COMMENTS ON LANGHOOGTE WIND FARM DRAFT EIA

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 4^th 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

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. 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

BRAKKEFONTEIN WITHDRAWN!

It is with great pleasure that Greytonian can announce that this ill-conceived wind farm proposal has been cancelled by the developer, Terra Power Solutions. This is what the EAP, Thomas King wrote:

"Dear Interested and Affected Parties and key stakeholders

As you are aware CES recently conducted an Environmental Scoping process for the above mentioned project that was initiated by Terra Power Solutions (TPS) in the Bonnievale area. Over the course of the last few months it has become apparent that the wind resource on the site, which has been subject to an approximately year-long monitoring programme, is not sufficient to justify the project proceeding. This is compounded by the fact that the feed in tariff (the price that the relevant government agency pays to independent power producers - IPPs) for wind energy has substantially decreased from its initial pricing levels, rendering the proposed project financially unviable

Coupled with the environmental sensitivities of the site and its surroundings, as well as the numerous conservation initiatives in various stages of development or implementation in the project area that were brought to CES and TPS attention during the Scoping process, the applicant has decided to withdraw the application. 

Please be aware that the national Department of Environmental Affairs has been informed of the reasons for withdrawal by CES and acknowledgement of this is still awaited from them. Please accept this correspondence as the final round of notification for this project.

Thomas King

Environmental Consultant

Coastal & Environmental Services"

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.

BRAKKEFONTEIN - ANOTHER OVERBERG WIND FARM

Another wind farm proposal has materialised, this time near Stormsvlei on the R317 road to Bonnievale.  It can be seen that all the turbines and infrastructure, including some 20 Km of internal roads are to be placed on ridges in threatened renosterveld at the Eastern extremity of the Riviersonderend Mountains. There will be an enormous loss of natural vegetation with associated disturbance and displacement of birds and other wildlife. Mortality of birds and bats from collision with turbines and associated barotrauma can be anticipated. This industrialisation of the landscape will detract from tourism and may well result in a net loss of local employment. The Draft Scoping Report has been published for comment before 30 September.

If anyone reading this has the slightest interest in the conservation of this environment please register as an Interested and Affected Party at  Thomas King at CESNET. The full DSR can be viewed or downloaded at Brakkefontein. Please submit your comments... Thank you.

BLSA/EWT Best practice guidelines for avian monitoring and impact mitigation at proposed wind energy development sites

These Guidelines were updated in July 2012, and significantly have now been endorsed by the South African Wind Energy Association (SAWEA) and Eskom. BLSA/EWT Avian Guidelines

OUTCOME OF THE APPEAL BY BIRDLIFE OVERBERG AGAINST THE AUTHORISATION OF THE KLIPHEUWEL/DASSIESFONTEIN WIND ENERGY FACILITY

Amendment of the Environmental Authorisation for the proposed establishment of the Klipheuwel/Dassiesfontein  Wind Energy Facility (WEF) and associated infrastructure within the jurisdiction of Theewaterskloof Local Municipality, Western Cape Province.

As a result of the Appeal by BirdLife Overberg, the DEA decision of 27 June 2011 to authorize this development was varied so as to strengthen the requirements for bird and bat monitoring, to specify that the guidelines published by BLSA and EWT should be used, and to instruct the applicant to provide monitoring data on a quarterly basis to all stakeholders, including the Appellants. Here follows a summary of the salient sections:

  

• The bird monitoring programme to be undertaken by an independent bird monitoring specialist

• A batmonitoring programme must be implemented to document the effect of the operation of the WEF on bats. This must commence prior to construction and continue during operation of the WEF

• The bat monitoring programme to be undertaken by an independent bat monitoring specialist

• The reports from the bat monitoring programme will be submitted to affected stakeholders, including the appellants and DEA, on a quarterly basis

• The birds and bat monitoring programmes must cover all listed and threatened species (TOPS), as well as other significant species identified by the respective specialists, and must include collision and mortality date during operation

• Baseline bird and monitoring must continue at least every 2^nd month for as long as possible before, and during the construction phase of the WEF

• Bird impact monitoring must produce data in the format required by the “Best practice Guidelines for Avian Monitoring and Impact Mitigationat proposed Wind Energy Development Sites in Southern Africa”, published by BLSA and EWT

• Bat impact monitoring must produce data in the format required by the “SA Guidelines for Surveying Bats in Wind Farm Developments” published by EWT

• Post constructiom monitoring must start as soon as possible, within the first few weeks of operation, and should last for at least 2 years – as opposed to the original EIA recommendation that monitoring starts 6 months after commissioning and is reviewed after 1 year of operation

• If problems are identified in the first 2 years, mitigation measures should be included in the EMP and monoitoring to continue to determeine the effectiveness of those measures

• The bat monitoring reports must be submitted quarterly to EWT, BLSA, CapeNature and DEA. The reports will assist all stakeholders in identifying potential and additional mitigation meassures and to establish protocols for bat monitoring programmes of EF development in SA

• Should monitoring results reveal serious impact on Threatened or Protected Species (TOPS), including among others, local extinction, all work must cease immediately in that area whilst all relevant authorities are notified

It was admitted by the DEA that a bat report was not considered by them as it had not been provided by the Applicant until long after the final EIA submission. After a retrospecive review the DEA states that it would nevertheless not have come to a different conclusion…

The applicant provided a copy of the Bat and Bird Reports to the Appellants only following the Appeal result. It would not appear that other registered I&APs were afforded this opportunity.

Comments on Langhoogte Final Scoping Report

Please follow the link to read Greytonian's comments on the Langhoogte Final Scoping Report - COMMENTS ON LANGHOOGTE FSR