, nor has any attempt been made to delineate avifaunal buffer zones around them.

•  It is proposed that there should be water body and wetland avifaunal buffer zones of a radius of 300 metres (not the 30 & 50 metre wetland buffers). (The DEA&DP site selection guideline shows buffers for rivers 500m; local wetlands 500m; bird habitats and flight paths 1000m)

·         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.

·         This report will remain incomplete at least until the follow-up surveys are conducted in September – November 2013 to gather further information on the presence of a potential Denham’s Bustard leks.

Extensive area of the site not surveyed

·         The author admits to limitations in that vantage point observations are biased towards larger, closer, more visible species, and that the distributions of species from transect counts may not be representative of the whole site.

·         We wholeheartedly agree that these are serious limitations. This is amply demonstrated in Fig.1 which illustrates that the area within the red ellipse, containing nearly half of the turbines, has been largely ignored.

·          There are no transects through this large important area which contains wetlands of high and moderate importance and much other vegetation, forming ecological corridors and areas used for feeding and breeding of priority species. Yet this same area was extensively visited and checked during the Bat and Wetland Surveys.

·         It is highly likely that if this area been properly investigated, other Blue Crane nests would have been found, as well as evidence of use by other priority species including Denham’s Bustards, Karoo and Southern Black Korhaans, Secretarybirds and Black Harriers.

·         Vantage points 3, 4 & 5 are far distant from each other with much undulating topography separating them.  Straight line distance are: VP4 to VP5 =5.3 Km; VP4 to VP3 =4.8 Km; VP3 to VP5 =2.9 Km.

Fig. 1 Area with no avifaunal transect routes or counts, and partial coverage from vantage points

• The author states that “Re-colonisation of the site by Blue Cranes after the construction phase is likely based on the species’ known tolerance for anthropogenic related sources of disturbance.”  This is then contradicted by the quotation from Bidwell’s paper which states that “This study demonstrates that cranes select against sources of human disturbance by selecting large fields, and by selecting fields and sites that are far from roads and buildings.”

• It is patent nonsense to compare normal farming infrastructure and activities with an industrial scale development such as this, which includes 44 turbines up to 160 metres in height and covering a total area of 7 hectares, 54 km of roads with a total coverage of 54 hectares, and over 8 Km of power lines.

• There is no reference site as recommended in the Best Practice Guidelines.

• This report is seriously inadequate and much fieldwork has yet to be initiated let alone completed. Decisions regarding environmental authorization should be postponed until the fieldwork and report are completed and all deficiencies redressed.

BATS

• Surveying reported so far in the EIA document was based on a visit restricted to 3 days in winter, in heavy rain during a cold front, which is inadequate for a baseline bat assessment survey. Only sections of the site were accessible by vehicle.
• 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.
• 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 is being used, which may not, in reality, be suitable for best practice. No information was provided regarding the analytical software being used.
• We are informed that pre-construction monitoring commenced in September 2012, whereby passive long-term bat detectors are being used to continuously detect and record bat calls for a 12 month duration, as well as further site visits to cover all 4 seasons in a 12 month period to conduct transect monitoring. This baseline monitoring must be regarded as being part of the EIA process to enable turbine micro-siting and decision-making by the DEA, and will not be complete until late 2013.

·         The author’s attention is brought to the Coega study – see reference.

 VEGETATION

• Errors and omissions from the Scoping Reports have still not been corrected despite being pointed out by CapeNature and an undertaking by the EAP to do so in the EIA.

Ø  Kogelberg Sandstone Fynbos was incorrectly classified as “Least Threatened” whereas it is in fact listed as “Critically Endangered”.

Ø  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.

• 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. Five turbines and extensive stretches of internal roads are either within or close to areas of renosterveld and can be expected to impact on and destroy the natural vegetation.

• The total affected ground area will amount to 54 hectares for roads, with turbine sites adding a further 7 hectares and the substation 0.7 hectares.

• 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. There have been no on-site botanical assessments.

• 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.

CUMULATIVE IMPACTS

• All  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 immediately adjacent ‘Caledon Wind Farm’  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.

Fig. 2 Cumulative area of planned and authorized WEFs

• 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 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.”

Bearing in mind resource constraints within the DEA, it is proposed that access to the site should be allowed for bona fide observers during the operational phase.

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.

In summary

This FEIA should be rejected in its present state as it is inadequate for informed decision-making due to:

1.       the lack of avifaunal and botanical field assessments of the power lines

2.       the huge area of the site (Fig.1) which has not been assessed from an avifaunal perspective

3.       avifaunal and bat assessments have not been completed

4.       avifaunal buffers have not been defined around wetlands and water bodies

 

Cc.

By email to:

Jacqueline de Goede, GIBB Langhoogte WEF Public Participation Office, Walter Fyvie, GIBB

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

1. 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

2. Best practice guidelines for avian monitoring and impact mitigation at proposed wind energy development sites in southern Africa, 2012.

http://www.birdlife.org.za/images/stories/conservation/birds_and_wind_energy/monitoring_guidelines.pdf

3. South African Good Practice Guidelines for Surveying Bats in Wind Farm Developments, Draft 3, 2012.

https://www.ewt.org.za/Portals/0/ewt/workgroups/WEP/WindSensitivity/South%20African%20Good%20Practice%20Guidelines%20for%20Surveying%20Bats%20in%20Wind%20Farm%20Developments%20_May2012.pdf

4. Avian Wind Farm Bird Sensitivity Map.

http://www.birdlife.org.za/conservation/birds-and-wind-energy/windmap

5. DEADP Guideline on Biodiversity Offsets. October 2011

6. Coordinated Avifaunal Roadcounts (CAR) Project;  Animal Demography Unit , Dept. of Biological Sciences, UCT 

7. 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

8. 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.

9. K. McCann, K. Morrison, A. Byers, P. Miller and Y. Friedmann editors. 2001. Blue Crane (Anthropoides Paradiseus). A Population and Habitat Viability Assessment Workshop. Final Workshop Report. Conservation Breeding Specialist Group (SSC/IUCN)., Apple Valley, MN.

10. 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