Shawn Johnston, Sustainable Futures ZA
14 January 2015
COMMENTS ON REVISED DRAFT EIA REPORT FOR THE PROPOSED GOEREESOE WIND
FARM, NEAR SWELLENDAM DEA Ref: 12/12/20/2199
Dear Mr Johnston,
Please find below our comments on the Revised DEIA
dated November 2014.
- FAUNA
This Specialist report is wholly inadequate, with only
one day-time site visit on 1 Nov 2012, and should be disregarded.
Even the author of the report admits to it being
unrepresentative as there were no seasonal visits. The proposed mitigation
measure of removing threatened fauna to a safe location is patently absurd.
- AVIFAUNA
Knowledge of SA avifauna of some of the field observers
is again questioned. There are no peer
reviews of the avifauna survey data. For
instance, a reported sighting of Black-chested Snake Eagle, Circaetus pectoralis, seems highly unlikely.
More likely this was confused with the Endangered Martial Eagle, Polemaetus bellicosus, which are known
to occur in the area, and can be misidentified by inexperienced observers. The
same applies for purported sightings of Ludwig’s Bustard. Many other common species are omitted.
The CVs of all observers, including specific
experience in SA bird identification, should be provided.
The proposed site is within the Overberg Wheatbelt) Important
Bird Area (IBA) (OV115), and is sandwiched between the De Hoop Nature Reserve
IBA (SA119), which has full protection, and the Bontebok National Park (South
African National Parks 2012).
Cape Vulture ( Gyps coprotheres)
The proposed development is situated well within the
40Km buffer zone around the Potberg Cape Vulture colony recommended in the SEA
for wind development (2013).
Blue Crane, Anthropoides
paradiseus, monitoring was woefully inadequate:
Nest Searches
Only 4 nest searches were conducted in total, not
optimally timed to discover Blue Crane nests, although the report admits to the
likelihood of them breeding within the area.
Of the total of 4 nests discovered the species could
only be identified in one of them, throwing doubt on the timing, methodology
and field observer expertise.
Flight movements
Blue Crane flights were mostly missed due to observers
being present in daylight hours, whereas this species is known to fly in extremely
low light conditions. There is therefore no possible way in which collision
risks could have been assessed for this globally Vulnerable species.
There is no evidence to support the statement “The pre-construction monitoring confirmed
the site to be of low
sensitivity from an
avifauna habitat perspective since the site (and the general surrounding area)
is heavily
transformed by
agriculture.” It serves only to demonstrate again the
ignorance and lack of understanding of this varied habitat by the ‘specialists’
It is clear from the DEIA statement that the entire
project should be abandoned as relocation of 10 turbines would not be feasible
and there is no confidence that proposed mitigation measures would succeed in
significantly reducing adverse impacts on avifauna: –
“In terms of the proposed Goereesoe Wind
Energy Facility, avoidance of the impact on avifauna would require the
relocation of all but 4 of the proposed turbines to areas of lower
sensitivity.”
The precautionary approach must be followed as there
is a high probability of negative impacts on local and regional avifauna.
BirdLife South Africa has recommended that important habitats for species such
as Blue Cranes and Denham’s Bustard (and Black Harrier) must be avoided until the
results of post-construction monitoring of already approved wind farms become
available for analysis before further wind farms are considered in the area.
- BATS
Appendix I, the Bat Impact Assessment Report is
exactly the same one that was included in the first DEIA. On questioning this with the EAP company,
Savannah, they replied that EWT had withdrawn and therefore the Bat Specialist
Report did not include findings from Pre-construction monitoring.
The results of pre-construction bat monitoring
conducted by Bio3 and then Bio Insight SA are published in a separate report,
from which Savannah, the EAPs, have selectively quoted in the Revised DEIA.
The proposed development is situated close to the 20Km
buffer zone around the De Hoop Guano Cave bat roosts where several hundred
thousand bats are estimated to roost. (SEA for wind development (2013)).
What is meant by “feasible” when not moving turbine
positions to safer locations? Technically, economically, profit-related? To
quote:
“Nonetheless
such measures should
only be implemented
if necessary and
they should be
carefully planned in order to find the best trade off in
reduction of the collision risk and minimize the loss in revenue resulting
from mitigation.”
Repeated recommendations of increased monitoring of
high-risk turbine positions does not constitute mitigation and is not a
substitute for removal of turbines from high-risk areas. The damage will have
been done, and as the chances of a WEF being closed down due to bat mortality
are vanishingly small, will continue for the lifetime of the development, and
beyond.
Section 5.2 of the Monitoring Report this observation was omitted
from the DEIA:
“The occurrence of at least one species
considered to have a medium to high collision risk with wind turbines, Near
Threatened conservation status (Friedmann & Daly 2004), with confirmed
utilization of the rotor swept area, and with a large population in a nearby
roost (i.e. Miniopterus natalensis) raises severe concerns regarding the impact
that the
Goereesoe Wind Energy
facility operation may have
on the species
population. …. the precautionary approach is recommended as this is a
species of conservation concern.”
Section
8.5.3 of the Revised DEIA:
“The overall
impact of the development is likely to be moderate to high if steps to
mitigate impacts are not taken. This was confirmed through the pre-construction
monitoring programme, this sensitivity is particularly due to the presence of
roost, including the De Hoop Guano Cave, located at less than 20km from the
study area, and features of higher importance for foraging bats.”
“Since
this study showed that bats occur across the entire study area assessed it is
likely that the proposed development will have a high impact on bat
populations though collisions and barotrauma even with appropriate mitigation
measures.”
There is no certainty that any mitigation measure,
effective of otherwise, will actually be implemented during the operational
phase. Who is there to monitor or enforce any recommendations?
- VEGETATION
Comments from the Overberg Lowlands Conservation Trust
on the botanical aspects of this EIA are fully supported, as are those
concerning the fauna and avifauna assessments.
- CUMULATIVE IMPACTS
All the potential local and regional cumulative
impacts of this and the three proposed neighbouring wind farms, two of which
have received authorization, must be addressed comprehensively.
It is stated in 8.5.1 of the Revised EIA that:
“… Compounding – the impact of two
developments of a similar nature is likely to be more than twice the impact of
two single developments. To reduce the possibility of displacing bats from
foraging areas in the area it would be better to place a second development in
a different area.”
It should be pointed out that the development referred
to above, the Biotherm Uitkyk & Excelsior WEF, was already authorized 3
years ago, therefore it is the Goereesoe development which should be “placed in
a different area”.
It is imperative that the DEA and DEA&DP consider
cumulative impacts of this and other WEFs in the vicinity.
In conclusion, it is
proposed that the proximity of this proposed development to the Potberg Cape
Vulture colony alone should constitute a Fatal Flaw and preclude any WEF
development at this site.
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.
Yours sincerely,
Cc. By email to:
BirdLife South Africa; Endangered
Wildlife Trust; CapeNature; BirdLife Overberg; Overberg Lowlands Conservation
Trust; Overberg Crane Group.
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
- DEA National
Wind & Solar PV SEAs, CSIR Environmental Management Services, 31 July
2013
- 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,
