The Greytonian: Goereesoe

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Thursday, 15 January 2015

COMMENTS ON REVISED DRAFT EIA REPORT FOR THE PROPOSED GOEREESOE WIND FARM, NEAR SWELLENDAM DEA Ref: 12/12/20/2199

Shawn Johnston, Sustainable Futures ZA

By email: swjohnston@mweb.co.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.

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

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

Avian Wind Farm Bird Sensitivity Map.

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

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,

DOI:10.1080/03014223.2012.741068 http://dx.doi.org/10.1080/03014223.2012.741068

Tuesday, 26 March 2013

COMMENTS ON THE GOEREESOE WEF, NEAR SWELLENDAM

20 March 2013

COMMENTS ON 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 this DEIA. The first question to be answered is why was the original Environmental Assessment Practitioner company, Doug Jeffrey, replaced by Savannah Environmental?

AVIFAUNA

The Avifauna Scoping Reports were prepared by Chris van Rooyen, a recognized specialist in this field who has been involved with this project from the outset, and who has extensive experience with environmental avifaunal assessments in South Africa, including much work in the Overberg. Why has he now been replaced during the Environmental Assessment phase by Bio 3, a Portuguese company with little if any local experience of Southern African birdlife?

In the DEIA report they state they are using previous scoping data supplemented by a 3 day visit in late November 2012. However impressive their stated methodology might appear, the results of this assessment are lacking in confidence and insufficient for EIA purpose.

Their limited knowledge of SA avifauna is evidenced by their inclusion of priority species in Table 7 of such unlikely species at this site of Damara Tern and Palmnut Vulture. There is further evidence of this in Table 9 showing many species (27) that they could not identify at all, or at best at genus level (10). What confidence does this inspire?

This is further compounded by Table 10.3, Appendix IV which lists all species previously recorded in this QDS, but with no attempt made to highlight what species might actually be likely to occur at this inland site. Thus giving rise to an absurd list which includes Albatrosses, Petrels, Gannets and Penguins, and this more than 30 Km from the nearest seashore or ocean!

Their data sources do not include reference to, or data from, the Coordinated Avifaunal Road Count programme at the Animal Demography Unit in Cape Town.

Species of conservation concern which are notably absent or found in small numbers in the transect report (Blue Crane 1 bird!) include, Blue Crane (100%), Denham’s Bustard (40%), Black Harrier (20%), as well as common Overberg species such as Jackal Buzzard (80%). Figures in brackets are the SABAP2 reporting rates.

Table 10 purports to report on raptors and large terrestrial species observed in November 2012, yet the column is headed ‘July.’

No nesting sites were found during the November visit. The peak breeding period of the Blue Crane in the Overberg of mid-December through January has not been assessed. Which is no doubt the reason why no Blue Crane nests were found.

It is surprising that Blue Cranes were not observed near the numerous water bodies on site. Though perhaps not surprising considering the very short, only a matter of minutes, visits to water bodies. Had they had local knowledge or consulted local sources they would have looked more carefully and been alerted to this unexpected finding.

The validity of the statement regarding the Control area that “species richness was similar in both areas” is thrown into doubt by the fact that the two main species of concern, namely Blue Crane and Black Harrier, were not observed in the Control area. Again, local knowledge would have alerted them to this discrepancy.

Several turbines appear to be placed in, or dangerously close, to the 150m riparian buffer zones. 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.

The proposed year of “pre-construction” baseline monitoring covering all 4 seasons, as recommended in the SA Best practice guidelines, has not been completed, with only one very short visit in summer.

This report is grossly insufficient for environmental authorization purposes.

BATS

Of particular concern is that there is no mention of the site falling within 35 km of an important, and one of the largest bat roosts in southern Africa, the De Hoop Guano Cave.

There has not been a full year of bat baseline monitoring, covering all 4 seasons, in accordance with the South African Good Practice Guidelines for Surveying Bats in Wind Farm Developments, 2012, with only one short site visit in October 2012. There are therefore no seasonal data on which to base any reasonable assessment, and therefore by which to guide turbine placement.

There are insufficient data on which to make an assessment for authorization.

VEGETATION

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.

It is essential that the recommendations of the specialist botanist should be accepted and incorporated into the design layout of the turbines and all infrastructure. It would appear that this advice is still being ignored which will result in the irretrievable loss of Critically Endangered Renosterveld categories.

CUMULATIVE IMPACTS

All the potential local and regional cumulative impacts of this and the three proposed neighbouring wind farms, two of which have received DEA authorization, must be addressed comprehensively.

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.

We fully support the comments from CapeNature dated 2 April 2012.

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 expect that all comments in this letter will be taken into account during the remainder of 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